- Site: Heysham 2
- IR number: 21-023
- Date: May 2021
- LC numbers: 24, 26
Executive summary
Purpose of Intervention
The purpose of this intervention was to undertake a compliance inspection at the EDF Energy Nuclear Generation Heysham 2 Power Station. The compliance inspection was theme based and structured around configuration control. It used nuclear site licence conditions (LC) 24 operating instructions, and LC26 control and supervision, to form a judgement.
The intervention was planned in accordance with ONR’s Heysham 2 Integrated Intervention Strategy (IIS) for 2020/21.
Interventions Carried Out by ONR
The nominated site inspector for Heysham 2, a project inspector overseeing the outage of Reactor 7 and a human factors nuclear associate performed the inspection at the site as set out in the plan attached to the Heysham nuclear site licence. For LC24 we sampled operating and maintenance instructions and the arrangements to ensure that they remain accurate and up to date. For LC26 we sampled the supervision arrangements for contractors and the setting to work process for all maintenance staff. The inspection included interviews with key staff, review of relevant documents and a walk-down of work being carried out.
An agenda based around a configuration control theme was provided in advance of the intervention.
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
A system-based inspection was not performed.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
For LC24 I found that the procedures sampled were accurate. Staff were being encouraged to report any issues with the procedures. Additional resource has been secured to help with any document amendments. Awareness of what good looks like is being raised through Human Performance (HU) training; an observation programme and procedure quality use and adherence (PQU&A) and configuration control working groups have been established.
For LC26 I observed that maintainers are being set to work with an understanding of the key hazards and control measures. When interviewed, the maintenance manager and a field supervisor were both able to explain the fundamental principles behind the field supervision programme and gave confidence that it was being used effectively. Unfortunately, the opportunities to verify this were more limited than anticipated due to delays in starting tasks on plant.
There were a number of observations made in relation to the procedures and processes, which although they do not amount to regulatory shortfalls, they do, in my opinion make the likelihood of personnel making errors more likely. Notably, for even fairly routine tasks, there is a large volume of paperwork required, much of which is independently checked and verified. Complexity and bureaucracy could be reduced in many instances without compromising safety, allowing more targeting of those tasks where additional verification and oversight would add real value.
Conclusion of Intervention
During the feedback to the station executive team, the observations were discussed and accepted. However given the number of procedures on station, the station’s current focus with respect to continual improvement involving engagement of all on station seems the only practical solution.
Based on what I have observed, I have assigned Green ratings (no formal action required) for compliance against both LC24 and LC26.
There were no findings from this inspection that could significantly undermine nuclear safety. At present, no additional regulatory action is needed over and above the planned interventions at Heysham 2 power station as set out in the 2021/22 Integrated Intervention Strategy.