Inspections were undertaken as part of a programme of planned interventions that are listed in the Hartlepool Integrated Intervention Strategy (IIS) plan.
A system based inspection was undertaken by the nominated ONR Site Inspector and a Technical Specialist from AMEC Foster Wheeler. The aim of the inspection was to confirm that the Hartlepool Additional Fuel Storage Facility (AFSF) with its associated operating instructions and maintenance schedule met the safety case requirements. We inspected the AFSF against the following licence conditions:
The inspections were based on sampling the implementation of the arrangements in place against each licence condition.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
This system based inspection judged that the AFSF meets the requirements of the safety case and is adequate.
A sample of EDF Energy Nuclear Generation Ltd (NGL) training records and procedures found AFSF staff to be compliant against a systematic and progressive training process. It was also evident that the training of key personnel is actively managed by the Station. Hence, I judge that compliance with LC10 to be adequate, IIS rating 3.
The current Operating Rules include Off-load Pressurised Refuelling (OPR) that should have been removed when the Hazards and Interlocks associated with OPR were removed several years ago. In light of this, I judge compliance with LC23 to be below standard, IIS rating 4. NGL have been actionned to correct the AFSF operating rules before the next refuelling outage.
The OPR issues raised against the operating rules rendered the operating instructions out dated and unclear. I judge that compliance with LC24 was below standard, ISS rating 4.
Noting that there is an ongoing discussion between NGL and ONR as to what constitutes a safety mechanism, device and circuit (SMDC), I inspected compliance against the intent of LC27, i.e. that plant is not operated, inspected, maintained or tested unless suitable and sufficient mechanisms, devices and circuits are properly connected and in good working order. With respect to the AFSF equipment I judged that compliance with LC27 was adequate, IIS rating 3.
The AFSF equipment is routinely checked and suitable and sufficient maintenance is undertaken. Therefore, I judge compliance with examination, inspection, maintenance and testing under LC28 to be adequate, IIS rating 3.
From the evidence sampled during this inspection in respect of LC34, leakage and escape of radioactive material and radioactive waste, it is considered that AFSF system is being appropriately maintained. Hence, I have judged that compliance with LC34 to be adequate, IIS rating of 3.
The current situation is acceptable since NGL have agreed to correct the significant Technical Specification inconsistency before the next refuelling outage and to furnish a programme to address the other issues raised. Issue 3108 has been raised to track closure of the actions.
The licensee of Hartlepool power station has agreed to correct the AFSF operating rules before they are next required (the next refuelling outage). From the evidence gathered during this intervention, I do not believe there are any matters that may impact significantly on nuclear safety. 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.