The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at EDF Nuclear Generation’s (NGL’s) Hartlepool power station in line with the planned inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS) for 2014/15.
A system based inspection of the Fuelling Machine was undertaken by the nominated ONR Site Inspector and a supporting Technical Specialist. The aim of the inspection was to confirm the adequacy of the implementation of the safety case with respect to the fuelling machine and against the following licence conditions (LC):
I inspected recent reported events against the requirements of LC7, “Incidents on site”.
I inspected recently modified operating instructions against the requirements of LC24 “operating instructions”.
The inspections were based on sampling the implementation of the arrangements in place against each licence condition. Meetings were held with key site personnel and the main findings of the discussions were communicated.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
I judged that overall the Fuelling Machine system meets the requirements of the safety case and is deemed adequate.
There was clear evidence of a task to training matrix, training programmes relevant to specific roles and qualification manuals recording evidence of achievement. The inspection did however identify a number of opportunities for improvement which were discussed with the station. I judge that compliance with LC10 is adequate, IIS rating 3.
Having reviewed the Technical Specifications (Tech Specs) relating to the Fuelling Machine it became clear that the specifications still contain information regarding pressurised re-fuelling which is no longer practiced at Hartlepool. The Tech Specs would also benefit from further detail to include control rod handling and interlock availability. In light of this, I judge compliance with LC23 to be below standard, IIS rating 4.
The arrangements and operating instructions that were in place regarding the use of the Fuelling Machine were acceptable. Links between the Tech Specs and the relevant operating instruction were easily identified. However, the shortfalls in the Tech Specs were manifest in the operating instructions. In light of this, I judge compliance with LC24 to be below standard, IIS rating 4.
The Safety Mechanisms relating to the Fuelling Machine are all listed on the Hazard Interlock Schedule which links relevant interlocks back to the safety case. I judge that compliance with LC27 was adequate, IIS rating 3.
The Fuelling Machine aspects of the maintenance schedule were found to contain an adequate level of maintenance regarding the key components relevant to safety. The evidence sampled demonstrated maintenance was being carried out in accordance with the maintenance schedule. I judge the 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 the Fuelling Machine function to contain radwaste is being appropriately inspected and maintained. Hence, I have judged that compliance with LC34 to be adequate, IIS rating of 3.
I judged compliance with LC 7 to be adequate for events reported at Hartlepool since the commencement of the outages on both reactor 1 and 2. The events sampled were good examples of event investigation, reporting and corrective action. I have therefore rated this element of my inspection through the IIS as 3 (adequate).
I judged the recently amended operating rules to be appropriate and progressive. In general they were clear and consistent with the principles presented in ONR guidance. I have therefore rated this element of my inspection through the IIS as 3 (adequate).
From the evidence gathered during this intervention, there are no findings that could significantly undermine nuclear safety and hence no change to the planned interventions and inspections of Hartlepool are required. However, although the current Tech Specs meet the fundamental safety case requirements they do require review and update to make them clearer and to reflect the current operations at Hartlepool.
The station were left actions to review the Fuel Route Tech Specs and Operating Rules to eliminate pressurised refuelling, clarify the pre-requisites of control rod handling and review the completeness of engineering training records. An ONR Issue was raised to track progress of these actions and will be discussed as part of the planned quarterly review of the issues database at Hartlepool.