Office for Nuclear Regulation

Heysham 2 planned interventions - System Based Inspection SBI-10 - Emergency Inspection

Executive summary

Purpose of Intervention

This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Heysham 2 power station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).
The work was carried out in line with the planned inspection programme contained in the Heysham 2 Integrated Intervention Strategy for 2018-19.

Interventions Carried Out by ONR

We performed a System Based Inspection (SBI) of the Emergency Equipment to examine if the licensee’s arrangements and their implementation enabled the system to fulfil its functional requirements in line with the safety case.

Through the examination of the emergency equipment, associated procedures, records and a confirmatory plant walk down, a compliance inspection was performed against the following Licence Conditions (LCs) which are applicable provisions of the Energy Act 2013:

LC 27 ‘Safety Mechanisms, Devices and Circuits’ and LC34 ‘Leakage and Escape of Radioactive Material and Radioactive Waste’ were not considered applicable to this system based inspection, given that the inspection was associated with the equipment in place and not driven by initiating events derived from the design basis safety case.

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

The nominated site inspector for Heysham 2 undertook the following additional regulatory activities:

Explanation of Judgement if Safety System Not Judged to be Adequate

The safety system was judged to be adequate, based on the sample inspected.

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

For LC23, we sampled the limits and conditions associated with the Emergency Indication Centre (EIC), communications and lighting. Based on the sample we were satisfied that the limits and conditions were appropriately derived from the safety case and the implementation was suitable and sufficient. However, we judged that the technical specification (3.2) associated with the EIC requires review to ensure that the Duly Authorised Person(s) actions are clearly defined if the action conditions cannot be complied with. An ONR Regulatory Issue (RI 7128) has been raised to monitor licensee progress in addressing the ONR findings.

For LC24, we sampled a number of emergency procedures including the Station Operating Instructions (SOI) for back up emergency feed to the boiler. The licensee noted that during its internal inspection of the emergency equipment it identified a shortfall relating to inadequate procedures for a submersible pump. The licensee is conducting a minor adverse condition investigation (MACI) to understand and address these minor deficiencies.  Overall, we judged that the licensee arrangements for LC24 associated with emergency equipment were adequate.

For LC 10, we sampled the training records of employees with respect to the training element ‘deployable back up equipment overview’. We noted that the training records for the sampled staff were all complete and valid. We noted good practice associated with the issue of a pocket book for the emergency equipment, and the Japanese Earthquake Response (JER) awareness training. However, we observed that there was not stipulation of suitable refresher training for deployment of back up emergency equipment awareness including the training associated with the hook-up points. RI 7128 also captures this aspect.

For LC28, we sampled maintenance and testing records for of the firefighting sprinkler system; surveillance checks of the EIC indications and alarms; and routine checks of the emergency equipment. Based on the sample inspected, we were satisfied that the emergency equipment claimed by the licensee is maintained in accordance with the safety case requirements.

We undertook a plant walk down which covered various emergency command and control areas and emergency stores across the site. Overall, we were satisfied that the emergency command and control centres and the equipment sampled was in a state of readiness to respond if called upon in an emergency. We did, however, identify a number of minor shortfalls associated with the material condition of the mobile Alternative Access Control Point (AACP), housekeeping within the garages, missing FME covers, plant labelling and lighting standards at hook-up points. We also noted that Official Sensitive documentation had been left in an unsecured facility [this specific issue was readily resolved by the licensee]. RI 7128 also captures these aspects.

In summary, the SBI 10 Emergency Equipment, inspected for Licence Conditions 10, 23, 24 and 28 is rated as Green.

For LC26, I focused on the conduct of maintenance standards, return to service walk downs and efficacy of task observations by sampling two specific jobs identified immediately prior to the inspection. I was satisfied that the start of shift and pre-job briefs for the tasks were consistent with my expectations and ONR guidance to inspectors. I was also content that the setting to work process was suitably rigorous and took account of the relevant hazards within the work area.  I am content that the licensee had followed its arrangements with respect to the return to service checks and walk downs. The knowledge of the status of the equipment being returned to service and the level of engagement between operations and maintenance exceeded my regulatory expectations.

Conclusion of Intervention

After considering all the evidence witnessed during each of the sample inspections undertaken against LCs 10, 23, 24 and 28 we consider that the safety system meets the requirements of the safety case and is adequate. Regulatory Issue RI 7128 has been raised to capture the minor shortfalls identified by ONR and monitor the licensee actions to resolve these in a timely manner

Based on the sample taken against LC26, I am satisfied that the licensee is meeting its legal obligations.

There are no findings from this inspection that could significantly undermine nuclear safety.