Office for Nuclear Regulation

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Systems Based Inspection SBI-001 Sea Defences

Executive summary

Purpose of Intervention

The purpose of this intervention was to carry out a System Based Inspection (SBI) of the sea defences, flood protection and drainage system at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station.

The intervention was planned in accordance with ONR’s Integrated Intervention Strategy (IIS) for Hartlepool 2019/20.

Interventions Carried Out by ONR

The ONR external hazards and civil engineering specialist inspectors performed a System Based Inspection (SBI) of the sea defences, flood protection and drainage system to judge the system performance against its safety function.  Through examination of this system and associated sub-systems, we performed compliance inspections against the following Licence Conditions (LCs) :-

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

Explanation of Judgement if Safety System Not Judged to be Adequate

From the areas sampled during this inspection, we judged that overall the sea defences flood protection and drainage system met the requirements of the safety case.

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

With respect to the system based inspection performed the following judgements were made:-

LC 10 (Training): We considered EDF’s hazards awareness training and Pond Package Cooling System training for Operatives. We judged that for the sample inspected the LC10 arrangements were adequate and an inspection RAG rating of Green was merited for this licence condition.

LC 23 (Operating rules) and LC 24 (Operating instructions): We considered the implementation of limits and conditions through technical specifications (operating rules) and station operating instructions. We further considered the principal safety case claims made on operator actions. We concluded that in the areas sampled the safety case was adequate for the safety of the operations being undertaken. Written limits and conditions had been identified and works were being controlled and carried out in compliance with such operating rules. In conclusion we were satisfied that from the sample taken both LC23 and LC24 arrangements were adequate and a Green RAG rating was given.

LC 27 (Safety mechanisms, devices and circuits): We focused on seismic monitoring equipment and the pond anti-syphon valves and safety case claims. Pond cooling is a safety function with the potential for failure in a seismic event. The station operating instructions for the pond following a seismic event include monitoring of the cooling water supply to the pond and activated fuel storage facility to ensure that the required safety mechanisms to maintain pond cooling after a seismic event are checked and continue to function adequately. We also checked the associated maintenance instructions and maintenance records. We judged that for the sample inspected the LC27 arrangements were adequate and an inspection rating of Green was merited for this licence condition.

LC 28 (Examination, inspection, maintenance and testing): Areas considered included the licensee arrangements; we reviewed the maintenance schedule focusing on elements of the flood defences, radioactive waste, ponds, and general drainage. We inspected the identification, prioritisation, sentencing and repair of defects. We reviewed aspects and compliance with the Licensee’s written schemes including technical guidance notes. We judged that for the sample inspected the Licensee had made and implemented adequate arrangements including the provision of a plant maintenance schedule. Examination, Inspection, Maintenance and testing was being carried out regularly and systematically by suitably qualified and experienced personnel at the intervals specified within the plant maintenance schedule.  We therefore concluded that the LC28 arrangements were adequate and an inspection rating of Green was given for this licence condition.

LC 34 (Leakage and escape of radioactive material and radioactive waste): We considered drainage systems that may be subject to leakage and escape of radioactive material or radioactive waste. We considered the ponds, leakage detection systems, active waste tanks and active waste drainage. We judged from the sample taken that radioactive materials and radioactive waste were being adequately controlled. We further concluded that a leakage or escape of such material would be detectable and from historic records satisfied ourselves that leaks would be notified, recorded, investigated and reported. We concluded that the LC34 condition was therefore satisfied. A Green RAG rating was given.

Safety Culture aspects: Safety Culture was considered additionally to the activities undertaken for the SBI. Generally we found the safety culture on site was good. Aspects considered included such areas as: Personal accountability; leadership accountability; communication; respectful work environment; problem identification and resolution; work planning; decision making; continuous learning and questioning attitude. We fed back aspects of note both positive and negative to the Licensee during the hot debrief session.

Conclusion of Intervention

Following the system based inspection of the, sea defences, flood protection and drainage system we judged that the expected standards in accordance with Licence Conditions LC10, 23, 24, 27, 28 and 34 had all been adequately met and were hence rated as Green under the ONR RAG rating system (Refer ONR-INSP-GD-064). 

Overall, we judged that the sea defences, flood protection and drainage system met the requirements of the safety case. There are no findings from this intervention that would significantly undermine nuclear safety at Hartlepool Power Station. At present, no additional regulatory action is needed over and above the planned interventions of Hartlepool power station as set out in the Integrated Intervention Strategy, which will continue as planned.