Executive summary
Date(s) of inspection:
Aim of inspection
System based inspections (SBIs) are an essential element of ONR’s overall intervention on a nuclear site.
An SBI comprises an examination of a systems safety case and supporting documentation, with a view to ascertaining the adequacy of the implementation of the Licensee’s arrangements as part of licence condition compliance. These inspections are generally undertaken with the support of specialists from within ONR and are informed through a review of the safety case (including supporting references), discussions with station specialists, from inspection and sampling documents and records.
A sampling approach is used to select the areas inspected, concentrating on those which pose the greatest risk and / or the most severe consequences. This improves effectiveness of ONR’s resources and improves the overall efficiency.
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: GREEN
- SyDP 4.1 - Procurement and Intelligent Customer Capability - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
LC10
The training records of a sample of staff with roles in the management, operation and / or maintenance of the emergency generation were reviewed.
I was satisfied from the sample inspected that staff were suitably qualified and experienced to undertake the roles related to the systems inspected.
On this basis I considered a Green (no formal action) inspection rating for license condition was appropriate.
LC23
NGL provided an overview of the current Safety Case for emergency generation. A clear line of sight was established between the safety case and the Technical Specifications, identifying the Operating Rules.
I identified that individual Technical Specifications do not explicitly state the requirement to consider the impact of other Technical Specifications, however Index (1.6) was identified as providing this information. I advised NGL that a link to Index (1.6) would support operators in their deliberations when entering Technical Specification conditions.
Based on the documentation examined and discussions, I judged that limits and conditions had been identified in the safety case and had been appropriately implanted. I therefore assigned a green (no formal action) inspection rating for this license condition.
LC24
I sampled and examined a range of operating instructions and compliance check sheets, which I judged consistent with the claims in the safety case.
Based on the documentation examined and discussions, I judged that the operating instructions were consistent with the claims in the safety case I therefore assigned a green (no formal action) inspection rating for this license condition.
LC27
NGL demonstrated availability of key plant through operator walkdowns and completion of check sheets confirming compliance with the relevant Technical Sheets.
Based on the documentation examined and discussions, I judged that suitable and sufficient safety mechanisms, devices and circuits are properly connected and in working order to meet the requirements of the operating limits and conditions identified within the safety case. Therefore, a green (no formal action) inspection rating for licence condition was considered appropriate.
LC28
I sampled a number of maintenance activities from the maintenance schedule. I examined the work order cards from the previous occurrence of the sampled maintenance activities. I also examined the plant item operating instructions and maintenance schedule policy statements associated with the sample.
I considered NGL to have a good understanding of the condition of diesel generators for each diesel train. This was confirmed by a plant walkdown of selected diesel generator systems.
Based on the documentation examined, discussions and plant walkdown undertaken I judged, on this occasion, a green (no formal action) inspection rating against this licence condition.
Intelligent Customer / Supply Chain
As part of this SBI I also explored the dutyholders arrangements with regards to Intelligent Customer and Supply chain arrangements.
NGL utilise the Proactive Obsolescence Management System. This is a database and search tool designed to provide vendor obsolescence information.
During this part of the inspection I examined NGL's arrangements for the supply of diesel fuel NGL remarked that they currently had two suppliers under contract. Each diesel delivery was tested through chemistry group to ensure that it met NGL's specification. I was content with this response.
Conclusion
LC10
I was content that the training records of the sampled individuals, were appropriate to the tasks and duties identified (confirm that individuals are competent (and “in-date” of training) to deliver that role and activity, NS-INSP-GD-010), (Identification of competencies required to perform a particular role, NS-INSP-GD-010).
Based on the training records sampled and discussions during the inspection, I was judged that staff were appropriately SQEP to undertake the roles related to the systems inspected.
On this basis I considered NGL merits a Green (no formal action) inspection rating for license condition 10 on this occasion and for the sample inspected.
During this part of my inspection I was cognisant that NGL's training arrangements had previously been the subject of an LC10 Licence condition compliance inspection (ONR-OFD-IR-123, 2019/358765) and judged that further consideration was disproportionate.
LC23
Based on the documentation examined and discussions, I judged that limits and conditions had been identified in the safety case and had been appropriately implanted through the TS. I therefore assigned a green (no formal action) inspection rating for license conditions 23 on this occasion for the sample inspected.
LC24
NGL could not confirm what the operational response to an Alarm had been, in addition a work request to investigate / rectify the defect did not appear to have been raised which would be the expectation (Operating instructions are consistent with conservative actions, and provide information necessary to recover from malfunctions, faults, or failures during the operations, NS-INSP-GD-024). I considered this to be a shortfall against our expectations. In response NGL have raised a condition report (CR) to investigate the alarm response.
As a CR has been raised and the site inspector is planning to undertake a targeted intervention next year regarding alarm response, we raised this as a regulatory observation to be addressed through normal regulatory activity and through the forthcoming inspection.
(Note: Following the inspection NGL forwarded a copy of the Heysham 2 Power Station Departmental Instruction, Control Room Alarms and Defects, HB/ODI/12/031, we did not get the opportunity during the inspection to discuss this as it was not made available for examination).
Based on the documentation examined and discussions, I judged that the operating instructions were consistent with the claims in the safety case and TS’s and that the compliance sheets had been appropriately completed. I identified a shortfall in an alarm response, are content with NGL’s response and note the targeted intervention planned for next year on this subject. I therefore assigned a green (no formal action) inspection rating for license condition 24 on this occasion for the sample inspected.
LC27
Based on the documentation examined and discussions, I judged that suitable and sufficient safety mechanisms, devices and circuits are properly connected and in working order to meet the requirements of the operating limits and conditions identified within the safety case. Therefore, on this occasion, a green (no formal action) inspection rating for licence condition 27 was applicable for the sample inspected.
LC28
I was content that EIMT activities sampled had been competed appropriately and were judged to be appropriately completed and in line with the PIOI and MSPS (Ensure that EIMT has been carried out in accordance with licensee maintenance instructions) (Review the output records from the EIMT activity and check they have been completed to the detail required by the arrangements, NS-INSP-GD-028). Results were within the acceptance criteria. However, for One work order card (3.6.0.0.1.0, Diesel Generator X Train, Test Run, 20W, WOC Ref.12671000) examined recorded out of tolerance readings and one instance of the alarm level being reached. I observed that there was no recognition of this on the work order card before signing off. We advised NGL that the data on the WOC could be used for trending and that we would have expected recognition of the adverse trend on the WOC (Arrangements should include the regular review of EIMT performance, including trend analysis capable of identifying any backlogs, NS-INSP-GD-028).
I considered NGL to have a good understanding of the condition of diesel generator components through a heat map identifying the considered condition of components for each diesel train. This was confirmed by a plant walkdown of selected diesel generator systems with the plant condition generally consistent with the heat map (Arrangements should recognise and assess longer term impacts on SSCs. The arrangements should take due consideration of asset management requirements (e.g. ageing and degradation, obsolescence) or reference out to a separate management system, NS-INSP-GD-028).
Based on the documentation examined, discussions and plant walkdown undertaken we judged, on this occasion, a green (no formal action) inspection rating against licence condition 28 was applicable for the sample inspected.