The purpose of this intervention was to undertake a Systems Based Inspection of the Seawater Systems (SBI05) and a Licence Condition (LC) 34 compliance inspection at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station, in line with the ONR’s inspection programme contained in the Hartlepool Integrated Intervention Strategy for 2019/20.
In my capacity of nominated site inspector for Hartlepool Power Station, I performed a System Based inspection (supported by two Mechanical Engineering Specialist Inspectors).
I also undertook a compliance inspection (jointly with a Nuclear Regulator from the Environment Agency) to examine the licensee’s implementation of its compliance arrangements with regard to LC 34 – Leakage and Escape of Radioactive Material and Radioactive Waste.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
In addition to the Systems Based inspection and the compliance inspection, I also undertook other activities including a ‘keep in touch’ meeting with the station-based Independent Nuclear Assurance team and a discussion on the 10% cut to investment on the station with the Engineering Manager.
The Emergency Seawater system (ESW) was not judged as adequate and a Level 3 Issue raised. Based on the evidence sampled, I noted shortfalls in: the current approach to determining the availability of the system, the measure being restricted to pumps and generator only; the lack of operating instructions beyond the initial pump switch on; and the standard of maintenance of the submersible pumps, pipework and valves.
I judge that due to the number of identified deficiencies in compliance arrangements these, in combination, demonstrate a significant weakness in implementation of safety case requirements. I therefore judge an inspection rating of AMBER be appropriate for LC28 for the Seawater system.
I performed a desktop review of the Licensee’s arrangements and associated documentation for the five License Conditions. The systems selected as my sample for inspection were the Essential Cooling Water System (ECW) and the Emergency Seawater System (ESW). I also performed a plant walk-down and had discussions with various System Engineers, Nuclear Safety Group personnel, and operators.
Hartlepool nuclear power station demonstrated that it has arrangements in place to ensure that the Essential Cooling Water System (ECW) is inspected, maintained and operated in accordance with its safety case. The arrangements sampled and examined by ONR complied with Nuclear Generation Limited’s (NGLs) legal duties in the areas sampled during the inspection, and I was satisfied that the System adequately fulfils the requirements of the safety case.
A number of shortfalls were identified for the ESW system and a rating of AMBER identified against LC28 due to these shortfalls.
I judge that the Licensee has adequate arrangements in place for training, and the individuals I sampled were appropriately trained for the tasks undertaken. I consider an inspection rating of GREEN to be appropriate.
I judge that the Licensee has an adequate process in place for identifying the operating rules to demonstrate the safety of an operation, ensuring configuration control and ensuring compliance with operating rules. A deficiency was identified in the specification of availability arrangements for the complete ESW system. However, no shortfalls were identified with the ECW, and therefore I consider an inspection rating of GREEN to be appropriate for the Seawater system.
I judge that the Licensee had an adequate process in place for the production and implementation of Operating Instructions. A minor deficiency was identified as no operating instruction was evident for the ESW post deployment. However, no shortfalls were identified with the ECW, and therefore I considered an inspection rating of GREEN to be appropriate for the Seawater system.
I judge that the Licensee had an adequate process in place for the management of Safety Mechanisms, Devices and Circuits. I considered an inspection rating of GREEN to be appropriate for the Seawater system.
I judge that the Licensee has an adequate process in place for the regular and systematic examination, inspection, maintenance and testing of the ECW system. A minor deficiency was identified in the storage of an ECW pump, post maintenance.
I judge that the Licensee does not have adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of the ESW system. No evidence was presented that the submersible pumps were maintained or identified as critical spares. No evidence was presented of functional tests on pipework. No evidence was presented of an extended test on the ESW diesel generator.
I consider an inspection rating of AMBER to be appropriate.
The inspection was conducted jointly with the Environment Agency (EA) and the focus of the inspection was on radioactive liquids; particularly their containment and leakage detection (including surface drainage and borehole monitoring). The inspection included a walkdown of the Reactor Basement & Waste Voids sumps, Radioactive Effluent Treatment Plant (RAETP), Radioactive Effluent Final Discharge Line and a selection of surface water drains and groundwater boreholes.
Based on the evidence I sampled and my interactions with NGL staff, I judge that the standard of compliance was consistent with relevant good practice and I am satisfied that the licensee is complying with its legal duties. Minor items for improvement were fed back to the station management; though these were not sufficient to warrant formal regulatory action. Overall, I consider the standard of compliance to be sufficient to award an inspection rating of GREEN against LC 34.
There are no findings from this intervention that could undermine nuclear safety at this time. A level 3 issue has been raised to seek improvements to the shortfalls identified. Therefore, no additional regulatory action is needed over and above the planned interventions at Hartlepool Power Station.