Executive summary
Date(s) of inspection: January 2024
Aim of inspection
The aim of this License Condition 26 inspection was to gain increased oversight of EDF Energy Nuclear Operations Nuclear Generation Limited (NGL)’s control of operations at the Hartlepool site, with a particular focus on reactivity management.
This is the fourth inspection at which reactivity management arrangements have been examined across the AGR fleet during financial year 2023/24. This is due to intelligence from events that have occurred in the AGR fleet. At Hartlepool, an incident occurred during a reactor startup in December 2022 in which power exceeded that allowable for the control rod state at the time (INF-2603). NGL’s investigation identified corrective actions including new reactivity management training and improvement of some related operating documentation. As a result of INF-2603, ONR’s site inspector identified future regulatory action to conduct a ‘multi-disciplinary inspection likely covering control room standards and training as well as criticality management’. This inspection fulfils that purpose.
Subject(s) of inspection
- LC26 - Control and supervision of operations - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Informed by guidance in NS-INSP-GD-026 and IAEA specific safety guide SSG-76 (‘conduct of operations at nuclear power plants’) we inspected on a sampling basis whether NGL’s local arrangements for reactivity management are:
- compliant with relevant good practice;
- compliant with its own company policy as specified in BEG/SPEC/OPS/028; and
- being adequately implemented by suitably qualified and experienced personnel (SQEP).
We found through review of station operating instructions (SOIs), review of pre-job brief templates and discussion with CCR staff that a number of principles for reactivity management we selected from IAEA SSG-76 and BEG-SPEC-OPS-028 are adequately implemented at Hartlepool. We did not find any significant shortfalls, but did provide regulatory advice on several points and have raised one Level 4 Regulatory Issue. This is due to a lack of prompting in some SOIs for CCR staff to undertake Reactivity Briefs at the right point in a procedure.
We sampled the slides from the new reactivity fundamentals training course developed in response to INF-2603, as well as the planned content and introductory slides for the first module of simulator training to be provided to CCR staff in 2024. On the basis of the material sampled, we were satisfied that the reactivity management classroom training material and simulator programme now in place at Hartlepool appeared adequate. We saw evidence that the CCR unit desk engineer and supervisor we had spoken to on the day were up to date with the training requirements of their duly authorised person (DAP) roles. They had both completed the new reactivity fundamentals training course in 2023. However, we found that one CCR shift team had not yet completed this training, and it had not yet been formally assigned to operations staff as a 12-monthly training requirement. Both of these were requirements of NGL's INF-2603 apparent cause investigation (ACIN), which had nevertheless been closed. ONR’s site inspector will follow up on full completion of this action either through normal business or via an LC7 inspection planned later in 2024.
Conclusion
Overall we rated the inspection green. In general, we found that relevant good practice and the requirements of NGL’s own Company Specification for Reactivity Management are met. We provided several points of regulatory advice, but did not find any shortfalls that we judged to warrant an amber inspection rating.