Heysham 2 Power Station - Control and Supervision of Operations and Maintenance - Theme 1 Intervention
- Site: Heysham 2
- IR number: 17-166
- Date: November 2017
- LC numbers: 12, 23, 24, 25, 26, 27, 28
Purpose of Intervention
This was a planned inspection at EdF Energy Nuclear Generation Ltd's (NGL's) Heysham 2 Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).
The work was carried out in-line with the inspection programme contained in the Heysham 2 Integrated Intervention Strategy (IIS).
As part of the inspection, a team of three Organisation for Economic Cooperation and Development (OECD) Working Group on Inspection Practices (WGIP) international observers observed the ONR inspection in order to determine any good practices, differences or improvements in inspection methods. This is a normal practice of observations of OECD member states in order to improve nuclear regulatory inspection practices. Their findings will be shared with regulators from member states across the world.
Interventions Carried Out by ONR
During this intervention, the following key activities were undertaken:
- Themed inspection examining control and supervision of operations and maintenance.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system based inspection was undertaken, hence not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We evaluated compliance against the following site licence conditions during the themed inspection:
- Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons) - We sampled the training database of duly authorised persons controlling and supervising operations and found the training supporting their appointments to be up to date. In addition, NGL had succession plans in place. We therefore assigned a rating of Green (no formal action) for LC12 compliance.
- Licence Condition 23 (Operating Rules) - We sampled Control Room logs, including the Action Tracking log and Significant Abnormalities Log. Based upon the evidence, the station demonstrated that operations were controlled and carried out in compliance with safety case limits and conditions. We therefore assigned a rating of Green (no formal action) for LC23 compliance.
- Licence Condition 24 (Operating Instructions) - The work activities observed during the inspection were conducted in accordance with written instructions. We sought clarification in the use of ‘tool pouch', which is meant to be used for minor plant remediation work. We assigned a rating of Green (no formal actions) for LC24 compliance.
- Licence Condition 25 (Operational Records) - The sampled document records, safety case limits and conditions and found them to be adequate. We therefore assigned a rating of Green (no formal actions) for LC25 compliance.
- Licence Condition 26 (Control and Supervision of Operations) - We examined hand over certificates and return to service logs. Documentation requirements appeared to be sound, but we did find that in the records sampled not all steps were positively reported eg confirmation checks that plant labelling and housekeeping were in order. We also noted that there appeared to be a discrepancy between information systems for eg operator aids and Control Room Defects. Our observation of setting to work and pre-job briefs for maintenance staff was judged to be satisfactory, however we judged that similar briefs observed for contractors was not of the same standard. Maintenance activities on the plant were considered to be in accordance with NGL expectations, this was a minor shortfall for which a regulatory issue has been raised and its progress will be followed by the nominated site inspector. We assigned a rating a Green (no formal actions) for LC26 compliance.
- Licence Condition 27 (Safety Mechanisms, Devices and Circuits) - We sampled the availability of safety mechanisms, devices and circuits providing reactor protection, by examination of the main Central Control Room logs and by discussion with control room operators. We assigned a rating of Green (no formal actions) for LC27 compliance.
- Licence Condition 28 (Examination, Inspection, Maintenance and Testing) - We sampled arrangements for planning maintenance activities and for dealing with emergent maintenance issues. We found that there was evidence of good cross functional working, eg with Operations and Engineering, at daily work review meetings to ensure optimal prioritisation of maintenance activities. We sampled some of the work of the Diagnostic and Response Team (DART), and found the arrangements to be adequate. We sampled a number of maintenance activities and concluded they were conducted by suitably qualified and experienced persons in accordance with written instructions and were subject to control and supervision commensurate with the nuclear safety significance of the task. We therefore assigned a rating of Green (no formal actions) for LC28.
- Management of Health and Safety at Work Regulation 5 (Health and Safety Arrangements) - We examined various elements of work management and control of work processes. There was sufficient evidence that control arrangements were being considered during the work planning process. We therefore assigned a rating of Green (no formal actions) for MHSW Reg 5.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
Conclusion of Intervention
The themed inspection examined compliance against LC12, LC23, LC24, LC25, LC26, LC27, LC28 and MHSW Reg 5. Overall, based on the evidence sampled, inspectors judged that legal requirements were met. We observed a number of work activities, examined management arrangements and sampled key documentation covering plant status control, work planning and work execution. In all cases the level of control and supervision was commensurate with the safety significance of the associated task. Two minor non compliances were identified for which two regulatory issues have been raised. ONR has assigned a rating of Green against the each of the legal requirements inspected.
OECD WGIP Findings
The OECD WGIP observers, nuclear safety inspectors from the Czech Republic, Germany and Japan, found the new ONR themed inspection practice interesting and complemented ONR on their inspection guidance documentation. A formal report will be written in due course which will include any learning for ONR. The report will be shared with OECD member states across the world.