Office for Nuclear Regulation

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Inspection of the Implementation of New Corporate Programme for Improved LC34 Compliance

Executive summary

Purpose of intervention

This intervention involved ONR’s participation in EDF Energy Nuclear Generation Ltd (EDF Energy NGL) Independent Nuclear Assurance (INA) inspection of the implementation of improvements to Corporate arrangements for Licence Condition (LC) 34 Leakage and Escape of Radioactive material and Radioactive waste at Hinkley Point B which is the lead Site for the roll out LC34 improvement programme.

Interventions Carried Out by ONR

ONR’s involvement was to evaluate the effectiveness of the way EDF Energy NGL is raising its standards in compliance with LC34 arrangements based upon ONR’s own LC34 guidance.  The intervention supports closing out ONR issue (1571) that was raised following regulatory concerns over EDF Energy NGL compliance with LC34.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

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

The findings of this inspection were very positive, with significant improvement in the management of the plant identified based on EDF Energy NGL’s INA inspection in 2012.  Improvements in leak management of the plant were noted, together with the importance that civil structures play in maintaining LC34 compliance.  There were a low number of known leaks on plant and no undetected leaks were identified during this inspection.

The Corporate Lead for the LC34 Improvement Programme agreed to check with EDF Civil's Group to confirm that LC28 Civil Structural inspections take into consideration LC34 compliance requirements.

The implementation of the new arrangements has been supported by considerable resource from EDF Energy NGL’s technical support centre at Barnwood and contractors.  Governance arrangements need to be put in place by station to ensure identified improvement work is delivered.  Consideration also needs to be given to the amount of corporate resource needed to assist other stations in implementing this LC34 improvement programme.

Conclusion of Intervention

Evidence gathered during this intervention concluded that EDF Energy NGL LC34 improvement programme is successful at Hinkley Point B.  The inspection identified several lessons for the roll out of this programme across the EDF Energy NGL reactor fleet as well as maintaining and developing improvements at Hinkley Point B.

Recommendations

The EDF Energy NGL Corporate Lead for the LC34 improvement programme agreed that the lessons learnt from Hinkley Point will be captured to assist in the roll out of the work across EDF Energy NGL reactor fleet.  This programme to be submitted to ONR as evidence of commitments given by EDF Energy NGL to improve their LC34 arrangements.