During early 2013 EDF Energy Nuclear Generation Limited (NGL) experienced a number of minor fire events including at Hartlepool. This led to a company wide focus on improving fire safety, with a number of initiatives aimed at improving the management of fire safety issues, including the management transient combustibles, improving the management of oil leaks, improving the condition of fire protection and suppression systems, etc. ONR sampled into this improvement both at station and at corporate level. Across the company the incident of fire events fell through the second half of 2014, but the company has accepted that the focus on improving fire safety still remains.
Despite the improving trend in many of the metrics that the station and the company use to measure differing aspects of fire safety, Hartlepool experienced three fire events within six weeks (first on 18 March 2014, third on 24 April 2014). All were small and contained, and rapidly extinguished without any significant nuclear safety concern, however the ONR Nominated Site Inspector requested that these fire events be followed up.
The purpose of this inspection was to look into the quality of station investigations of fire events and the capture of learning points for improvement, and also whether the learning from the company initiatives in 2013 should have prevented the events in 2014. This is a reactive inspection as it was not originally planned within Hartlepool's Integrated Inspection Strategy (IIS).
The intervention consisted of a detailed examination of the investigation of a number of recent fire events at Hartlepool and the learning from experience processes followed by the station.
Discussions were held with various NGL staff involved in fire investigations, including sponsoring managers for the investigations, participants in investigation teams, members of the management review board for investigation reports, and with the local manager responsible for the process.
A meeting was held with the internal regulator (SRD -Safety and Regulation Division), particularly regarding a "fire referential" inspection that they carried out in 2013.
Discussion with an independent safety expert, who had also carried out a review of fire safety during 2013, and had returned to look at the progress on implementing improvements.
Meetings were also held with NGL staff involved in management of support contracts, and also with contract partners.
No safety system inspection was undertaken, hence this is not applicable.
The inspection raised questions over the detailed implementation at Hartlepool of the processes for investigating events and learning from them, and also in the control of maintenance work carried out at the site - both work carried out in-house, and work including the use of contractors. There was recognition by NGL that improvements are required to both these areas.
At the closeout meeting I gave the uncompromising message that all of the fire events that we had looked would not have occurred if NGL had achieved the high standards of nuclear professionalism that they set up to achieve. However we recognised that all the fire events were terminated without significant damage, and before they grew to a size that they would have led to either a loss of safety related plant, or to a loss of defence in depth.
With respect to LC7, Incidents on site, I have rated this inspection as 4 (below standard) against the approach of the Integrated Intervention Strategy (IIS)). This is because whereas the fundamental requirements have been met, my judgement is that there are some weaknesses in the implementation of the procedures.
Similarly, against LC26, Control and supervision of operations, I have rated this inspection as 4 (below standard) using the guidance within the IIS rating table. Again, this is because although company procedures appear to have sound features, we identified are some weaknesses in how these were working at Hartlepool.
The licence conditions were inspected against ONR's published guidance requirements (as described in our technical inspection guides).
We provided a detailed overview of the major findings from the inspection with station management, and confirmed that our next step was to reach a collegiate decision within ONR on any appropriate action, using our enforcement management model as a guide.