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Heysham 2 power station – LC 19, 20, 21 and 22 inspection

  • Site: Heysham 2
  • IR number: 21-111
  • Date: November 2021
  • LC numbers: 19, 20, 21, 22

Executive summary

Purpose of Intervention

This was a planned inspection of EDF Energy Nuclear Generation Ltd’s (NGL’s) Heysham 2 nuclear power station, undertaken as part of the intervention strategy for the Operating Facilities Division of the Office for Nuclear Regulation (ONR).

The inspection was conducted in accordance with the planned inspection programme contained in the Heysham 2 Integrated Intervention Strategy for 2021/22.

Interventions Carried Out by ONR

This inspection was against licence conditions (LC):

  • LC19 - Construction or installation of new plant
  • LC20 - Modification to design of plant under construction
  • LC21 - Commissioning
  • LC22 - Modification or experiment on existing plant

These LC’s require the licensee to provide a system of rigorous and appropriate control of changes to plant or processes on the licensed site. The inspection comprised of a desktop review of the licensee’s arrangements, discussions with the licensee staff and sampling the implementation of the arrangements.

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

No system based inspection was undertaken hence, this is not applicable for this intervention.

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

For LC19 and LC20 we targeted NGL’s investment delivery process which is used to deliver new plant. We considered aspects of the design process, the stage gates in the investment delivery process and the management of technical issues. From the evidence sampled we were satisfied that NGL’s arrangements required the provision of adequate safety documentation and that there is an appropriate route for resolution of technical queries and management of changes to the design (via LC20 or LC22 compliance arrangements).

For LC21 we examined the appointment of SQEP individuals for commissioning activities and the role of the test and commissioning panel. From the evidence sampled we considered that the commissioning arrangements sampled are comprehensive and adequately implemented by appropriately qualified and experienced individuals.

For LC22 we examined evidence relating to the close-out of modifications, the arrangements for temporary and urgent modifications and discussed performance indicators associated with NGL’s LC22 modification process. We were content that the modifications sampled had been closed out appropriately. NGL are monitoring several performance indicators for the modifications process and we considered these to be appropriate. We were satisfied that NGL are reducing the number of modifications where the modification had been implemented but not closed out.  

Conclusion of Intervention

From the areas targeted and the evidence examined during the inspection, I consider the licensee has adequate arrangements for compliance with LC’s 19, 20, 21 and 22. The licensee demonstrated adequate implementation of these arrangements. I judge that no formal regulatory action is required over and above the planned inspections at Heysham 2. I identified a number of minor areas for improvement and these will be captured in a Level 4 regulatory issue.

Based on the evidence sampled during this inspection, I judge that an inspection rating of Green is appropriate against LC 19, 20, 21 and 22, in accordance with the ONR inspection rating guidance.