Office for Nuclear Regulation

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LC32 and LC34 Compliance inspection

Executive summary

Purpose of intervention

The purpose of this intervention was to undertake Licence Condition (LC) compliance inspections at EDF Nuclear Generation’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):

Explanation of Judgement if Safety System Not Judged to be Adequate

No safety system inspection was undertaken, hence this is not applicable.

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

Since the last LC32 inspection performed in December 2013 the revised Radioactive Waste Safety Case (RWSC) has been implemented at Station.  As a result I elected to inspect progress with the implementation of the case including plant modifications and examination, inspection, maintenance and testing. 

The revised safety case contains a number of recommendations so I sought confirmation that NGL considered the case to be adequate.  NGL confirmed during the inspection that the recommendations were associated with realising improvements that drove the risk to As Low As Reasonably Practicable (ALARP) as opposed to the identification of safety shortfalls with the extant safety case.  In addition NGL confirmed that the RWSC had been captured within relevant Safety Case Update Documents.

An overview was provided of the quantities of radioactive waste currently stored on site and since the last LC32 inspection there has been a steady reduction in the quantities of Low Level Waste to a level of about one third of what was being stored last year.  The miscellaneous wastes (previously referred to as non-conforming wastes) have dropped slightly, however there is work on-going to address this relatively low volume of waste.        

I am satisfied that the arrangements and their implementation for LC32 are to an adequate standard and have rated this element of my inspection through the IIS as 3 (adequate).

As part of the LC34 inspection I sampled the work that had been undertaken associated with the improvements further to the implementation of the RWSC including a number of Work Order Cards associated with the maintenance.  A plant inspection was performed of the Active Effluent Treatment Plant (AETP), which included visiting the AETP control room to view the updated active drains control system and to discuss the proposed modification to the AETP control system that is being implemented.

The Fuel Route Engineer provided an overview of the modifications that have been undertaken during the past 12 months.  There has been extensive work undertaken associated with the Active Effluent Treatment Plant (AETP) including the discharge chambers and the implementation of a replacement control system to be installed to control discharges.  It was positive to note the extent of work involved in the replacement of the control system including line by line replication and review of the code as well as Independent Verification (IV) by station specialists.

I recognised the positive work that had been undertaken associated with the improvements to nuclear safety associated with the installation of modifications; however, some elements of maintenance had not yet been adequately addressed by Station.  ONR received a letter in January 2014, which stated that it was the intention of station to focus on completing the outstanding AETP and Plant Water Treatment Plant (PWTP) maintenance routines in 2014.  Whilst this was not a formal commitment to ONR, it was disappointing to note the limited progress that had been made in addressing the maintenance elements.  NGL are to write a letter to ONR explaining the current position with the maintenance and I will consider its’ content upon receipt.    

I am satisfied that the arrangements and their implementation for LC34 are to an adequate standard and have rated this element of my inspection through the IIS as 3 (adequate).

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 LC32 and LC34 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 my intervention with 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 are required.