- Site: Heysham 1
- IR number: 21-007
- Date: April 2021
- LC numbers: 10, 26, 28
Executive summary
Purpose of Intervention
The primary purpose of this intervention was to establish whether EDF Energy Nuclear Generation Limited (EDF NGL) has made adequate progress towards addressing a number of maintenance record keeping arrangement shortfalls that were identified during the Office for Nuclear Regulation’s (ONR) Heysham 1 (HY1) reactor 1 (R1) statutory outage control and instrumentation (C&I) inspection, which was undertaken in November 2020.
Interventions Carried Out by ONR
This intervention was undertaken by an ONR C&I specialist nuclear safety inspector, who was assisted by the ONR HY1 nominated site inspector (NSI). The intervention involved holding discussions with relevant maintenance, engineering, and training department stakeholders (in accordance ONR’s and EDF NGL’s COVID-19 secure arrangements), reviewing a sample of maintenance related documents, and observing routine maintenance of a nuclear safety protection system.
The primary purpose aspects of this intervention were undertaken in relation to the following Licence Conditions (LCs), which are applicable provisions of the Energy Act 2013:
- LC 10 – Training.
- LC 26 – Control and supervision of operations.
- LC 28 – Examination, inspection, maintenance and testing (EIMT).
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The key LC 10 (training) related findings of the intervention were:
- I sampled HY1 C&I equipment specific maintenance training material and found it to be clear and informative. I also reviewed HY1’s C&I related maintenance training planning and scheduling arrangements and found them to be adequate.
- I noted that the training material that I reviewed incorporated operating experience (OPEX) examples and that learning/event briefs were distributed to relevant personnel.
- I examined the training records of a number of personnel who were responsible for undertaking C&I related maintenance and found that they were suitably qualified and experienced personnel (SQEP).
- I noted that HY1 has recently introduced a number of additional maintenance related training and mentoring arrangements, which I considered to be suitable and worthwhile.
Based on the information provided to me during the intervention, I have assigned an integrated intervention strategy (IIS) rating of Green for LC 10.
The key LC 26 (control and supervision of operations) related findings of the intervention were:
- I observed a C&I nuclear safety related maintenance task from start to finish and considered that the task was suitably controlled and supervised and was conducted in a calm and professional manner. Overall, the task appeared to have been undertaken appropriately.
- I reviewed HY1’s maintenance work scheduling and planning arrangements and found them to be adequate.
- I did identify a number of maintenance record keeping shortfalls, which indicated to me that there had also been review process shortfalls. However, HY1 informed me that additional maintenance related arrangements have been implemented since the associated maintenance tasks were undertaken, which should obviate similar shortfalls reoccurring. Given this, and the fact that none of the shortfalls that I identified presented an immediate threat to nuclear safety, I am content, based on the overall information provided to me during the intervention, to assign an ISS rating of Green to LC 26 (control and supervision of operations). However, I intend to undertake a further C&I related LC 26 intervention at HY1 in November 2021 to determine whether these improvements have resulted in the desired improvements.
The key LC 28 (EIMT) related findings of the intervention were:
- I reviewed a number of work instructions (WIs), work order cards (WOCs) and checksheets and did not identify instances where C&I equipment was declared as being fit for return to service with ‘out of tolerance’ operating parameters having been recorded.
- I found that all of the maintenance tasks that I sampled had been completed within the specified time limits and had been undertaken by SQEP.
- I did identify a number of maintenance record keeping shortfalls. However, HY1 informed me that additional maintenance related arrangements have been implemented since the associated maintenance tasks were undertaken, which should obviate similar shortfalls reoccurring. Given this, and the fact that none of the shortfalls that I identified presented an immediate threat to nuclear safety, I am content, based on the overall information provided to me during the intervention, to assign an ISS rating of Green to LC 28 (EIMT). However, I intend to undertake a further C&I related LC 28 intervention at HY1 in November 2021 to determine whether these improvements have resulted in the desired improvements.
Conclusion of Intervention
Based on the information provided to me during the intervention, I consider that HY1 has made adequate progress towards addressing a number of maintenance record keeping arrangement shortfalls that were identified during the ONR HY1 R1 statutory outage C&I inspection, which was undertaken in November 2020.
I have assigned ISS ratings of Green in relation to LC 10 (training), LC 26 (control and supervision of operations) and LC 28 (EIMT) compliance. However, I intend to undertake a further C&I related LC 26 and LC 28 intervention at HY1 in November 2021 to determine whether recent improvements in maintenance arrangements have had the desired effect. I have raised one level 4 (L4) regulatory issue (RI) (8715) to track the progress of these improvements.
During this intervention I did not identify any issues that would pose an immediate significant threat to nuclear safety.