- Site: Hartlepool
- IR number: 21-038
- Date: June/July 2021
- LC numbers: 10, 23, 24, 27, 28
Executive summary
Purpose of Intervention
The purpose of this intervention was to undertake a system based inspection of the Fuelling Machine, Irradiated Fuel Disposal Facility and the Ponds Area systems at EDF Energy Nuclear Generation Limited’s (EDF NGL) Hartlepool power station in line with the planned inspection programme contained in the Hartlepool Integrated Intervention Strategy for 2021/22.
Interventions Carried Out by ONR
The inspection was undertaken by a multi-disciplinary team of ONR inspectors, including the Hartlepool Site Inspector, Control & Instrumentation (C&I), Nuclear Liabilities Regulation (NLR) and Internal Hazards specialist inspectors.
The aim of the inspection of the Fuelling Machine, Irradiated Fuel Disposal & Ponds Area systems was to confirm the adequacy of implementation of the safety case against the following licence conditions:
- LC 10 Training – requires EDF 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 EDF 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 EDF 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 EDF 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 EDF 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.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
From the System Based Inspection on the Fuelling Machine, Irradiated Fuel Disposal & Ponds Area, I concluded that:
- LC 10 (Training) – I examined the training records of a number of personnel involved in operations and maintenance activities associated with the fuel route. I judged that the personnel undertaking these operations and maintenance activities were suitably qualified and experienced. I also had discussions on the arrangements in place for the training of personnel. These were considered appropriate for ensuring staff are suitably trained and experienced. I therefore assigned a rating of ‘Green’ (no formal action) for LC10 compliance.
- LC23/ LC24 - (Operating Rules) and LC 24 (Operating instructions) - I sampled the fuel route safety case and associated Technical Specifications to determine whether the principal limits and conditions were identified and enacted into station procedures and operator surveillances. I considered the principal limits and conditions of the fuel route 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, operating and maintenance instructions associated with the system. Overall, I considered they were implemented via clear working instructions, but did identify some minor issues with some of the maintenance instructions were the clarity could be improved. I included an action in a Level 4 Regulatory Issue to track this issue. Overall, I considered EDF NGL provided an adequate level of assurance and evidence to demonstrate compliance against LC 23/24. As such, an inspection rating of ‘Green’ (no formal action) was assigned for LC 23/24.
- LC 27 (Safety Mechanisms, Devices and Circuits) – Based on the areas sampled in our inspection of LC23, LC24, LC28, security of computer based systems important to safety and the system health, I was satisfied that suitable and sufficient safety mechanisms, devices and circuits are connected and in working order to meet the requirements of the safety case. As such, an inspection rating of ‘Green’ (no formal action) was assigned for LC 27.
- LC 28 (Examination, Inspection, Maintenance and Testing) – I examined several maintenance schedule items and associated work order cards. I confirmed that generally maintenance was being undertaken in line with the intervals. However, I did identify a maintenance schedule item that was not tested on its due date (but was still within the 12-week tolerance period). In addition, I noted that Fuel Route did not appear to be fully applying station/company arrangements to ensure that maintenance is completed within maximum tolerance dates as required by LC28, which could potentially impact nuclear safety. I have therefore raised a Level 3 Regulatory Issue to track this issue. I also identified a number of other minor shortfalls against LC28 relating to control and supervision and timely scanning of work order cards, and also a weight sensing system drifting out of tolerance on repeat occasions. Two Level 4 Regulatory Issues have been raised to track these issues. As such, an inspection rating of ‘Amber’ (seek improvement) was assigned for LC 28.
- LC34 (Leakage and Escape of Radioactive Material and Radioactive Waste) - I did not seek to obtain evidence to provide a rating for this LC as it is subject to other ONR compliance inspections that are planned to take place in 2021/22.
Conclusion of Intervention
From the evidence sampled during this SBI, I judged that Hartlepool’s Fuel Route System (Fuelling Machine, Irradiated Fuel Disposal & Ponds Area) adequately fulfils the requirements of the safety case and fulfils its safety functional requirements. However, I judged there were shortfalls in compliance against LC28, as detailed above. Level 3 and 4 Regulatory Issues have been raised to address these shortfalls.
The intervention findings were shared and accepted by EDF NGL as part of normal inspection feedback.