This is a planned inspection at EDF Energy Nuclear Generation Ltd (NGL) Hartlepool (HRA) power station, undertaken as part of the planned intervention strategy for the Civil Nuclear Reactor Programme of the Office for Nuclear Regulation (ONR).
I completed a planned System Based Inspection (SBI) of “shutdown systems – control rod system”, safety system grouping SBI28. The objectives of an SBI is to confirm that the relevant safety systems and structures are able to meet the safety functional requirements defined in the safety case and to test implementation of the Licence Condition (LC) arrangements for: LCs 10 (training); 23 (operating rules); 24 (operating instructions); 27 (safety mechanisms, devices and circuits); 28 (examination, inspection, maintenance and testing); 34 (leakage and escape of radioactive material and radioactive waste).
Based on the information sampled, I made an overall judgement that the relevant safety systems and structures are able to meet the safety function requirements defined in the safety case and are adequate.
In relation to the LC10 element of the SBI, I judge that training records are up to date and in accordance with the post training profile requirements. I witnessed operations being performed, confirming the competence of the individuals to follow the instructions and in completion to an appropriate standard. The trainee System Engineer was undertaking training with appropriate arrangements to safeguard the extent of his authority. I judged the LC10 element of this inspection to be adequate, warranting an associated Integrated Intervention Strategy (IIS) rating of 3 - Adequate.
In relation to the LC23 element of the SBI, based on the evidence sampled during this inspection, NGL demonstrated an adequate understanding of the requirements of the safety case and supporting technical specifications, commentaries, and schedules which were judged to be consistent with the claims presented within the Living Safety Case Document (LSD) and System Based View (SBV). I judged the LC23 element of this inspection to be adequate, warranting an associated IIS rating of 3 - Adequate.
In relation to the LC24 element of the SBI, based on the evidence sampled during this inspection, the operations witnessed and discussion with NGL personnel I was satisfied operating instructions provide sufficient detail, have been improved over time, are valid and being followed in achieving the requirements of the safety case. Therefore, I judged the LC24 element of this inspection to be adequate, warranting an associated IIS rating of 3 – Adequate.
In relation to the LC27 element of the SBI, I was satisfied the availability and reliability of the safety mechanism, devices and circuits for the Control Rod system were identified in the safety case for operations important to safety and were subject to procedural control which was being adequately followed. I judge overall the LC27 arrangements to be adequate, warranting an associated IIS rating of 3 – Adequate.
In relation to the LC28 element of the SBI, the licensee demonstrated that there are adequate processes, procedures and records in place for the examination, inspection, maintenance and testing [EIMT] of control rod systems. The activities are adequately defined and implemented; performance is consistent with the safety case reliability claims. The CR maintenance facility is adequate, enabling LC28 activities to be undertaken consistent with the requirements of the maintenance schedule. The requirements identified in the safety case are included on the maintenance schedule, undertaken consistent with the schedule frequency and performed to an adequate standard. The Safety System Review report required improvement in respect to reliability analysis and errors. With this minor improvement, overall I judge control rod EIMT arrangements under LC28 are adequate, warranting an associated IIS rating of 3 – Adequate.
In relation to the LC34 element of the SBI, I confirmed for SBI28 it was not applicable.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.