Office for Nuclear Regulation

Planned Interventions – LC10 & LC12 Compliance Inspection/LC28 Compliance Inspection

Executive summary

Purpose of intervention

The purpose of this intervention was to carry out licence compliance inspections at the EDF Energy Nuclear Generation Limited’s (NGL’s) Heysham 1 power station in line with the planned inspection programme contained in the Heysham 1 Integrated Intervention Strategy (IIS) for 2015/16. 

Interventions Carried Out by ONR

The nominated site inspector carried out planned Licence Condition (LC) compliance inspections against LC10 and LC12.  An operational readiness inspection against LC28 was also undertaken prior to return to service of the East Carbon Dioxide (CO2) plant.

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

Prior to this inspection, I carried out a review of the company LC10 and LC12 procedures against the relevant ONR guidance documents for these licence conditions.  I judged that these procedures provide adequate arrangements to satisfy the requirements of LC10 and LC12.

In order to determine the adequacy of the implementation of these arrangements, I sampled a number of roles against the company defined training requirements and the Duly Authorised Person (DAP) requirements.  I targeted my sample at the most significant safety roles of Shift Manager, Central Control Room Supervisor (CCRS) and Reactor Desk Engineer.

I found one of the essential training modules (HV switching) required for two of the CCRS had lapsed in December 2014.  Since the station has deemed this training mandatory for the role of CCRS, the two individuals should have completed this refresher training, or provided written justification  to continue undertaking this role.  I found that no such written justification had been produced.

The essential training module is scheduled for later this year.  On the identification of this shortfall, the station produced an acceptable written justification to support the continued operation of the two CCRS in this role until completion of the refresher training later in the year.

As a result of these findings a number of issues have been raised for the station to investigate.  I expect the investigation to consider why this happened and to review their arrangements to prevent similar future issues. In addition they are required to review all safety significant roles to ensure that this is an isolated incident. 

In light of the findings from this inspection I consider that compliance with LC 10 and LC12 is below standard with an IIS rating of 4.

The nominated site inspector and an ONR specialist inspector also carried out an operational readiness inspection of the East CO2 plant prior to its return to service following the recent pipework failure and the subsequent issue of an Improvement Notice by ONR against inadequate maintenance. 

The station was able to explain the work undertaken and improvements being made; however documentary evidence justifying the approach taken, in particular the reason for not inspecting specific sections of pipework, has not yet been completed. 

Notwithstanding the completion of documentation, from the information gathered during the visit, I judged that sufficient progress has been made to allow the East CO2 plant to return to service.  However, the Improvement Notice will remain extant and in force until all the documentary evidence has been produced and reviewed by ONR.  A letter will be sent to the station confirming this position.

Due to the lack of progress with completion of documentary evidence at the time of this inspection I have rated this intervention against LC28 as below standard with an IIS rating of 4.

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

From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety. The actions raised will be pursued as part of normal business.

At present, no additional regulatory action is needed over and above the planned interventions of Heysham 1 power station as set out in the IIS, which will continue as planned.