Hartlepool - Inspection ID: 54068

The aim of this inspection was to determine whether control and instrumentation (C&I) related Hartlepool (HRA) reactor 1 (R1) statutory outage Licence Condition (LC) 28 – examination, inspection, maintenance, and testing (EIMT) activities that are necessary to support safety case claims have been / will be undertaken.

The findings of this inspection will contribute to the Office for Nuclear Regulation’s (ONR’s) regulatory decision to grant a Consent to the return of R1 to normal operating service in accordance with LC 30 – periodic shutdown.

During the inspection we sampled statutory outage control and instrumentation (C&I) equipment related examination, inspection, maintenance, and testing (EIMT) activities important to nuclear safety, based on the schedule of activities contained within the Hartlepool (HRA) maintenance schedule (MS).

During the inspection we held discussions with several system engineers (SEs) and found that they had a good understanding of the systems and equipment they were responsible for, and that they appreciated the importance of the statutory outage work being undertaken. We also considered the personnel we engaged with to be open and receptive to the feedback we provided.

We found the majority of activities we sampled had either been satisfactorily completed or were on schedule to be completed. However, we found an instance where out of tolerance reactor post trip logic system (RPTLS) timer relays had not been identified as such, and were declared fit for return to service. We considered that this constituted a significant failure to implement compliance arrangements and thus merited an AMBER rating for the inspection. We raised this issue with HRA who subsequently retested the timer relays and found them to be within tolerance. HRA also identified that incorrect operation of the timing equipment by the maintenance technician (MT) had resulted in the timer relay times being incorrectly recorded as out of tolerance in the first instance. In relation to this, we proposed to raise a Level 3 (L3) Regulatory Issue (RI) (RI-12640) to ensure that lessons are learnt, and to ensure that appropriate measures are implemented to prevent a similar occurrence of this situation.

We also raised two Level 4 (L4) RIs relating to the timeliness of resolving condensate polishing plant (CPP) leaks, and the use of an unapproved method to inhibit protection relay operation. It should be noted that we did not consider that these issues posed an immediate or significant risk to nuclear safety or needed to be addressed before reactor 1 (R1) returns to service. These RIs have been captured in WIReD as RI-12638 and RI-12639 respectively.

We also identified a number of additional maintenance documentation and record keeping shortfalls, and raised them with the relevant SEs, who agreed to address them. However, we also considered that they did not pose an immediate or significant risk to nuclear safety and would not preclude R1 from returning to service.

We also noted a number of proactive C&I equipment ageing and obsolescence (A&O), parameter value tracking, and data processing and control system (DPCS) staff training initiatives, which we welcomed.

We also conducted a plant walkdown during the inspection and found the operating conditions and lighting levels afforded an acceptable working environment for maintenance personnel. We did identify some housekeeping shortfalls, and raised them with the relevant SEs, who agreed to address them. However, we also considered that they did not pose an immediate or significant risk to nuclear safety and would not preclude R1 from returning to service. 

Based on our sample inspection of the C&I equipment aspects of the HRA R1 2025 statutory outage we have assigned an intervention rating of AMBER to LC 28 compliance. However, given that HRA has satisfactorily addressed the issues that drove this intervention rating we are able to recommend that support be given for a Consent to allow R1 to return to normal operating service. However, this is subject to the satisfactory completion of the planned EIMT activities and any emergent work.

We found the majority of activities we sampled had either been satisfactorily completed or were on schedule to be completed. However, we found an instance where out of tolerance reactor RPTLS timer relays had not been identified as such, and were declared fit for return to service. We considered that this constituted a significant failure to implement compliance arrangements and thus merited an AMBER rating for the inspection. We raised this issue with HRA who subsequently retested the timer relays and found them to be within tolerance. HRA also identified that incorrect operation of the timing equipment by the maintenance technician had resulted in the timer relay times being incorrectly recorded as out of tolerance in the first instance. In relation to this, we proposed to raise a L3 RI (RI-12640) to ensure that appropriate lessons are learnt, and to ensure that appropriate measures are implemented to prevent a similar occurrence of this situation.

We also raised two L4 RIs relating to the timeliness of resolving CPP leaks, and the use of an unapproved method to inhibit protection relay operation. It should be noted that we did not consider that these issues posed an immediate or significant risk to nuclear safety or needed to be addressed before R1 returns to service. These RIs have been captured in WIReD as RI-12638 and RI-12639 respectively.

Based on our sample inspection of the C&I equipment aspects of the HRA R1 2025 statutory outage we have assigned an intervention rating of AMBER to LC 28 compliance. However, given that HRA has satisfactorily addressed the issues that drove this intervention rating we are able to recommend that support be given for a Consent to allow R1 to return to service. However, this is subject to the satisfactory completion of the planned EIMT activities and any emergent work.