- Site: Hartlepool
- IR number: 20-096
- Date: December 2020
- 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 Hartlepool’s Integrated Intervention Strategy (IIS) for 2020/2021, a planned SBI on the fire protection systems (SBI-11) at EDF Energy Nuclear Generation Limited’s (NGL’s) Hartlepool (HAR) power station was conducted on 7th, 8th, 11th, 15th, 16th and 17th December 2020.
The purpose of the inspection was to examine whether the safety case claims associated with the fire protection systems (detection, suppression, barriers, doors and dampers) have been adequately implemented to meet the requirements of the case. The inspection was carried out at Hartlepool power station through examination of compliance against the Licence Conditions (LCs) listed below.
The inspection was undertaken by internal hazards, external hazards and fault analysis specialist inspectors. Given the restrictions in place due to the coronavirus pandemic, this inspection was carried out remotely using teleconferencing facilities.
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, I examined evidence to determine compliance against five 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.
I 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. The fire protection systems cannot themselves lead to escape of radioactive waste and hence LC 34 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, I considered that NGL has adequately implemented those safety case claims that relate to the fire protection systems.
Licence Condition 10 (Training) – I sampled the training records of personnel who fulfil roles associated with the fire suppression system and the passive fire protection system. I also discussed handover and training. I noted that the training records for all the individuals sampled were complete and valid. Overall, I considered that NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC 10. As such, an inspection rating of Green (no formal action) was assigned for LC 10.
Licence Condition 23 (Operating Rules) and Licence Condition 24 (Operating Instructions) – The focus of this part of the inspection was to confirm that the principal limits and conditions of the fire safety case were identified in the station’s Technical Specifications and how these specifications were enacted into station procedures and operator surveillances. I considered the principal limits and conditions of the fire safety case were identified in the station’s technical specifications. A review of surveillance records and compliance check sheets demonstrated that the technical specifications were adhered to during operations. For LC 24, I sampled safety and maintenance instructions associated with the fire system and considered they were implemented via clear working instructions. Overall, I considered NGL provided an adequate level of evidence to demonstrate compliance against LC 23/24. As such, an inspection rating of Green (no formal action) was assigned for LC 23/24.
Licence Condition 27 (Safety Mechanisms, Devices and Circuits, (SMDCs)) – Due to the remote nature of this inspection (due to Covid-19) NGL’s Internal Regulator undertook a plant walk down on ONR’s behalf which covered various fire protection equipment and included the Fixed Jet Fire System Pumps, High Pressure Back Up Cooling System Building, Turbine Hall and Transformers. Overall, it was considered that housekeeping, general plant condition, management of fire loads, condition of the fire system and plant labelling was good. Based on the plant walk down and areas sampled during the inspection, I considered that suitable and sufficient safety mechanisms, devices and circuits are connected and in working order to demonstrate compliance against LC 27. As such, an inspection rating of Green (no formal action) was assigned for LC 27.
Licence Condition 28 (Examination, Inspection, Maintenance and Testing) – I sampled the maintenance and testing records for various parts of the suppression, detection and passive systems associated with significant fire risks on site. Based on this sample, I considered the equipment was maintained in accordance with the safety case requirements. I found some minor issues associated with the logging of maintenance of fire doors which will be tracked through a Level 4 Regulatory Issue. Overall, I considered NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC 28. As such, an inspection rating of Green (no formal action) was assigned for LC 28.
Conclusion of Intervention
From the evidence sampled during this SBI, I 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. I considered NGL adequately demonstrated ownership and implementation of the fire protection systems safety case to ensure and maintain nuclear safety.