Office for Nuclear Regulation

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System Based Inspection, SB104, Auxiliary Cooling (Including Pressure Vessel Cooling Water System)

Executive summary

Purpose of intervention

The principle purpose of this intervention was to undertake a system based inspection on the auxiliary cooling system. This intervention was undertaken in line with the planned inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS).

Interventions Carried Out by ONR

This intervention included the following:

Through examination of this system, we performed compliance inspections against LC 10: Training; LC 23: Operating rules; LC 24: Operating instructions; LC 27: Safety mechanisms, devices and circuits; and LC28: Examination, inspection, maintenance and testing. Our inspections were based on sampling the implementation of the arrangements in place against each licence condition. I held pre- and post- inspection meetings with Hartlepool management where the inspection agenda was discussed and the outcome of the inspection was communicated.

LC 34 (Leakage and Escape of Radioactive Material and Radioactive Waste) was not applicable to the chosen structures and therefore it was not considered during the inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

This system based inspection judged that the arrangements and their implementation, associated with auxiliary cooling system, met the requirements of the safety case and are adequate.

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

I found the licensees arrangements under LC 22 (modifications to plant) to be adequate (IIS Rating - 3 adequate). The arrangements for designing commissioning programmes had scope for improvements.

After a review of the year, I found the licensee's emergency arrangements to be progressive and adequate (Rating - 3, adequate).

The findings from the team of ONR specialist assessment inspectors undertaking the system based inspection undertaken on the auxiliary cooling systems are detailed below.

From an LC10 perspective, the overview of the safety case by those involved from EDF Energy Nuclear Generation Limited (NGL) demonstrated that they have adequate knowledge and experience in the areas of the safety case as well as the operating rules and instructions in place for the PVCW, LPBUC, RACW, THACW and TPVCW systems inspected.

The inspection of staff training records and profiles found a shortfall associated with the essential training courses required for a particular role. However, during the inspection the particular individual demonstrated his understanding and experience of the system. Therefore, I consider the LC10 element of this inspection to be adequate, warranting an associated IIS rating of 3.

From an LC23 perspective, based on the evidence sampled during this inspection, the implementation of the technical specifications, commentaries, and schedules has been demonstrated to be consistent with the claims and arguments presented within the safety case for the PVCW, LPBUC, TPVCW, RACW, THACW systems inspected. I consider the LC23 element of this inspection to be adequate, warranting an associated IIS rating of 3.

From an LC24 perspective, based on the evidence sampled during this inspection, I was content that the provisions in place as required by the PVCW, LPBUC, TPVCW, RACW, THACW safety cases were adequately implemented at Hartlepool. The operating rules under LC23 have been implemented through station and plant operating instructions, which was confirmed by sampling documents and records during the inspection. I consider the LC24 element of this inspection to be adequate, warranting an associated IIS rating of 3.

From an LC27 Safety mechanisms, devices and circuits I have considered the LPBUC and the TPVCW systems. In general, the duty holder was able to demonstrate an adequate level of compliance against LC 27. I consider that the LC27 element of this inspection to be adequate, warranting an associated IIS rating of 3.

Examination, inspection, maintenance and testing under LC28 involved sampling a number of maintenance tasks including completed records and check sheets as well as consideration of asset condition as part of the plant inspection. The inspection highlighted that the RACW tanks are not inspected and the concealed LPBUCS pipework has not been inspected as part of the Pipework Inspection Programme. Minor shortfalls were observed regarding the leak management. I have raised an ONR issue to follow the inspection of the concealed LPBUCS pipework. However, I am content that the Licensee will be capturing the remaining observations within Condition Reports. I consider the LC28 compliance of this inspection to be adequate, warranting an associated IIS rating of 3.

The licence conditions were inspected against ONR's published guidance requirements (as described in our technical inspection guides).

Conclusion of Intervention

After consideration of all the evidence witnessed during the sampling inspections undertaken against LCs 10, 23, 24, 27 and 28, we consider that the arrangements and their implementation, associated with auxiliary cooling system, meet the requirements of the safety case and are deemed adequate. I consider the licensee's arrangements under LC 22 and the emergency arrangement to be adequate.

A number of observations were made as a result of this system based inspection, however, given that they are of minor nuclear safety significance, I am content that they be addressed by NGL in accordance with their own arrangements.

There are no findings from this inspection that could significantly undermine nuclear safety and no change to the planned interventions and inspections of Hartlepool.