The purpose of this intervention was to undertake Licence Condition (LC) compliance inspections at EDF Nuclear Generation Limited's (NGL's) Heysham 2 power station in line with the planned inspection programme contained in the Heysham 2 Integrated Intervention Strategy (IIS) for 2014/15.
This intervention included compliance inspections against the following Licence Conditions (LCs):
In addition I observed part of a Fuel Route Follow-up Surveillance performed by NGL's independent regulatory function, Independent Nuclear Assurance (INA).
No safety system inspection was undertaken, hence this is not applicable.
The areas covered as part of the LC10 inspection included observation at a fuel route training course, discussions with station staff over their role and training profiles, on-the-job training (OJT), and training provided by external contractors to their own staff. The areas for inspection were selected from ONR guidance relating to LC10, T/AST/027 and were also informed via the observations from previous inspections undertaken.
From an LC10 perspective, I am satisfied that training delivered, OJT, and oversight of contractor delivered training is to a good standard. This is due to the comprehensive nature of the approach to the implementation of the arrangements and the quality of the instruction provided to individuals performing work on the site.
The areas covered as part of the LC12 inspection included re-authorisation of Duly Appointed Persons (DAPs), discussions with a contractor in relation to his suitably qualified and experienced person (SQEP) status, a discussion with an NGL Maintenance Team Leader in relation to assuring the competence of his staff, and a discussion with an NGL Contract Manager (CM) in relation to SQEP of contractors. The areas for inspection were selected from ONR guidance relating to LC12, and utilised the same guidance as for LC10 (above) and were also informed via previous inspections undertaken.
From an LC12 perspective, I am satisfied that the DAPs and SQEPs at Heysham 2 are managed to an adequate standard. This is due to the extent of oversight provided by NGL and the diligence of the contract partners in place. Some shortfalls have been identified in relation to completion of paperwork and follow-up recommendations, however, these are considered to be minor in nature.
The areas covered as part of the LC36 inspection included status of the Management of Change (MOC) associated with 12 hour shift working within the Central Control Room (CCR), application of the MOC risk assessment process, sample of a recent MOC, independent review and audit of the arrangements for LC36, and any changes to the nuclear baseline. The areas for inspection were selected from ONR guidance relating to LC36, T/AST/048 and were also informed via previous inspections undertaken.
From an LC36 perspective, I am satisfied that the Organisation capability at Heysham 2 is to an adequate standard. This is based upon the approach to the implementation, review, and categorisation of the management changes that have been undertaken at Heysham 2 as well as the status in relation to Post Implementation Review of the previous MOCs. I have, therefore, rated this element of my inspection through the IIS as 3 (adequate).
I attended the final day of a fuel route follow-up surveillance and although some minor areas were identified as a result of the plant inspection, the lead evaluator from NGL's internal regulator concluded that they were associated with continuous improvement. I concurred with the findings of the internal regulator based upon my sample into the surveillance.
Information gathering meetings were also held with station staff to discuss routine regulatory matters with no significant concerns identified as a result.
The licence conditions were inspected against ONR's published guidance requirements (as described in our technical inspection guides).
I am satisfied that the arrangements and their implementation at Heysham 2 for LC10 are to a good standard and judge that the outcome of the sample inspection undertaken met with the expectations detailed within ONR guidance. I have therefore rated this element of my intervention an Integrated Intervention Strategy (IIS) rating of 2, good.
I am satisfied that the arrangements and their implementation at Heysham 2 for LC12 and LC36 are to an adequate standard and judge that the outcome of the sample inspection undertaken met with the expectations detailed within ONR guidance. I have therefore rated this element of my intervention an Integrated Intervention Strategy (IIS) rating of 3, adequate.
There are no findings from this inspection that could significantly undermine nuclear safety and no change to the planned interventions and inspections of Heysham 2.