Office for Nuclear Regulation

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Heysham 2 - LC7 and LC36 inspections

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection activities at EDF Energy Nuclear Generation Limited’s (NGL’s) Heysham 2 power station in line with the ONR’s planned inspection programme contained in Heysham 2’s Integrated Intervention Strategy (IIS) for 2018/19.

The LC36 intervention was carried out by the ONR Leadership and Management for Safety (LMfS) specialist inspector who was joined by one of NGL’s independent nuclear assurance evaluators. The LC7 intervention was undertaken by the nominated site inspector supported by the LMfS specialist inspector

Interventions Carried Out by ONR

The LMfS inspector undertook a licence compliance inspection of NGL’s arrangements for Licence Condition (LC) 36 (Organisational Capability) which requires that ‘the licensee shall provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site’.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

The nominated site inspector also undertook the following regulatory activities;

Explanation of Judgement if Safety System Not Judged to be Adequate

No system based inspection was undertaken hence, this is not applicable for this intervention.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The station presented evidence to show how it was managing its human resources and managing organisational change.
We examined the arrangements in place for managing organisational change and sampled a number of changes in order to judge whether they were appropriately categorised and whether risks were identified and managed.

We reviewed capability requirements of the stations Emergency Scheme and examined how resilience of roles within the scheme was managed. We judged the scheme to be well managed and there were clear succession plans.

Based on our sample of interviews, observations and document reviews we judged that there are effective processes in place to manage and monitor human resources and organisational change. We identified a number of positive findings and we also identified some opportunities where the station can improve the effectiveness of its activities in this area and we provided advice.

Overall, we judge the licensee was meeting relevant good practice when compared to ONR guidance and have therefore assigned a rating of Green (no formal action) for LC36 compliance.

For LC 7, we focused on the adequacy of investigations and the associated process for ensuring that those leading investigations are competent. Furthermore, to judge whether the station is adequately assessing the LFE (Learning From Experience) from events across the fleet by implementing the relevant findings. We reviewed a Significant Adverse Condition Investigation (SACI) into two trips associated with a relatively newly installed station transformer protection system, a number of Mandatory Evaluations (MEVLs) and the training arrangements for licensee staff leading investigations on site.

Overall, we judged that the licensee’s arrangements meet relevant good practice for organisational learning. The aforementioned SACI was of a high standard, which highlighted some key findings associated with gaps in project governance and oversight. As these gaps are with respect to LC 22 compliance, I will take these forward separately after discussions with the corporate Inspector. For Licence Condition 7, I consider that an inspection rating of Green is appropriate.

Conclusion of Intervention

There are no findings from this inspection that could significantly undermine nuclear safety and no change is necessary to the planned interventions and inspections at Heysham 2 as a result.