Executive summary
Date(s) of inspection:
March 2025
Aim of inspection
Fire hazards, if not controlled, can present risks to safety (nuclear and conventional) including common cause failure of safety systems. It is therefore important that the risks from fire are suitably controlled.
This inspection was scheduled during the outage given the increase in potential fire risks. The aim of the inspection was to undertake a planned fire safety inspection at Heysham 2 during outage to determine the adequacy of implementation of the Licensee’s claims associated with fire prevention and protection to ensure fire (conventional and nuclear) risks are reduced as low as reasonably practicable. This was be achieved by determining how the Heysham 2 fire safety cases and risk assessments are implemented to ensure safety functional requirements are delivered.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: GREEN
- LC 10 - Training - Rating: GREEN
- LC 23 - Operating rules - Rating: GREEN
- LC 24 - Operating instructions - Rating: GREEN
- LC 27 - Safety mechanisms, devices and circuits - Rating: GREEN
- LC 28 - Examination, inspection, maintenance and testing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The inspection assessed the implementation of arrangements for managing life and nuclear fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and the requirements of Licence Conditions LC10 Training, LC23 Operating Rules, LC24 Operating Instructions, LC27 Safety Mechanisms, Devices & Circuits & LC28 Examination, Inspection, Maintenance and Testing (EIM&T).
Training - I sampled the training for the Fire Systems Co-ordinator (FSC) and Fire System Engineers (SEs). I noted that they were all very knowledgeable and were either trained or in training to carry out the fire related aspects of their role. I provided some advice on areas for improvement but overall considered EDF NGL is adequately implementing its training arrangements.
Operating Rules & Operating Instructions - I sampled the Technical Specifications relating to fire barriers and control of combustible materials. I considered the principal limits and conditions from the fire safety case were identified in the specifications and enacted into station procedures and operator surveillances. I also sampled the operator surveillances and considered they were being appropriately undertaken to confirm the availability of fire system (fire barriers, fire door, fire fighting equipment) and effective control of combustible material. I sampled the associated operating instructions and considered the instructions were clear and unambiguous.
Safety Mechanisms, Devices & Circuits & Examination, Inspection, Maintenance and Testing (EIMT) - I sampled maintenance and reliability of several components of the Fire Protection System including fire dampers, fire doors, fire barriers, fire detection and suppression. I found some shortfalls relating the the maintenance of fire dampers within the Admin Building and raised a Regulatory Issue to ensure these are addressed in a timely manner. I also provided advice on areas for improvement but overall considered EDF NGL is adequately it's EIM&T arrangements. Also, based on the plant walkdown I considered that suitable and sufficient safety mechanisms, devices and circuits were connected and in good working order in line with LC27 requirements.
Regulatory Reform (Fire Safety) Order 2005 - I sampled the life fire safety management arrangements, which included reviewing a selection of Fire Risk Assessments. I provided some advice on areas for improvement but overall considered EDF NGL was in compliance with the FSO.
Conclusion
Based on my sample I found some shortfalls in maintenance expectations for fire dampers and have raised a Regulatory Issue to track progress and provided some advice on areas for improvement, but overall considered EDF NGL is adequately implementing its arrangements with respect to Training, Operating Rules. Operating Instructions, Maintenance and Fire Risk Assessments and therefore award a Green rating for LC10, LC23, LC24, LC27 LC28 & the FSO. As such I judge the fire system is able to fulfil it's safety functional requirements in line with the safety case and award a Green rating (No formal action) for this system.