The purpose of this intervention was to undertake Licence Condition (LC) System Based Inspection (SBI) at EDF Energy Nuclear Generation Limited’s (NGL) Hinkley Point B (HPB) Power Station, in line with the inspection programme contained in ONR’s Operational Facilities Division Intervention Strategy 2019-20.
The ONR team performed an SBI to confirm the implementation of safety claims made on the fuel route front end. This covered fuel receipt, storage, handling, in-core condition monitoring and refuelling activities.
This inspection was undertaken by ONR nuclear safety inspectors including the nominated HPB site inspector and specialist inspectors from: Fuel and Core; Fault Studies, and Control and Instrumentation.
In addition to the safety inspectors, a specialist inspector from ONR safeguards was also in attendance. The purpose of this was to afford ONR safeguards an opportunity to understand HPBs front end fuel route arrangements from a safeguards perspective.
During this intervention we examined HPB’s compliance with the following nuclear site Licence Conditions (LC), which are applicable provisions of the Energy Act 2013:
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
The safeguards aspects of the inspection are reported separately (2020/19328).
Following an inspection of the fuel route front end at HPB, we judge that overall this system fulfils the requirements of the safety case.
From the areas targeted and the evidence examined during this inspection, we consider that HPB has largely implemented those safety case claims that relate to the fuel route front end adequately.
We consider that HPB have suitable and sufficient arrangements to monitor and record fuel build status.
We considered that the fuel build quality plans were effective in ensuring activities important to safety were clearly being planned, monitored and controlled.
The number of staff associated with fuel route activities exceeded the nuclear baseline. In addition, effective succession management was in evidence.
NGL staff were helpful and knowledgeable and housekeeping on site was good, with the exception of in the new fuel inspection facility where flakes of paint were identified.
We identified a number of minor shortfalls relating to procedure use and adherence. Individually, and considered in isolation, there is no evidence that these minor shortfalls have resulted in any effect on nuclear safety. However, given the number of instances and the range of systems affected, we consider these shortfalls may be indicative of a broader and systemic issue with procedure use and adherence. An ONR level 4 regulatory issue has been raised to monitor NGL’s activities in addressing these issues and any underlying causes (RI 7850).
A separate Regulatory Issue (RI 7858) has been raised in relation to the application of foreign material exclusion within the new fuel inspection facility. Foreign material exclusions controls are required in certain areas to prevent proscribed materials entering the fuel route. The Regulatory issue will ensure that adequate controls are re-instated.
From the evidence sampled during this inspection, we consider that the fuel route front end largely met the requirements of the HPB safety case.
That said, there were some instances of procedure use and adherence shortfalls, which should they continue, and if left unresolved may lead to compliance issues with the safety case in the future. As a result, a new Regulatory Issue (RI 7850) has been raised to ensure controls in this area are improved.
In addition, a Regulatory Issue (RI 7858) has been raised on foreign material exclusion.
Overall we judged that the arrangements for the receipt, inspection, assembly, and refuelling of reactor fuel assemblies met relevant good practice and therefore we have given an intervention rating of ‘Green’ in relation to compliance with LCs 10, 23, 24, 27, 28 and 4.
There are no findings from this intervention that could significantly undermine nuclear safety at HPB. No other regulatory actions are suggested as a result of this inspection, over and above the already planned interventions as set out in the Integrated Intervention Plan.