Office for Nuclear Regulation

EDF Corporate LC14 and LC 17 inspection

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection of activities at EDF Energy Nuclear Generation Limited’s (NGL’s) corporate centre at Barnwood. This is in line with the ONR’s planned inspection programme contained for 2019/20.

Purpose of Intervention

The purpose of this intervention was to gain confidence in the corporate centres role in the provision of technical governance, oversight of implementation and provision of support to the fleet. This is relevant to two of ONR’s corporate centre themes, including the adequacy of fleet / functional oversight and organisational learning. Given selection of topics and interrelationship between chemistry and control & instrumentation (C&I), a multi-disciplinary intervention was judged appropriate to ensure a consistent and proportionate approach.

Interventions Carried Out by ONR

Previous NGL commitments included the requirement to implement chemistry technical governance in station safety case documentation. Within the chemistry function, these are historically known as British Energy Operating Manuals (BEOMs) in additional to Company Technical Specifications (CTSs). Review, implementation and dispensation with BEOMs is therefore judged relevant to production of safety cases and specifically sampled during this intervention. This was therefore rated in terms of License Condition (LC) 14 compliance.

NGL’s submissions as part of the third Periodic Safety Reviews (PSR3) identified specific and fleet-wide challenges with respect to qualification of obsolescent smart and analogue chloride ingress protection system (CIPS) conductivity probes. The fleet approach for qualifying replacement instruments was therefore sampled during this intervention. This was therefore rated in terms of LC17 compliance.

While not rated, aspects of the corporate centres derivation and application of chemistry metrics were also explored. Similarly, given approaching end of generation at a number of stations, the corporate centres consideration of resources and succession planning was also discussed.

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

Explanation of Judgement if Safety System Not Judged to be Adequate


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

In terms of LC14 compliance, based on my sample I am content that NGL has an appropriate process for BEOM review and dispensation. I note however that the corporate oversight of BEOM updates in response to RI 1786 has not been fully effective, given my own interventions have identified gaps. However, this is already captured by RI 7756 and the Independent Nuclear Assurance (INA) regulator will maintain oversight of remaining BEOM updates. I am therefore content that this is being managed.

With respect to LC17 and qualification of replacement conductivity probes, I judge that the corporate centre has made good progress. I note however that the corporate centre could improve in terms of disseminating information between various technical disciplines, while focus should also be given to ensuring reliance on spares is suitably justified. I am content however to follow this up as part of routine C&I interactions.

Conclusion of Intervention

There are no findings from this inspection that could significantly undermine nuclear safety and no change is necessary to the planned interventions and inspections. I have identified a number of topics for follow up however by either myself or other ONR specialists.