Date(s) of inspection:
- August 2023
Aim of inspection
This inspection aims to confirm that the appropriate C&I related statutory outage activities that are necessary to support safety case claims have / will be undertaken. The inspection will involve a sample review of HRA Reactor 2 (R2) 2023 statutory outage (R213) activities carried out in relation to C&I equipment and systems important to nuclear safety and will consider compliance of the associated arrangements in relation to Licence Condition (LC) 28 – examination, inspection, maintenance and testing (EIMT). The findings of this inspection will contribute to ONR’s regulatory decision to grant Consent to the return of R2 to normal operating service in accordance with LC 30 – periodic shutdown.
Subject(s) of inspection
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
During this inspection we sampled examination, inspection, maintenance and testing (EIMT) related activities on C&I equipment and systems important to nuclear safety, based on the schedule of activities contained within the outage intentions document for R213. The activities we sampled had either been satisfactorily completed or were on schedule to be completed. It should be noted that in relation to the latter we were confident, based on the information provided, that the outstanding EIMT activities would be completed satisfactorily.
We did identify a small number of maintenance record keeping shortfalls and raised them with the relevant system engineers, who agreed to address them. We provided advice to system engineers where appropriate to prompt consideration of potential further improvements to maintenance records.
We did identify two regulatory issues (RI) regarding the recording of test equipment used on work order cards and housekeeping, and will monitor their progress to resolution as part of normal regulatory business. However, it should be noted that we did not consider either of these issues would pose an immediate or significant risk to nuclear safety. Nor did we consider that either of them needs to be addressed before R2 can return to service.
During the inspection we held discussions with several C&I equipment and system stakeholders and found that they had a good understanding of the systems and equipment they were responsible for and that they appreciated the importance of the statutory outage work being undertaken. We also noted positive examples of improvements to arrangements arising from learning from experience, and we noted the reported positive impact of new staff joining and the efforts made to transfer knowledge and train new staff effectively.
Based on our sample inspection of the C&I aspects of the HRA R2 2023 statutory outage (R213) we have assigned an intervention rating of Green to LC 28 (EIMT) compliance.
We raised two RIs that have been captured in WIReD as RI-11641 and RI-11643 and will monitor their progress to resolution through normal regulatory business. It should be noted that we did not consider that these RIs posed an immediate or significant risk to nuclear safety or needed to be addressed before R2 returns to service.
We did not identify any significant issues in relation to the C&I equipment and systems during this inspection that could prevent ONR from issuing a Consent to allow HRA R2 to return to service. Based on our sampled inspection of the C&I aspects of the HRA R2 2023 statutory outage (R213), we recommend that support be given for a Consent to allow R2 to return to service. This is subject to the completion of the planned EIMT activities and the completion of any emergent work.