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System Based Inspection 023 - Hartlepool – CO2 Processing and Gas Blowdown Systems

  • Site: Hartlepool
  • IR number: 20-054
  • Date: September 2020
  • LC numbers: 10, 23, 24, 27, 28, 34

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake planned compliance inspection activities at EDF Nuclear Generation Limited’s (NGL’s) Hartlepool (HRA) power station in line with the 2020-21 HRA integrated intervention strategy (IIS).

Interventions Carried Out by ONR

Two ONR specialist Chemistry inspectors, assisted by the ONR nominated site inspector performed a system based inspection (SBI) to confirm the implementation of safety claims made for the carbon dioxide processing and blowdown systems.  The SBI examined the licensee’s compliance with the following licence conditions (LCs):

  • LC10 – Training
  • LC23 – Operating Rules
  • LC24 – Operating Instructions
  • LC27 – Safety Mechanisms
  • LC28 – Examination, inspection, maintenance, and testing.
  • LC34 – Leakage and escape of radioactive material and radioactive waste

Site INA staff also conducted a plant walkdown of the CO2 blowdown system and produced a presentation, including numerous photographs of areas and plant.  This was an invaluable inclusion to this remote SBI and resulted in a number of minor comments surrounding general husbandry, plant labelling, defect tags and area classification. 

Explanation of Judgement if Safety System Not Judged to be Adequate

On the basis of the evidence sampled during this inspection, I judged that the aspects of the CO2 Processing and Blowdown systems sampled were adequate and met the requirements of the safety case.

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

I was satisfied that staff training records and profiles sampled were in accordance with the requirements for the roles performed from an LC10 perspective. The licensee demonstrated an effective knowledge and understanding in the areas of the safety case examined. For the LC10 element of this inspection relevant good practice was being met, warranting an assessment rating of GREEN.

With respect to LC23 and LC24, I identified appropriate operating rules and instructions in line with the aspects sampled. I therefore judged the LC23 and LC24 elements of this inspection to be meeting relevant good practice, warranting an assessment rating of GREEN.

I was satisfied that safety mechanisms examined within my sample were appropriately maintained and available to perform their safety functions. I therefore considered the LC27 elements of this inspection to be meeting relevant good practice, warranting an assessment rating of GREEN.

I sampled the examination, inspection, maintenance and testing (EIMT) regime of a sample of components judged to be important to nuclear safety. Overall, the LC 28 maintenance regime was judged to be meeting relevant good practice, warranting an assessment rating of GREEN.

From an LC34 perspective, I noted that while there was generally good leak monitoring, a number of leaks were long standing and leaks from within active systems were not always categorised as such and hence not identified as relevant for LC34 reporting. This finding contributes to the basis for Regulatory Issue RID8376 and has been shared with the responsible inspector and not pursued further here.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

After considering the evidence examined during the inspections undertaken against LCs 10, 23, 24, 27, 28, and 34, I considered that the aspects of the CO2 Processing and Blowdown system sampled meet the requirements of the safety case.

A number of minor observations and improvements were identified, which were fed back to the licensee, and one matter was identified relating to both the management and reporting of leaks relevant under LC34, which is part of a wider fleet issue being progressed by the corporate inspector. The licensee accepted ONR’s findings.

There are no findings from this inspection that could significantly undermine nuclear safety and no change to the planned interventions and inspections of HRA.