Executive summary
Date(s) of inspection:
Aim of inspection
This inspection was a planned chemistry-themed inspection that considered Licence Conditions LC 23 (Operating Rules) and 24 (Operating Instructions) for rating, and included a number of intelligence-led chemistry-specific topics. This inspection included follow-up of Regulatory issue 9007, 10520 and 10694.
Subject(s) of inspection
- LC23 - Operating rules - Rating: Green
- LC24 - Operating instructions - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This was a planned chemistry-themed inspection agreed with the nominated site inspector, that took place over 18 and 19 January 2023. The inspection was to rate LC23 (Operating Rules) and LC24 (Operating Instructions) in terms of station chemistry control, and to seek wider assurances relating to chemistry-specific activities at the site, particularly including progress against a number of regulatory issues.
I identified that chemistry-relevant limits and conditions (operating rules) at Heysham 2 were reflected in the safety case and effected across a number of relevant station operating instructions (SOI).
I identified only minor issues with the implementation of operating rules in station documentation at HYB in that the expectation for action on entry to be the norm for any entry into a chemistry action level was not well reflected, and the definition for action level 3 (AL3) was absent from this SOI. Station raised CR1304225 to capture these observations.
Overall, from the perspective of chemistry, I rated both LC23 and LC24 GREEN at HYB.
Conclusion
Licence Condition 23 - Operating Rules
I identified that chemistry-relevant limits and conditions (operating rules) at HYB were reflected in the safety case and effected across a number of relevant station operating instructions (SOI). In particular, Station Operating Instruction 2.1.8 Section 9 (Condensate and Feed) contained a number of chemistry Limits and Conditions of Operation (LCOs). This SOI is being used at HYB to consolidate a number of LCOs into a single source, which will in turn be referenced by multiple other instructions to operators. I consider this a sensible approach which will avoid any requirement for multiple documents to be edited in the event of an LCO change. I identified only minor issues with the implementation of operating rules in station documentation at HYB in that the expectation for "action on entry" to be the default expectation for any entry into a chemistry action level, which was not captured in SOI 2.1.8, and the definition for action level 3 (AL3) was also absent from this SOI. Overall, from the perspective of chemistry I was content, and rated LC23 GREEN at HYB.
Licence Condition 24 - Operating Instructions
My sample of operating instructions, including those considered under LC23 above, identified no significant issues. I identified a good line of sight from chemistry operating rules into instructions for both feedwater chemistry (SOI 2.1.8 > SOI 2.1.1 and 2.1.2) and pond water chemistry (TS 9.1.1/TS 9.10.1 > CCS0011 and HYB/OTI/SWI/011/CSM/PCM/046). I made two minor recommendations, relating to the omission of an AL3 definition and the missed opportunity to reflect the philosophy of "action on entry" (both from Station Operating Instruction (SOI) 2.1.8) and from the chemistry perspective overall I rated LC24 GREEN at HYB.