- Inspection date(s): 13/9/2022
Purpose of inspection
The aim of this inspection is to test the station’s compliance with the requirements of Licence Condition 10 (Training) and Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons) specifically:
- That all those people on the site who have responsibility for any operations which may affect safety are adequately trained for that purpose.
- A suitable competence management process encompassing all individuals influencing safety, and
- Additional processes for appointing designated individuals for specific roles required by other licence conditions
Subject(s) of inspection
The following actives were the subject of this inspection:
- LC 12 – Duly authorised and other suitably qualified and experienced persons – Rating – Amber
- LC 10 – Training – Rating – Amber
This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Heysham 2 (HYB) Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR). It was carried out in accordance with the planned inspection programme contained in the HYB Integrated Intervention Strategy (IIS) for 2022/23.
The inspection was focused on the Operations Department and actions in response to the Significant Adverse Condition Investigation (SACI) into HYB’s Reactor 7 automatic trip on Flux Protection (SACI 1246364 – INF-1148). Itcomprised both the review of documentation plus on-site interviews and discussions to gain assurance that the training, competence and appointment of personnel required to maintain nuclear safety is being controlled adequately.
The inspection was conducted by one specialist Human Factors inspector, one specialist Leadership and Management Safety inspector and ONR’s HYB nominated site inspector. It was performed in line with ONR’s guidance as described in our technical inspection guides.
I found clear, comprehensive and well-structured development programmes are defined for each Operations Department post and the training team maintains comprehensive recording of individual technical competence and an aggregated record of individual technical training compliance within teams. Sampling did not identify a similar record of individual or team non-technical individual competence. Even so, I identified instances where individuals have been out of ticket for posts and roles whilst performing duties which I found to be the result of the incorrect posts and roles being assigned to an individual rather so that compliance reporting is conducted against an inaccurate requirement.
In response to SACI 1246364, improvements have been developed and delivered to simulator Crew Resource Management training including the development of more realistic simulator scenarios that have been developed to test crew dynamic issues, active participation of Shift Managers in demanding scenarios and assessments tailored to Crew Resource Management to test the shift dynamics. I found also, however, that the active participation of the Shift Manager in the revised simulator training has introduced a requirement for a second simulator tutor which, to date this has been met through the use of overtime which is not a sustainable solution and commitment to formally resource the post has not been forthcoming.
Additionally, the Simulator Lead Instructor has developed a Shift-dynamics reporting format that I consider to be good practice and should be developed further through engagement across the fleet.
Although I identified one instance of a lapse in DAP re-authorisation, I consider the implementation of the Authorisation process to be a strength that provides confidencein the competence of those in control and supervisory roles for nuclear safety.
The Fleet Performance Improvement Governance, Oversight, Support and Performance (GOSP)intervention conducted in May 2021 placed the Station into enhanced attention for thetraining of unqualified persons undertaking tasks and maintenance Instructional delivery. I judge that that appropriate immediate action had been taken to assess the issues identified in the GOSP intervention and identify corrective actions.I found shortfalls in the Station’s implementation of the training governance and oversight arrangements, which reinforces the conclusion of a Mandatory Evaluation (MEVL) into shortfalls in Heysham 2 CCR Training that ‘TheRoot Cause was governance and oversight functions were ineffective.’ Further, I found that the corrective actions arising from the GOSP intervention have not been embedded into the business whichI judge to be due to the ineffective governance and oversight functions.
Site Licence Condition 10 – Training
Based on the evidence sampled, I judge that HYB has shortfalls in the governance and oversight of NGL’s arrangements for compliance with LC10. In accordance with ONR’s guidance on inspection ratings therefore, I have assigned an LC10 inspection rating of Amber (Seek Improvement).
Site Licence Condition 12 – Training
Based on the evidence sampled, I judge that HYB has shortfalls in the governance and oversight of NGL’s arrangements for compliance with LC12. In accordance with ONR’s guidance on inspection ratings therefore, I have assigned an LC10 inspection rating of Amber (Seek Improvement).
I have raised two Level 3 and one Level 4 regulatory issue because of this inspection. Further, I recommend that a follow-up inspection of LC10 and LC12 should be conducted in twelve month’s time.