Office for Nuclear Regulation

Ageing Management and LC28 inspection

Executive summary

Purpose of Intervention

The purpose of this intervention was to conduct an Ageing Management Inspection of EDF Energy Nuclear Generation Ltd’s (NGL) Heysham 1 Power Station (HYA). 

This intervention was undertaken as part of a series of planned interventions that are listed in the Heysham 1 Integrated Intervention Strategy 2020/2021.

Interventions Carried Out by ONR

An ageing management inspection was performed and rated against Licence Condition 28 (LC28) Examination, Inspection, Maintenance and Testing.

The purpose of LC28 is to ensure the licensee makes and implements adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.

Ageing management arrangements are included within the scope of arrangements necessary to demonstrate compliance with LC28.
An ageing management inspection was conducted and the following systems were sampled:

The focus of the inspection was to establish if the licensee’s arrangements are adequately implemented to detect the onset of equipment degradation, and also to quantify the extant material condition and the rate of ageing of nuclear safety significant plant.
The inspection sampled licensee’s arrangements for ageing management and their implementation for the systems under consideration. The inspection included discussions with various responsible members of EDF NGL staff.  Principally, this included system engineers, senior management and Independent Nuclear Assurance engineers.

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

Overall, it was concluded that the arrangements for ageing management had been adequately implemented in line with ONR’s expectations and good examples of proactive ageing management of plant were provided.

During the inspection however, deferred preventative maintenance routines were examined and it was revealed that out of service inspections for a number of safety relief valves within the Nitrogen Storage and Vaporisation plant had not been completed.  These examinations are specified in the relevant Written Scheme of Examination which is a requirement of the Pressure Systems Safety Regulations 2000. Although we judge that nuclear safety was not challenged, these inspection shortfalls remain within the scope of LC28 and it is judged that Amber (Seek Improvement) against licence condition 28 is appropriate. This shortfall is currently being reviewed against ONR’s Enforcement Management Model to determine the most appropriate enforcement action.

In addition the inspection revealed a small number of minor shortfalls associated with the timely completion of equipment reliability reviews and GT stack engineering review both of which will require further routine regulatory follow up.

It was also accepted that EDF’s corporate ageing management arrangements, which are adhered to by the site, require review to assist with their effective implementation.

We also took the opportunity to gather intelligence on the site’s 2021/22 investment plans; pressure systems safety regulations 2000 compliance activities associated with reactor 1 and reactor 2 pressure vessel examinations, and Covid-19 transmission risk mitigation arrangements.  No issues were identified on these matters.  It was noted that station staff were observed to fully adhere to the site’s recently revised facemask policy and that the physical arrangements of thermal imaging at site entrances; availability of hand sanitiser solutions; personnel testing, isolation and track and trace measures; disinfectant and cleaning materials in all offices; signage and briefing material used to reinforce the 2 metre social distancing rule and hand wash policy remained in place.