Office for Nuclear Regulation

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Licence Condition 6, ONR Issues Database Meeting, and SBI-11 “Fire Detection, Suppression, Barriers, Doors and Dampers” Compliance Inspection

Executive summary

Purpose of intervention

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.

Interventions Carried Out by ONR

This intervention included compliance inspections against the following Licence Conditions (LCs):

System Based Inspection, SBI-11 - Fire Detection, Suppression, Barriers, Doors and Dampers, which included:

In addition I attended an ONR Issues Database meeting with the Technical Safety and Support Manager in which we discussed the current open ONR Issues affecting Heysham 2.

Explanation of Judgement if Safety System Not Judged to be Adequate

This system based inspection judged that the system inspected meets the requirements of the safety case and is adequate.

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

The LC6 inspection involved consideration of both generic and local implementation documents as defined within their arrangements with the following areas covered as part of the inspection:

I am satisfied that the arrangements and their implementation for LC6 are to an adequate standard and have rated this element of my inspection through the IIS as 3 (adequate).

From an LC10 perspective, I consider that the knowledge of the safety case by those at Heysham 2 was comprehensive.  There is one shortfall associated with the ability to demonstrate that those performing maintenance tasks associated with fire dampers are adequately trained.  As a result, I have scored this element of my inspection through the IIS as 4 (below standard).  An ONR Issue has been raised in order to capture the shortfall in training to address this non-compliance with the training requirements for the role.

From an LC23 and LC24 perspective, I consider that the operating rules and associated instructions are well understood and embedded at Heysham 2.  There is an outstanding condition report in relation to the surveillance requirements (SR) for fire and hot gas and steam release fire zone boundary doors, which I consider to be more of an anomaly within the arrangements rather than a direct non-compliance.  In addition there is no degradation of plant condition as a result of the surveillance not being fully implemented.  I have therefore scored this element of my inspection through the IIS as 3 (adequate).  An ONR Issue has been raised in order to capture the need to address the anomaly associated with the two surveillance requirements.

From an LC27 perspective, I consider that implementation of safety case through the application of plant locking for the water spray fire protection system (WSFPS) does not appear to meet the intent of the safety case.  It is important to stress that there was no nuclear safety shortfall in terms of the availability of the WSFPS, however, there was uncertainty over compliance with the operating rules as contained within the licensees arrangements.  In addition to this finding, a previous inspection of LC27 which included plant locking identified similar issues.  I judge that the LC27 element of this inspection is below standard and as a result I have scored it as 4 (below standard) through the IIS.  An ONR Issue has been raised to address this shortfall in compliance.

From an LC28 perspective and based upon my sample, I consider that maintenance of the fire systems does not meet the expectations as detailed within ONR guidance due to the non-compliance identified within the Maintenance Schedule.  Given that this non-compliance had not been suspended in accordance with NGL’s approved arrangements, I judge that the LC28 element is below standard and as a result scored a 4 (below standard) through the IIS.  An ONR Issue has been raised to address this shortfall in compliance.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

I am satisfied that the arrangements and their implementation at Heysham 2 for LC6 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.

With regards to the SBI, after considering the evidence and on balancing the  implementation with the relatively minor shortfalls within 3 of the Licence Conditions, I judge that the fire detection, suppression, barriers, doors and dampers system meets the requirements of the safety case and its’ implementation is deemed adequate. 

Four ONR Issues have been raised to address a number of observations raised as a result of the inspection in order to address the shortfalls in compliance.  In addition further observations of minor nuclear safety significance that were made as a result of this system based inspection are to be addressed by NGL in accordance with their own arrangements.  NGL has raised a number of Condition Reports (CR) capturing the observations.

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.