Date(s) of inspection
- October 2023
Aim of inspection
The inspection is scheduled during the outage given the increase in potential for fires, potentially compromised protective measures and numbers of people. The aim of this inspection is to undertake a planned joint nuclear/ conventional fire safety inspection at Heysham 1 to determine the adequacy of implementation of the Licensee’s claims associated with the fire prevention and protection including fire detection and suppression systems to ensure fire (conventional and nuclear) risks are reduced as low as reasonably practicable. This will be achieved by determining how the Heysham 1 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
- LC10 – Training – Rating: Green
- LC24 – Operating instructions – Rating: Green
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
- Overall Inspection Rating – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This was a planned inspection at the EDF-NGL Heysham 1 site. The inspection was undertaken as part of the intervention strategy for Operating Reactors Sub-Division.
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 fire safety (FS) inspection at Heysham 1 considered both Nuclear and Life Fire Safety (LFS) and was undertaken by the Nominated Site Inspector and fire specialist inspectors to determine whether fire risks at site are suitably controlled. The inspection focussed on areas of the Reactor Building, Turbine Hall, contractors cabins and Admin/Workshops/Stores Building with the greatest nuclear and conventional fire risks respectively.
The FS inspection assessed the implementation of arrangements for managing life fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and compliance against the requirement of Licence Conditions LC10 Training, LC24 – Operating Instructions & LC28 Examination, inspection, maintenance and testing.
I sampled the training records for several operators that fulfil roles associated with the fire system. This included, the Fire Systems Co-ordinator (FSC), Fire Risk Assessor, Fire System Engineers and an operator. I considered that EDF NGL is adequately implementing its training arrangements as staff are either trained or in the process of undertaking the training currently identified as necessary to carry out the fire related aspects of their role. I judge that EDF NGL is adequately implementing its arrangements with respect to Training and award a Green rating for LC10.
I sampled the several operating instructions and reviewed surveillance and compliance instructions. I considered that operations were being carried out in accordance with the written instructions and that the instructions were clear and unambiguous. I judge that EDF NGL is adequately implementing its arrangements with respect to Operating Instructions and award a Green rating for LC24.
I sampled the EIMT records on several components of the Fire Protection System including fire dampers, doors, barriers and fire extinguishers. I considered the equipment was maintained in accordance with the safety case requirements. I judged that EDF NGL is adequately implementing its arrangements with respect to EIM&T and award a Green rating for LC28.
I sampled arrangements and found adequate evidence for compliance with the FSO. Advice and observations were raised in several areas but these were not of sufficient significance to affect the overall rating. A Level 4 Regulatory Issue was raised with respect to Article 8 General Fire Precautions (discussed below under Article 8) which requires EDF NGL initially to make an assessment and therefore also does not affect the overall rating. I judge that overall EDF NGL is adequately implementing its arrangements with respect to compliance with the Regulatory Reform ( Fire Safety) Order 2005 and award an Green rating for this part of the inspection.
EDF NGL are adequately implementing preventative and protective measures in line with the requirements of Article 8, and were already aware of and are responding positively to potential deficiencies regarding the provision of fire resisting compartmentation and fire protection requirements for raised floor areas in the Admin/ Workshop /Stores area, and I therefore award a Green rating. I did, however, identify areas that require assessment in regards to the provision of fire resisting compartmentation and fire protection in the Admin/ Workshop /Stores area and have raised a Level 4 Regulatory Issue (RI 11826), to monitor this process, requiring EDF NGL to assess and address potential issues in these areas.
Overall, I found that EDF NGL’s existing arrangements made under LC10, LC24 and LC28 and the requirements of the Regulatory Reform (Fire Safety) Order 2005 are adequate for controlling risks related to fire hazards. From the evidence sampled during this SBI I judge that there were no matters that have the potential to impact significantly on nuclear safety or life safety.
During the inspection I identified some matters of advice or observation for consideration however these do not significantly impact on the overall adequate provision of safety.
I have raised a Level 4 Regulatory Issue (RI-11826) to track the assessment of fire resisting compartmentation and protective measures in the Workshop area. These considerations were known to station before my inspection having been raised in a fleet REVL and by the Fire Risk Assessment for the area. The fleet wide REVL (Routine Evaluation – assessment number 1334849) was raised following an ONR fire safety inspection at Torness power station and requires other stations in the EDF-NGL fleet to consider management of compartmentation. Station are in the process of assessing potential issues and I therefore have confidence that this will be managed appropriately and if any corrective actions are required that they will be undertaken as part of this process. I judge that these matters are not of sufficient significance to warrant an amber rating.
Inspection findings were shared with and accepted by EDF NGL as part of inspection feedback.
I consider that EDF NGL adequately demonstrated ownership and implementation of the fire protection systems safety case to ensure and maintain nuclear safety and adequately demonstrated arrangements for Life Fire Safety and on that basis award EDF NGL a Green rating for both elements of the inspection.