This intervention involved a compliance inspection against Licence Condition (LC) 7 – Incidents on site and was undertaken utilising ONR’s guidance document NS-INSP-GD-007 – Incidents on site.
The guidance document requires inspectors undertaking compliance inspections against LCs to consider both the arrangements that are in place, together with their associated implementation.
As part of this intervention, I, the ONR Nominated Site Inspector, was supported by Human and Organisational Capability and Internal Hazards specialist inspectors. The inspections were based on sampling the implementation of the arrangements in place at the station against LC7 EDF NGL arrangements.
The intervention was performed in line with ONR’s guidance requirements (as described in the technical inspection guides, which can be found at www.onr.org.uk/operational/tech_insp_guides/index.htm).
As part of the intervention, the ONR inspectors attended the station’s Daily Screening Meeting (DSM).
No safety system inspection was undertaken as part of the LC7 compliance inspection hence this section is not applicable.
The LC7 inspection sampled EDF NGL Heysham 2 arrangements and their implementation in the following areas:
From my inspection of the arrangements and their implementation, I consider both to be robust. Specifically, I saw evidence that the Licensee raises, classifies and analyses condition reports consistently and in line with EDF NGL’s arrangements. I also noted that trend analyses are performed regularly and review meetings result in meaningful actions and priorities. I also saw evidence that actions are closed out satisfactorily and effectiveness reviews are conducted in line with the arrangements.
As part of the intervention, the ONR inspectors sampled the station’s follow up of two trends from the Learning Trend Review Board Reports. In both cases, I was satisfied that the actions had been completed and adequately closed out.
I also sampled the effectiveness of action management and close out from a Significant Adverse Condition Investigation (SACI). I noted that two of the actions associated with the SACI were closed appropriately and a single action remained open following an extension. Although justification for new dates and action close out narratives are not always entered in the AMS, I discussed it with the station as an opportunity for improvement and I am content that it is not a significant concern which does not require further regulatory follow-up.
I discussed the Red and Amber status of trending in timeliness of investigations, with investigations extending beyond EDF NGL’s expected completion targets. The station produced evidence to support that there was an improving trend in the timeliness of investigations, re-dating of actions more than twice is avoided as a management priority, and further training is planned to increase the number of Suitably Qualified Experienced Personnel resource to carry out investigations. On this basis, I am content that EDF NGL continues to address open issues and investigations at Heysham 2 in a satisfactory manner.
The ONR inspectors observed the Daily Screen Meeting (DSM). In my view, the meeting evidenced that there is a suitable level of challenge and review of the nature and status of ongoing investigations at Heysham 2.
Based on the above, I judged that the implementation of the LC7 arrangements at Heysham 2 is adequate and have rated this element of the inspection as Green.
Overall I consider that the LC7 arrangements and their associated implementation met the required standard, and the intervention was therefore rated through the IIS as Green.
There are no findings from this inspection that could significantly undermine nuclear safety nor require a change to the planned interventions and inspections of Heysham 2.