Date(s) of inspection:
- March 2023
Aim of inspection
System based inspections (SBIs) are an essential element of ONR’s overall interventions on nuclear licensed sites. They are intended to establish that the basic elements of a site/facility safety case as implemented in safety systems and structures are fit for purpose and that they will fulfil their safety functional requirements (ONR-INSP-GD-059 Issue 8.2).
This intervention is in line with ONR’s Operating Reactors sub-division Integrated Intervention Strategy (IIS) for 2022/2023.
The overarching aims of this SBI were to:
- Evaluate (on a sample basis) whether the systems covering buildings, structures and infrastructure at Hartlepool power station meet the safety functional requirements defined in the safety case.
- To test the adequate implementation of arrangements made under the Licence Conditions (LC) listed as Inspection Activities.
Subject(s) of inspection
- 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: AMBER
- LC 34 – Leakage and escape of radioactive material and radioactive waste – Rating: Not Rated
- Overall Inspection Rating – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
A team of specialist inspectors, assisted by the Hartlepool nominated site inspector performed a SBI of the Buildings, Structures and Infrastructure system to judge the system performance against its safety function. Through examination of this system and associated sub-systems, we performed compliance inspections against the listed LCs.
We considered that LC34 (Leak and Escape of Radioactive Material and Radioactive Waste) was not applicable to the sampled system components.
This intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides, which can be found at Office for Nuclear Regulation (ONR) Compliance inspection – Technical inspection guides) in the areas inspected.
From the areas sampled during this inspection, we judged that overall the Buildings, Structures and Infrastructure system met the requirements of the safety case.
LC10 (Training) – We examined the training records for a sample of the personnel involved in the inspection of the system. We found that essential training was generally within date, with two minor anomalies. An Observation was raised with respect to the ‘one-off’ role out of a particular training module in 2015/16. We judged that compliance with LC 10 met ONR’s expectations and hence assigned an inspection rating of Green.
LC23 (Operating Rules) and LC 24 (Operating Instructions) – Based on the evidence sampled we concluded that suitable limits and conditions had been derived from the safety case, and are implemented through the technical specifications (operating rules) and station operating instructions. We found that the sampled operating instructions clearly identified appropriate operator actions to be taken following receipt of warnings of significant high winds, following high wind or seismic events. An Observation was raised in relation to a station operating instruction, which required updating. We judged that compliance with LC 23 and LC 24 was consistent with ONR’s expectations and hence assigned an inspection rating of Green to both LCs.
LC27 (Safety Mechanisms, Devices and Circuits) – We sampled devices identified in the station’s maintenance schedule against safety case requirements. We confirmed that the seismic monitoring equipment was functional and available. We also confirmed that the non-return flap valves in the Turbine Hall flood barrier were available and met the requirements of the associated technical specification. The potential for identified corrosion to challenge the deployment of a particular dam-board was noted and recorded as an LC 28 issue. We therefore considered that compliance with LC 27 met ONR’s expectations and hence assigned an inspection rating of Green.
LC28 (Examination, Inspection, Maintenance and Testing) – We sampled LC 28 arrangements and noted some shortfalls with respect to their alignment and the implementation of identified responsibilities. A series of shortfalls were noted regarding the management and rectification of safety related defects. An Observation was raised in relation to dam-board maintenance and whether observed corrosion could prevent removal of boards from their stored position. Overall, significant shortfalls with LC 28 compliance were judged to exist when compared with appropriate benchmarks and relevant good practice and an inspection rating of Amber was assigned.
A single ONR Regulatory Issue (RI-11362) has been raised to capture the actions identified in this intervention report. Satisfactory close-out of the issue will be monitored by the ONR civil engineering specialist and nominated site inspector as part of routine regulatory business.
Following the SBI of the Buildings, Structures and Infrastructure system we judged that compliance with LC10, 23, 24 and 27 met the expected standards and were rated as Green, with a RI-11362 raised to address shortfalls identified with respect to LC28 compliance, which was rated Amber. Overall, we judged that the Buildings, Structures and Infrastructure system met the requirements of the safety case.
There were no findings from this inspection that could significantly undermine nuclear safety. At present, no additional regulatory action is needed over and above the planned interventions of Hartlepool as set out in the integrated intervention strategy, which will continue as planned.
I judged that overall, from the information sampled, station staff interviewed, and the plant inspected that the Buildings, Structures and Infrastructure system adequately met the requirements of the safety case and awarded an overall inspection rating of Green, relevant good practice generally met.
I identified four areas of minor non-compliance and raised these as Observations. Based on the discussions held, I am satisfied that EDF-NGL understood the areas for improvement and that they will address these as part of routine business. However, I did request a statement from EDF-NGL Independent Nuclear Assurance once they have witnessed the maintenance and deployment of dam board FB109. If any updates are required to the related arrangements (e.g., to include greasing) these can then be discussed.
A significant shortfall was identified, and a regulatory finding raised with respect to LC 28 compliance and the management and rectification of nuclear safety related defects. A Level 4 Regulatory Issue (RI-11362) has been raised to monitor and track the Licensee’s progress made in addressing this shortfall.