- Site: Hinkley Point B
- IR number: 19-028
- Date: June 2019
- LC numbers: 10, 23, 24, 27, 28
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Strategy, each year ONR performs a series of planned System Based Inspections (SBIs). In line with Hinkley Point B Integrated Intervention Strategy (IIS) for 2019/20, a planned SBI on the fire protection systems (SBI-11) at EDF Energy Nuclear Generation Limited’s (NGL’s) Hinkley Point B (HPB) power station was conducted on 4th-5th June 2019. The purpose of this inspection was for ONR to determine the adequacy of implementation of the safety case claims in respect of the fire protection systems.
Interventions Carried Out by ONR
In order to determine the adequacy of implementation of the Licensee’s safety case claims in respect of the fire protection systems, ONR examined evidence to determine compliance against six key Licence Conditions (LCs), which are applicable provisions of the Energy Act 2013. These LCs (listed below) have been selected in view of their importance to nuclear safety and in providing a structured approach to determining whether the safety case has been implemented adequately through the system being inspected.
ONR assessed compliance against the following LCs using applicable inspection guidance:
- LC 10 Training – requires NGL to make and implement adequate arrangements for suitable training of those who have responsibility for any operations that may affect safety.
- LC 23 Operating Rules – requires NGL to produce adequate safety cases to demonstrate the safety of operations on the site, and to identify and implement operating conditions and limits necessary in the interests of safety.
- LC 24 Operating Instructions – requires NGL to make and implement adequate arrangements for the provision of suitable written instructions for undertaking any operation that may affect safety.
- LC 27 Safety Mechanisms, Devices and Circuits – requires NGL to ensure that, before a system is operated, inspected, maintained or tested, all safety mechanisms, devices and circuits are properly connected and in good working order.
- LC 28 Examination, Inspection, Maintenance and Testing (EIMT) – requires NGL to make and implement adequate arrangements for the regular and systematic EIMT of all plant which may affect safety.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
The inspection sampled and examined the applicable safety case claims, through a combination of document reviews, discussions with plant operators and plant inspections to determine compliance against the selected LCs. In this case, the inspection plan did not cover any area where fire protection systems could lead to escape of radioactive waste and hence LC34 did not form part of this inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
From the areas targeted and the evidence examined during the SBI, ONR considers that NGL has adequately implemented those safety case claims that relate to the fire protection systems.
Licence Condition 10 (Training) – ONR considered NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC10. As such, an inspection rating of Green (no formal action) for LC10.
Licence Condition 23 (Operating Rules) and Licence Condition 24 (Operating instructions) – ONR considered NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC23/24. As such, an inspection rating of Green (no formal action) for LC23/24.
Licence Condition 27 (Safety Mechanisms, Devices and Circuits, SMDCs) – ONR considered NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC27. As such, an inspection rating of Green (no formal action) for LC27 .
Licence Condition 28 (Examination, Inspection, Maintenance and Testing) – ONR considered NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC28. As such, an inspection rating of Green (no formal action) for LC28.
Conclusion of Intervention
From the evidence sampled during this SBI, it was judged that there were no matters that have the potential to impact significantly on nuclear safety. Consequently, an overall rating of Green was awarded for the fire protection systems as a whole. The inspection findings were shared and accepted by NGL as part of normal inspection feedback. ONR considers NGL adequately demonstrated ownership and implementation of the fire protection systems safety case to ensure and maintain nuclear safety.