Office for Nuclear Regulation

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LC23 (Operating Rules) and LC24 (Operating Instructions) Compliance Inspection

Executive summary

Purpose of intervention

The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at EDF Energy Nuclear Generation Limited (NGL) Heysham 2 power station in line with the planned inspection programme contained in the Heysham 2 Integrated Intervention Strategy (IIS).

Interventions Carried Out by ONR

This intervention included a compliance inspection against the following Licence Condition (LC):

The inspection undertaken utilised ONR guidance documents, NS-INSP-GD-023 and NS-INSP-GD-024, which require inspectors undertaking compliance inspections against these LCs to consider both the arrangements that are in place together with their associated implementation.

The intervention was undertaken as a planned joint inspection with the Torness Nominated Site Inspector and a Nuclear Associate as part of training and development. 

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

The following areas were covered as part of the LC23 inspection:

It was recognised during this inspection that NGL had not completed the review of technical specifications as had been committed to during the LC23 inspection in July 2013.  NGL accepted that they had not made progress in addressing the shortfall and recognised the shortfall in compliance with their own arrangements and the expectations as detailed within ONR guidance.  As a result an ONR Issue was raised. 

It should be noted that the remainder of the LC23 inspection found robust processes in place for the implementation of the arrangements for operating rules, which was further reinforced by the plant inspection.

Notwithstanding the shortfall associated with the outstanding review of the operating rules, I consider the arrangements for LC23 to have been adequately implemented and hence warrant an associated IIS rating of 3 (adequate).

The following areas were covered as part of the LC24 inspection:

From an LC24 perspective, based on the evidence sampled during this inspection I consider the arrangements to have been implemented to a good standard and hence warrant an associated IIS rating of 2 (good).

The plant inspection was performed which involved discussions at two plant areas and considered elements of both LC23 and LC24.  The areas were identified by visiting the Work Execution Centre (WEC) and sampling work associated with the replacement of a nuclear significant fire barrier and some reactive work being performed by the Diagnosis And Response Team (DART) associated with a generator coolant pump. 

In the case of both plant inspections we observed a very comprehensive and professional approach to the work being undertaken by the individuals involved with a demonstrable competence in the areas of work in which they had been tasked.  There were no areas of improvement or shortfall identified in either of the work tasks sampled.

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

Overall I considered that the arrangements and their associated implementation for LC23 and LC24 met with the requirements of ONR guidance and were rated through the IIS as 3 (adequate) and 2 (good) respectively.

One ONR Issue has been raised to address the shortfall identified during the LC23 inspection.

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.