Heysham 1 Power Station - System Based Inspection (SB11) - Fire Protection, joint inspection with a team from EDF NGL’s Independent Nuclear Assurance Department
- Site: Heysham 1
- IR number: 16-110
- Date: September 2016
- LC numbers: 10, 23, 24, 27, 28, 34
Purpose of Intervention
The purpose of this intervention was to carry out a joint inspection of fire protection systems with EDF Nuclear Generation Limited’s (NGL’s) Independent Nuclear Assurance (INA) Department. The inspection constituted both a system based team inspection under NGL’s internal processes, and an ONR system based inspection of compliance with Licence Conditions (LC) in line with the planned inspection programme contained in the Heysham 1 Integrated Intervention Strategy (IIS) for 2016/17.
Interventions Carried Out by ONR
This intervention: consisted of a System Based Inspection, SBI-11 - Fire Detection, Suppression, Barriers, Doors and Dampers, which included compliance inspections against the following Licence Conditions (LCs):
- LC10 – Training
- LC23 – Operating Rules
- LC24 – Operating Instructions
- LC27 – Safety Mechanisms
- LC28 – Examination, inspection, maintenance, and testing
Explanation of Judgement if Safety System Not Judged to be Adequate
From the areas sampled during this inspection, I judged that overall the fire protection systems met the requirements of the safety case and are adequate.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The joint inspection with INA was a system based inspection. I ensured during the planning phase of the inspection that the approach and the evidence gathered would be capable of allowing me to make judgements against the licence conditions that would ensure it met the requirements of ONR’s process for system based inspection.
The team found it worthwhile to raise two OFIs (opportunities for improvement) and left several other low-level issues for station to progress. I have considered the significance of each low-level issue and confirm that this approach is appropriate and that none require specific tracking by ONR. INA also reported on the overall health of the fire protection systems for the five aspects. The feedback from the joint inspection was well received by station management, both because the overall message was positive, and also that the findings would allow additional focus on improvements.
With respect to the SBI against ONR’s approach I was able to make the following judgements:
- LC 23 (Operating Rules) – the inspection included reviewing the relationship between the technical specifications and the modes of compliance for plant operation. It also covered aspects of surveillance. Based on the evidence sampled, I judge that that suitable and sufficient conditions and limits have been derived from the current safety case for the fire protection systems and that these are adequately implemented on the plant. I judged that there are no significant shortfalls when compared with appropriate benchmarks for LC 23 compliances and therefore assigned an inspection rating of green.
- LC 24 (Operating Instructions) – the inspection looked at a number of supporting procedures associated with the fire protection systems including procedures for surveillance. Particularly noteworthy was a station schedule for Compensatory Fire Protection which identifies pre-agreeing measures when fire systems are to be removed from service (for example for testing, maintenance or repair). The evidence sampled showed the operating instructions provided to station staff were appropriate to ensure that operations that could affect safety are adequately controlled and that relevant operating rules are implemented. I judged that there this met my understanding of ONR’s expectations and therefore assigned an inspection rating of green for LC24 compliance.
- LC 28 (Examination, Inspection, Maintenance and Testing) – during the plant walkdowns, the inspection included several plant areas where plant was out for maintenance. The team also sampled maintenance requirements both for passive and active fire systems (both detection and suppression). A number of minor areas of poor plant condition were shared with station plant management. When checked, most (but not all) of these had been already captured on work order cards for future repair or improvement. Plant management were receptive to INA’s suggestion of reinforcing messages about tolerance of plant conditions, and had planned some improvements in this area. Notwithstanding these minor issues, I judge that overall compliance with LC28 in the areas sampled meet my understanding of ONR’s expectations and therefore have assigned an inspection rating of green to LC28 in this SBI.
- LC 10 (Training) – We examined several areas of training during the inspection. This included discussions on the training of operators in making judgements over appropriate actions when fire protection systems are taken out of service, and on inspection staff looking at the condition of fire barriers and fire doors. There was also a meeting with training management as part of the joint inspection. The balance of the SBI was on the safety case and the operations and maintenance of the plant, but sufficient evidence was gathered to provide an IIS score for LC10 compliance. I judge that in the areas sampled my understanding of ONR’s expectations have been met and therefore have assigned an inspection rating of green to LC10.
- LC 27 (Safety Mechanisms, Devices and Circuits) – With respect to the fire protection system, I have interpreted the application of plant locking via the “orange band” visible compliance approach as a safety mechanism. The application of this was viewed for several systems during the plant walkdowns as part of the joint inspection. In the plant areas visited, there was no sign of any failure to comply with this approach, and it was well understood by station personnel during interviews. I judge that the LC27 element of this inspection meets ONR’s expectations and I have assigned an inspection rating of green to LC27.
- LC 34 (Leak and Escape of Radioactive Material and Radioactive Waste) – the joint inspection did not cover any area where fire protection systems could lead to leak and escape of radioactive material and radioactive waste either directly or indirectly so I have not assigned an inspection rating to LC34 compliance.
Conclusion of Intervention
Following the system based inspection of fire detection, suppression, barriers, doors and dampers systems I judged firstly that the company had benefited from the joint inspection in which I participated. This had generated some valuable learning points and actions to improve the station focus. Secondly I judged that compliance with LC10, 23, 24, 27 and LC28 met the expected standards and were rated as green. Overall I concluded that the systems met the requirements of the safety case.
There are no findings from this inspection that could significantly undermine nuclear safety. At present, no additional regulatory action is needed over and above the planned interventions of Heysham 1 power station as set out in the Integrated Intervention Strategy, which will continue as planned.