EDF Energy Nuclear Generation Limited – Hartlepool – Nuclear · EXECUTIVE SUMMARY Title EDF...

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PROJECT ASSESSMENT REPORT Unique Document ID and Revision No: ONR-HRA-PAR-14-014 Revision 1 TRIM Ref: 2014/0411687 Project: Reactor 1 Periodic Shutdown 2014 Site: Hartlepool Title: EDF Energy Nuclear Generation Limited – Hartlepool – Nuclear Site Licence No. 59 - Consent to start up Reactor 1 under Licence Condition 30(3) Licence Instrument No: (if applicable) 548 Nuclear Site Licence No: 59 Licence Condition: 30(3) Document Acceptance and Approval for Issue / Publication Role Name Position Signature Date Author Principal Inspector 18 November 2014 Reviewer Principal Inspector 18 November 2014 Accepted by 1 Superintending Inspector 20 November 2014 Approval for publication 2 Superintending Inspector 20 November 2014 Revision History Revision Date Author(s) Reviewed By Accepted By Description of Change A 14 November 2014 n/a 1 st draft for peer review 0 18 November 2014 n/a Rev 0 for SI comment 1 19 November 2014 n/a Rev 1 final ammendments Circulation (latest issue) Organisation Name Date 1 Acceptance of the PAR to allow release of LI 2 Approval is for publication on ONR web-site, after redaction where relevant

Transcript of EDF Energy Nuclear Generation Limited – Hartlepool – Nuclear · EXECUTIVE SUMMARY Title EDF...

PROJECT ASSESSMENT REPORT

Unique Document ID and Revision No:

ONR-HRA-PAR-14-014 Revision 1

TRIM Ref: 2014/0411687

Project: Reactor 1 Periodic Shutdown 2014

Site: Hartlepool

Title: EDF Energy Nuclear Generation Limited – Hartlepool – Nuclear Site Licence No. 59 - Consent to start up Reactor 1 under Licence Condition 30(3)

Licence Instrument No: (if applicable) 548

Nuclear Site Licence No: 59

Licence Condition: 30(3)

Document Acceptance and Approval for Issue / Publication

Role Name Position Signature Date

Author Principal Inspector

18 November 2014

Reviewer Principal Inspector

18 November 2014

Accepted by1 Superintending Inspector

20 November 2014

Approval for publication2

Superintending Inspector

20 November 2014

Revision History

Revision Date Author(s) Reviewed By Accepted By Description of

Change

A 14 November 2014

n/a 1st draft for peer review

0 18 November 2014

n/a Rev 0 for SI comment

1 19 November 2014

n/a Rev 1 final ammendments

Circulation (latest issue)

Organisation Name Date

1 Acceptance of the PAR to allow release of LI 2 Approval is for publication on ONR web-site, after redaction where relevant

Office for Nuclear Regulation Deputy Chief Inspector

– Superintending Inspector

Environment Agency

Licensee – Station Director, Hartlepool

– Technical and Safety Support Manager, Hartlepool

Hartlepool Reactor 1 2014 Periodic Shutdown

EDF Energy Nuclear Generation Limited (NGL) - Hartlepool Power Station – Nuclear Site Licence No. 59 - Consent to start up Reactor 1 under Licence Condition 30(3)

Project Assessment Report ONR-HRA-PAR-14-014 Revision 0

18 November 2014 © Office for Nuclear Regulation, 2014 If you wish to reuse this information visit www.onr.org.uk/copyright for details. Published 04/14 For published documents, the electronic copy on the ONR website remains the most

current publicly available version and copying or printing renders this document uncontrolled.

EXECUTIVE SUMMARY

Title

EDF Energy Nuclear Generation Limited – Hartlepool Power Station – Nuclear Site Licence 59 – Consent to start up Reactor 1 under Licence Condition 30(3).

Permission Requested

EDF Energy Nuclear Generation Limited (NGL), the licensee of Hartlepool nuclear power station, has applied for1 Consent from the Office for Nuclear Regulation (ONR) to start-up Reactor 1, in compliance with Condition 30(3) attached to Nuclear Site Licence 59.

Background

Hartlepool power station is a nuclear licensed site operating two Advanced Gas-cooled Reactors, known as Reactors 1 and 2. To continue to operate safely and reliably the reactor plant requires examination, inspection maintenance and testing. Continuous improvement also requires plant upgrades to be implemented where deemed to be reasonably practicable. Whilst some of these activities can take place when the reactor is at power, many of them require it to be shutdown. The licensee’s arrangements require that periodic shutdowns (also referred to as statutory outages) are carried out every three years at each reactor at Hartlepool, providing the opportunity to undertake such activities. On completion of a periodic shutdown the reactor concerned cannot be started up without Consent from ONR under Licence Condition (LC) 30(3).

During the 2014 Reactor 1 periodic shutdown at Hartlepool, which commenced on 16th August 2014, the licensee has conducted:

Examinations, inspections, maintenance and testing (EMIT) activities in accordance with the Plant Maintenance Schedule (MS)

Inspections to support the station safety case Work to comply with statutory requirements (such as Pressure Systems Safety

Regulations) Remedial work to rectify plant adverse conditions and emergent work Work to modify and/or enhance the plant where deemed appropriate. A particular feature of this outage followed the discovery of a boiler spine defect at Hartlepool’s sister station (Heysham 1, Reactor 1). This discovery led to a programme of unplanned inspections and modifications to gain further assurance that the defect observed at Heysham 1 was not present on the boiler spines in both reactors at Hartlepool. ONR’s assessment of NGL’s safety case to support the continued operation of the boilers is reported separately37 and is outside the scope of this start-up report.

In general where inspection work revealed the potential for an adverse plant condition, the licensee has assessed the inspection results in accordance with its arrangements and taken appropriate remedial action as necessary prior to ONR granting Consent to reactor start-up.

The Hartlepool Station Director wrote to ONR requesting Consent to start-up Reactor 1. In his letter, the Director confirmed that following completion of the outstanding work, as controlled by the Operational Safety Review Committee (OSRC), Reactor 1 will be safe to return to service.

The licensee’s internal regulator, Independent Nuclear Assurance (INA), has indicated there are no issues that prevent the start-up or continued operation of Reactor 1. INA has further indicated a Concurrence Part B will be issued once its assessment programme has been concluded. Release of Concurrence Part B is a requisite component that informs the OSRC’s decision to authorise return to service.

The third party Pressure Systems Safety Regulations (PSSR) competent person has issued an inspection report that is included in the licensee’s request for Consent. The final inspection report will be included in the licensee’s final outage report issued within 28 days of reactor restart. The Appointed Examiner for the Reactor pre-stressed concrete pressure vessel (PCPV) has issued a start-up report that concludes the PCPV is in satisfactory condition and fit for return to service for a further period of three years subject to normal in-service surveillance.

Assessment and inspection work carried out by ONR in consideration of this request

The ONR nominated site inspector and specialist inspectors have sampled the licensee’s arrangements for controlling and completing the examination, inspection, maintenance and testing requirements of the maintenance schedule (MS), and other plant modifications of nuclear safety significance, as identified within the outage intentions document (OID). Inspectors have undertaken inspections throughout the periodic shutdown to:

Inspect samples of the licensee’s implementation of arrangements under LC28. Inspect and assess the licensee’s implementation of LC22 modifications, delivered

through NGL’s Engineering Change process Assess the adequacy of control and supervision under LC26 Assess the adequacy of the licensee’s quality management arrangements associated

with activities carried out during the periodic shutdown. The specialist inspectors have undertaken assessments and produced reports for each specialism approved where appropriate by the ONR professional leads. I have considered these reports to assist in the compilation of this Project Assessment Report (PAR) and development of a regulatory judgement that Reactor 1 is fit for return to service.

The regulatory interventions carried out by ONR inspectors have not identified any issues that would prevent ONR from issuing its Consent to start-up Reactor 1 under Licence Condition 30(3).

Matters arising from ONR’s work

There are no outstanding matters arising from the work undertaken by ONR inspectors preventing issue of Licence Instrument 548, a Consent under Licence Condition 30(3) to restart Hartlepool Reactor 1 in relation to the 2014 periodic shutdown.

Conclusions

In summary, ONR have scrutinised the scope of the Reactor 1 outage and found it to be appropriate. Where ONR specialist inspectors have inspected the conduct of the outage they have found the planned work was in progress and inspection results either within the acceptance criteria or correctly sentenced. The NGL quality management system for the outage was found to be a good standard. We have received supporting statements from independent examiners and NGL’s internal

regulators. The Station Director1 has written to ONR certifying completion of all maintenance schedule activities before return to service and requesting ONR issue a Consent to start up Reactor 1.

Following assessment and inspection of NGL’s activities as part of the 2014 periodic shutdown of Hartlepool Reactor 1, I am satisfied that the licensee’s justification to start-up the reactor and operate for a further period of three years is adequate, and that consequently a Consent to start-up the reactor should be granted.

Recommendation

I recommend that in accordance with the request from the licensee, ONR should issue Licence Instrument 548 under Licence Condition 30(3) Consent to start-up Hartlepool Reactor 1.

LIST OF ABBREVIATIONS

ALARP As low as reasonably practicable

APEX Appointed Examiner

BAP Boiler Assessment Panel

BS British Standards

CBIU Channel Bore Inspection Unit

C&I Control & Instrumentation

CNRP Civil Nuclear Reactor Programme

CNS Civil Nuclear Security

EBFP Emergency Boiler Feed Pump

EA Environment Agency

EC Engineering Change

EMIT Examination Maintenance Inspection and Testing

FME Foreign Material Exclusion

GAP Graphite Assessment Panel

GC Gas Circulator

HRA Hartlepool

HOW2 Office for Nuclear Regulation Business Management System

INA Independent Nuclear Assurance

INSA Independent Nuclear Safety Assessment

IR Intervention report

IRR99 Ionising Radiation Regulations 1999

JCO Justification for Continued Operation

KRC Keyway Root Crack

LI Licence Instrument

MS Maintenance Schedule

NGL EDF Energy Nuclear Generation Limited

NICIE2 New In-Core Inspection Equipment mark 2

OAP Outage Assessment Panel

ODH Off-load Depressurised Handling

OID Outage Intentions Document

ONR Office for Nuclear Regulation

OSRC Operational Safety Review Committee

PAR Project Assessment Report

PCPV Pre-stressed Concrete Pressure Vessel

PRV Pressure vessel Relief Valve

LIST OF ABBREVIATIONS

PSSR Pressure Safety Systems Regulations 2000

RTR Rapid Trending Review

RP Radiological Protection

QA Quality Assurance

SAP Safety Assessment Principle(s) (HSE)

SACI Significant Adverse Condition Investigation

SUS Start-Up Statement

TABLE OF CONTENTS 1  PERMISSION REQUESTED ............................................................................................. 10 2  BACKGROUND ................................................................................................................. 10 2.1 General .............................................................................................................................. 10 2.2 Outage Planning and Management ................................................................................... 10 2.2.1  Licensee’s management ............................................................................................ 10 2.2.2  ONR’s intervention management process ................................................................. 11 3  ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN

CONSIDERATION OF THIS REQUEST ............................................................................ 12 3.1 Management Systems ....................................................................................................... 12 3.2 Civil Engineering ................................................................................................................ 13 3.3 Radiation Protection ........................................................................................................... 15 3.4 Mechanical Engineering ..................................................................................................... 15 3.5 Electrical Systems .............................................................................................................. 16 3.6 Structural Integrity .............................................................................................................. 17 3.7 Graphite Core ..................................................................................................................... 19 3.8 Control and Instrumentation (C&I) Systems ....................................................................... 20 3.9 Site Inspector oversight ...................................................................................................... 20 3.10  Events ........................................................................................................................... 21 3.11  Start-up meeting ............................................................................................................ 22 4  SUMMARY OF MATTERS ARISING FROM ONR’S WORK ............................................. 22 5  CONCLUSIONS ................................................................................................................. 24 6  RECOMMENDATIONS ...................................................................................................... 24 7  REFERENCES ................................................................................................................... 25 

1 PERMISSION REQUESTED

EDF Energy Nuclear Generation Limited (NGL), the licensee of Hartlepool nuclear power station, has applied for1 Consent from the Office for Nuclear Regulation (ONR) to start-up Reactor 1, in compliance with Condition 30(3) attached to Nuclear Site Licence 59. This Project Assessment Report (PAR) presents my consideration of this request and recommends issuing Licence Instrument 548, Consent to start-up Reactor 1.

2 BACKGROUND

2.1 General

Licence Condition (LC) 30 Periodic Shutdown of the nuclear site licence issued to NGL for Hartlepool power station requires the licensee to shutdown the reactors in accordance with its plant maintenance schedule (MS), to enable examination, inspection, maintenance and testing to take place in accordance with the requirements of LC28 Examination, Inspection Maintenance and Testing. At Hartlepool, reactor periodic shutdowns are undertaken triennially as specified in the MS preface, which is an Approved document under LC28(5). As part of the shutdown, the licensee also undertook work associated with the requirements of Pressure Systems Safety Regulations (PSSR), previous commitments, and the installation of plant modifications etc.

The licensee requires Consent from ONR under LC30(3) to start-up Reactor 1 on completion of its periodic shutdown. The previous Consent to start-up Reactor 1, Licence Instrument No 540 is dated 17th August 20112. The Reactor 1 2014 periodic shutdown commenced on 16th August 2014.

In addition to planned routine activities, the licensee also undertook a significant amount of work to improve the safety and reliability of the station.

2.2 Outage Planning and Management

2.2.1 Licensee’s management

NGL produced an outage intentions document4 (OID) for Reactor 1 periodic shutdown 2014. The document outlined the outage organisation, infrastructure and management arrangements to deliver the safety related activities being undertaken during the outage. The activities are in accordance with the MS, statutory inspections, modifications and significant work in order to meet the requirements of the relevant sections of LC22, 28, and 30. The document, together with the referenced scope related supporting documents, comprised the outage intentions proposals for Reactor 1.

The licensee’s outage process includes a series of meetings with ONR, viz. the outage intentions meeting12, mid-outage meetings2 and the start-up meeting3.

NGL provided ONR with a copy of the OID prior to holding the outage intentions meeting on 25th February 2014, during which the organisational arrangements and programme of work for the shutdown were discussed. The nominated site inspector and lead structural integrity assessor attended the meeting4 and provided feedback to NGL on the document.

ONR attended the NGL start-up meeting5 on 30th October 2014. The purpose of the start-up meeting was for the licensee to demonstrate it had adequately met

its statutory outage objectives, dealt with emergent issues and demonstrated the safety of Reactor 1 for the next operational period.

On 18th November 2014 The Hartlepool Station Director wrote to ONR requesting its Consent to start-up Reactor 11. In this letter, the Director confirms that following completion of the outstanding work, (as controlled by the Operational Safety Review Committee) (OSRC), Reactor 1 will be safe to return to service.

The request letter1 was supported by a series of appendices detailing the outcome of inspections and PSSR requirements to date, and a memorandum stating the internal regulator, Independent Nuclear Assurance’s (INA) position on Reactor 1 2014 return to service.

The licensee’s internal regulatory process requires that INA provide its independent support to the application for reactor start-up. INA demonstrates its assurance by undertaking a series of surveillance activities both before and during the outage, specified in the Concurrence Part A5. This includes inspections, oversight of management processes and document reviews. A summary of INA activities undertaken during the Reactor 1 shutdown are presented in their start-up memorandum6. On completion of these activities, INA issues a report, ‘Concurrence Part B’, which presents the findings of their work and includes a statement supporting the start-up.

INA will submit its Concurrence Part B report to Hartlepool’s OSRC as part of the licensee’s consideration as to whether Reactor 1 is fit for return to service, in accordance with NGL’s company arrangements7. ONR accept that the report will only be issued if INA considers that there are no issues remaining with respect to the requirements of Concurrence Part A. Therefore, I am content with NGL’s proposal to defer issue of the Concurrence Part B after ONR grants Consent under LC 30(3) and that this constitutes an additional internal hold-point to returning Reactor 1 to service.

2.2.2 ONR’s intervention management process

ONR business management process within the Civil Nuclear Reactor Programme (CNRP) requires that a task sheet is produced for significant regulatory activities. The task sheet provides the basis for the proposed intervention, the anticipated outcomes, duration, prioritisation, lists specialisms assigned to the project and the intervention strategy.

As nominated site inspector for Hartlepool, I produced task sheet TS-2068 for Reactor 1 periodic shutdown. The task sheet was endorsed by the CNRP sub-programme management board. The anticipated outcomes of the project included the licensee delivering:

An outage that is safely managed and appropriately regulated. Assurance that the outage has met the requirements of LC28 and delivers

an agreed programme of safety improvements. Closeout of significant issues raised by interventions to the satisfaction of

the Inspector raising the issue, prior to the conclusion of the outage (wherever possible, or an acceptable plan is made to address the issue beyond the outage).

Safe delivery of the required work activities, enabling ONR to produce a PAR that considers NGL’s request to start up Reactor 1 on completion of the shutdown.

The following specialisms were assigned to the project:

Mechanical systems Management systems Electrical systems Control and Instrumentation systems, including reactor protection systems Civil engineering systems Structural integrity Graphite core Site inspection Ionising Radiation Regulations Radioactive Waste

ONR’s process for delivering a permissioning project requires preparation of a PAR for the permissioning decision by the Delegated Authority. The PAR is informed by the intervention findings of the inspectors assigned to the project to allow the Delegated Authority to consider issuing a Consent for the restart of the reactor.

As nominated site inspector I have maintained a spreadsheet9 to monitor progress and status of all restart and non-restart related actions.

3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST

I have considered NGL’s request for ONR’s Consent to start-up Hartlepool Reactor 1 on completion of its periodic shutdown in my capacity as nominated site inspector. I have followed ONR procedures for delivering a permissioning project, as detailed in HOW210. To support my work I have utilised the services of the ONR specialist inspectors assigned to this project by the ONR Civil Nuclear Reactor Programme management team. I have taken note of the outage-associated work undertaken by NGL’s internal regulator, INA.

I have consulted with the Environment Agency (EA) who have no objections to ONR giving Consent to start-up Reactor 111.

I summarise below the inspection and assessment work undertaken by specialist inspectors and myself as the nominated site inspector during the course of the periodic shutdown.

3.1 Management Systems

In my capacity as the nominated site inspector I inspected the outage management and quality systems through targeted inspection and a joint inspection with an ONR quality management specialist inspector.

My site visit was reported in2 as follows:

The R1 pre-outage milestone plan13 (POMP) had mapped good progress through the outages preparatory phases.

A significant area of concern was the unplanned outage of Reactor 2 and the impact it may have had on the Reactor 1 outage. During the outage around 1600 staff were on site which had the potential to over-stretch the stations supervisory capability and imposed a significant workload on the staff. Some contractors reported an unusually high proportion of personnel with no previous nuclear experience. I noted12 that there were arrangements to ensure that some of the less experienced workers were adequately managed.

Following an event where a boiler closure unit ESR bolt was slackened off whilst the reactor (2) was still pressurised (INF 2014/352) the station recognised a need to move to a single co-ordinating organisation for both reactors (on 3 shifts). I followed up this event and concurred with the station’s own findings.

The specialist inspector carried out a planned compliance inspection against Licence Condition 17 (LC17) ‘Management Systems’. This focused on a review of the adequacy of the outage quality management oversight arrangements for a range of activities including: audit & surveillance; supply chain and contract management; management of work closure and the management of a portfolio project during the outage. The specialist inspector produced an intervention record14 and assessment report15 for his inspection. The salient points of his work are presented below:

He discussed the outage surveillance programme with the Station Quality Engineer (SQE). He was satisfied that the programme was being well managed and supported by both the SQE, resources from other stations and the Contract Partners and that based on the examples reviewed that the surveillances were of a good standard.

He discussed work management arrangements for the outage with the outage manager and was satisfied that there was an adequate process for closing work packages and returning plant and systems back into service.

He discussed supply chain management arrangements for the outage with the supply chain manager and found these to be in accordance with relevant procedures.

He examined the contract management arrangements for one of the main contract partners and found these to be adequate and in accordance with procedural requirements. He visited the main contract partner’s site office and discussed their arrangements for managing work and found these to be satisfactory. He sampled a design, manufacture, and install project and found the project to be well managed with appropriate records and good overall quality management arrangements.

He discussed Field Supervision arrangements with the maintenance manager and found these to be mature and well managed with the role understood and implemented in accordance with NGL fleet procedural requirements.

The specialist inspector was satisfied from the activities he sampled that the LC17

Management Systems quality management oversight arrangements for the outage of Hartlepool Reactor 1 were good and consistent with the relevant procedures. No actions were raised. He recommended based on the areas examined during this intervention, that the LC17 management systems arrangements for the outage of Hartlepool Reactor 1 were sufficient to support a return to service.

3.2 Civil Engineering

NGL has an appointed examiner (APEX) to oversee the maintenance and inspection activities related to the reactor pre-stressed concrete pressure vessel (PCPV) and associated systems, as identified within the OID. On completion of the maintenance and inspection work, the APEX provides a start-up statement, which identifies all of the inspections undertaken, what was revealed and any remediation that was required. The APEX provides a justification for returning the reactor to service.

An ONR civil engineering specialist inspector visited Hartlepool prior to the shutdown and met with the APEX, reactor systems civil engineer and the reactor systems pressure vessels cooling system engineer. The purpose of her visit was to discuss and review a sample of the statutory surveillances, inspections and tests undertaken by NGL on the PCPV of Reactor 1.

The inspection findings are presented in the ONR specialist inspector’s intervention report16. She has also produced an assessment report17 of the APEX start-up statement18 (SUS). The scope of the assessment included findings from inspections and tests of certain key safety related components of the reactor pressure vessel including: tendon loads, tendon anchorages, tendon corrosion, concrete surfaces, foundation tilt and settlements, vibrating wire strain gauges, vessel concrete liner temperatures, reactor coolant leakage, top cap deflections, tendon tensile strength, pressure vessel cooling water (PVCW) leakage and Boiler Closure Units (BCUs).

The statement provides a progress statement on each of the statutory surveillances, inspections and tests, and is presented by NGL in support of their request for permission to return the reactor to service following the Statutory Outage. The ONR specialist noted the surveillances, inspections and tests had been compared with the requirements set out in British Standard BS4975 (specification for pre-stressed concrete pressure vessels for nuclear engineering) and exceed those requirements.

She confirmed that the SUS adequately covered NGL’s progress with the statutory surveillances, inspections and tests on the pre-stressed concrete pressure vessel as described in the Branch Instructions that include the requirements of the Maintenance Schedule.

A full and detailed report of the statutory surveillances, inspections and tests will be presented in the Statutory Examination Report by NGL within 28 days of return to service.

The ONR specialist made no findings that would prevent a return to service, however, a number of recommendations were made.

From the results of the surveillances, inspections and tests as reported in the documentation provided, the ONR specialist was content to support the return to service of Hartlepool Reactor 1 pre-stressed concrete pressure vessel for a period of 3 years. This judgement is based on her assessment of the data and information presented in the documents provided, and an acceptance of the judgements made by the Appointed Examiner.

A total of 259 tendon strands were removed as part of the outage. This greatly exceeds the minimum required by the maintenance schedule (30 strands). By doing this the cumulative age of wetted tendons has been significantly reduced.

The start-up statement was issued on time and the quality and detail on the report is good, with some areas where the Maintenance Schedule requirements have been exceeded. There are some areas for improvement, mainly the reliability of the Vibrating Wire Strain Gauges and the limited inspection of the inner bearing pads (supporting the PCPV). Nevertheless, the proactive pressure vessel cooling system leak management and the extent of tendon surveillance should be recognised.

The ONR civil engineering inspector concluded that she is satisfied with the claims, arguments and evidence laid down within the licensee’s safety case, and she judges that the PCPV is in an adequate condition for return to service

for the next three years of operation, subject to normal in-service surveillance.

20. Although the ONR civil engineering inspector made a number of recommendations to be followed up, these recommendations are not issues that would prevent re-start of the reactor.

3.3 Radiation Protection

An ONR radiation protection specialist inspector undertook a planned readiness inspection to establish whether statutory outage work programme on Reactor 1 was being conducted in compliance with the Ionising Radiations Regulations 1999 (IRR99). He produced an assessment report to detail his inspection and assessment findings19.

He assessed the following key areas of performance requirement:

Contamination control arrangements at points of entry and egress from controlled areas;

Management of temporary controlled areas; Radiological safety training for contractors and other staff involved in the

outage; Personal contamination control performance, and Radiation measurement equipment performance management.

The key findings are summarised below:

During the outage, the ONR specialist inspector observed improvements had been made by the licensee in the use of temporary C2 Contamination Controlled Areas which had been the subject of compliance comment by ONR in 2013.

An outcome of the decision by the licensee in August 2014 to conduct an unplanned outage on Reactor 2 which coincided with the statutory outage on Reactor 1 was that additional health physics personnel had been required at short notice. The need for additional health physics surveyors to cover the boiler spines investigations on Reactor 2 had initially proven difficult to meet resulting in the need for subcontracted surveyors: The ONR specialist inspector indicated the need for this issue to be kept under review but accepted that the Head of Radiological Protection was maintaining a baseline of five accredited health physicists and that no problems in providing health physics cover during the outages had, thus far, been experienced or were foreseen. He reviewed the training and competence vetting arrangements put in place by the licensee for contractors working on the site: these were found to be satisfactory.

From a radiological protection standpoint, the ONR specialist inspector was content

with the licensee’s current state of compliance.

3.4 Mechanical Engineering

An ONR mechanical specialist inspector conducted a compliance inspection to confirm the adequacy of mechanical engineering related activities conducted by the licensee to comply with the requirements of Licence Condition 28, examination, inspection, maintenance and testing against a sample of nuclear safety significant reactor components. He has produced an intervention record to detail his inspection and assessment findings20.

The intervention consisted of on-site meetings and a plant inspection with relevant staff from NGL to determine the adequacy of the work being undertaken on Reactor 1 in complying with the requirements of Licence Condition 28. The activities examined were selected due to their nuclear safety significance and included:

Maintenance of Gas Circulators (GCs) Maintenance of Control Rod Assemblies (CRAs); Control rod drop tests; Maintenance of Gas Safety Relief Valves;

The inspection was supported by visits to the following areas:

Gas Circulator (active) maintenance facility North (GCMF); Control Rod Mechanism Maintenance Room (CRMMR).

From the sample of Control Rod Assembly maintenance reviewed, he considered that the Examination, Inspection, Maintenance and Testing (EIMT) arrangements are adequate, the performance against the schedule is being achieved and the records supporting the tasks confirmed compliance with arrangements and completion of the tasks consistent with the expectations of LC28.

From the sample of Gas Circulator maintenance reviewed, he considered that the EIMT arrangements are adequate, the performance against the schedule is being achieved and the records supporting the tasks confirmed compliance with arrangements and completion of the tasks consistent with the expectations of LC28.

From the sample of gas safety relief valve maintenance reviewed, he considered that the EIMT arrangements are consistent with previous undertakings, performance against the schedule is being achieved and the records supporting the tasks confirm compliance with arrangements and completion of the tasks consistent with written instructions.

Inspection of CRMMR confirmed an adequate standard of housekeeping was being achieved with suitable foreign material exclusion (FME) arrangements in place. Minor improvements were identified and captured on a condition report for NGL review. Equipment obsolescence was proving a challenge in maintaining equipment capability, but did this not directly affect nuclear safety.

Inspection of the GCMF confirmed an adequate standard of housekeeping was being achieved, consistent with the workshop at near capacity with GC’s and the limited space available. FME controls were evident and no significant challenges uncovered with respect to loose components or items left outside of tool control arrangements.

He judged that the LC28 arrangements in place are adequate and are being adequately implemented.

From a Mechanical Engineering perspective, he found no significant areas of concern relating to nuclear safety and supported Consent for return to service of Hartlepool Reactor 1 upon completion of the outage commitments identified in the OID.

3.5 Electrical Systems

The ONR specialist electrical inspectors met with the station’s electrical engineering management and support staff to inspect electrical engineering aspects of Reactor 1 statutory outage related LC 28 and LC 22 modifications to plant. This was centred mainly on the work described in the station’s Outage

Intentions Document4 (OID) and any emergent work found necessary during the outage. An electrical plant walk down was conducted and further details are given below. They have produced an intervention record21 to detail his inspection and assessment findings.

The specialist inspectors established that the electrical work was broadly on schedule, but that some maintenance activities had needed to be re-arranged to suit other programme activities. They reviewed the electrical work activities documentation to confirm this to be the adequate. At the time of the inspection, adequate progress was being made with the switchboard maintenance.

The specialist inspectors examined testing of the 275 kV breaker capacitors of Reactor 1 which had given test results outside the range expected by the station. Advice was sought from a recognised independent technical authority (Doble) and from the Corporate Technical Centre at East Kilbride and the station was given assurance that the equipment was fit for continued service. The specialist Inspectors were shown correspondence confirming this position.

The specialist inspectors reviewed the following Engineering Change Proposals and judged them to be adequate:

Replacement of two of the station’s 275 kV through wall bushings. A Multi Gas Analyser being fitted to the Reactor 1 Generator Transformer

tap changer selector chamber. A 23 kV undervoltage protection modification, to improve the resilience of

11 kV supplies in the event of generator excitation system faults. At the time of the inspection the ONR Specialist Inspectors were given assurances

that the electrical system modifications and maintenance planned in the OID would be completed before the end of the Reactor 1 outage and that it was not planned to defer any safety significant work. This position has subsequently been confirmed1.

The ONR Specialist Inspectors accompanied by station personnel, conducted a plant walk down. No matters of significant safety concern were observed during the plant inspection and minor concerns were addressed by the station upon identification.

The ONR Specialist Inspectors reviewed NGL’s management of ageing and obsolescence of systems and components within the plant’s electrical system. In the context of the work planned for the outage, this was judged to be acceptable.

The overall outcome from the inspection is that ONR Specialist Inspectors did not identify any electrical issues that should affect the return to service of Reactor 1, on completion of the planned and emergent work.

3.6 Structural Integrity

The ONR structural integrity specialist inspector and the structural group lead undertook on-site meetings and plant inspections to determine the adequacy of the work being undertaken on R1 in complying with the requirements of LC28. They concentrated their inspections on items judged important to Nuclear Safety including the following:

in service inspection of reactor internal components; seawater and essential cooling water systems; feed and steam system pipework weld inspections; feed and steam system supports (hangers) inspections, and

flow accelerated corrosion inspections. They have produced an intervention record22 to detail their inspection and an

assessment report23.

The assessment report has considered the adequacy of the structural integrity inspection results of welds, pipe work, components and metallic reactor internal structures completed during the Reactor 1 2014 periodic shutdown.

As previously stated, this report does not consider the integrity of the boiler tubes or spines. A separate PAR37 and an agreement (licence instrument number 549) in accordance with the licensee’s arrangements under licence condition 22 has been issued which provides ONR’s formal agreement to a defined operating regime for the reactors following the discovery of a defect in the spine at Hartlepool’s sister station (Heysham 1).

The structural specialists’ assessment was being conducted in three stages to include activities before the outage and during the outage, including a site visit.

This included a review of the OID and Inspections Specification Document24 (ISD) and discussions with the licensee to understand the proposed scope of work for the Reactor 1 outage in accordance with LC28 (examination, maintenance, inspection and testing). During the outage they visited site to review the progress of the inspections across a range of plant items and to discuss the results with the responsible engineers and competent persons. Following the site visit, they have been monitoring the minutes from the weekly outage assessment panel meetings to ensure any emergent issues and works in progress identified during the inspection were managed adequately.

The reactor internal steel components inspections have been completed to scope and the licensee has not identified any issues that could affect the return to service of Hartlepool Reactor 1. As part of the ONR assessment, ONR specialists have sampled the inspection process and viewed two examples of the reactor internal steel inspection footage. Furthermore, they sampled non-conformance reports and verified that they had been sentenced accordingly.

The ONR specialists verified that steam and boiler feed pipe hanger and flow assisted corrosion inspections had been completed as detailed within the ISD, and changes or modifications to scope had been recorded in the outage management database.

At the time of the assessment, the Pressure Systems Safety Regulations (PSSR) inspections were on-going. To demonstrate satisfactory completion of the PSSR inspections, the licensee’s site nominated PSSR competent person submitted a statement supporting return to service as part of the return to service Engineering Change (EC) submission.

Steam and boiler feed pipework weld inspections were in the final stages of completion. The ONR specialists sampled several inspections and are content that the results of the inspections have been sentenced appropriately, following due process through consultation with materials specialists and site safety representatives.

From the inspections ONR specialists have sampled, the licensee has demonstrated adequate procedures to ensure that any structural integrity issues identified on nuclear safety significant plant will be appropriately addressed, so as not to affect the safe return to service of Hartlepool Reactor 1.

ONR’s structural integrity specialists concluded by recommending that ONR should issue the Licence Instrument to grant Consent for start-up of Reactor 1 at Hartlepool Nuclear Power Station, following the 2014 periodic shut down.

This recommendation is contingent on the demonstration of satisfactory completion of the inspections sampled as part of this assessment and closure of the necessary Outage Assessment Panel (OAP) actions. This should be demonstrated by confirmation that the return to service EC has been produced, verified and approved through Independent Nuclear Safety Assessment (INSA) by provision of the appropriate certification, supporting return to service with no caveats identified. The licensee should provide ONR with an approved copy of the return to service EC and the 28 day report, when available.

To demonstrate satisfactory completion of the Pressure Systems Safety Regulations (PSSR) inspections, it is recommended that statements from the Competent Persons25 should be submitted as part of the application for Consent to return to service.

3.7 Graphite Core

During the statutory outage, NGL has undertaken inspections, measurements and taken samples of the reactor graphite core, as required by the graphite core safety cases. An ONR specialist graphite inspector visited Hartlepool to inspect how the licensee was performing the various periodic shutdown related activities necessary to ensure the integrity of the graphite core. The findings of his inspection are given in his intervention record26 and there are further developed in his assessment report27.

The ONR graphite specialist inspector undertook a number of activities before and during the shutdown, including visiting Hartlepool to inspect samples of the work that the licensee was carrying out under Licence Condition 28. The work included visual remote inspection and dimensional measurements of twenty fuel channels and one control rod channel, eddy current examination of six fuel channels and trepanning of thirty six graphite specimens from the core for subsequent examination and testing. He also considered the licensee’s safety documentation and how the findings of the inspections and examinations are considered and sentenced. The assessment complies with Graphite Reactor Cores Technical Assessment28.

The licensee set out the inspection and examination requirements for Reactor 1 graphite core prior to the start of the shutdown in the OID4. They achieved all their targets during the shutdown. The licensee used the Graphite Assessment Panel (GAP) to consider and sentence the findings of the core inspections and examinations. The panel concluded that the observations were within the allowable bounds of the safety case and no additional inspections were required to support return to service. A member of the licensee’s Independent Nuclear Assurance function sat on the panel. The ONR specialist observed the GAP meeting where the inspection and examination findings were considered and sentenced. He judged that the panel had adequately discharged its duty.

The ONR specialist assessed the findings of the Hartlepool Reactor 1 graphite core inspections that were undertaken by the licensee during the 2014 periodic shutdown. He judged that the licensee has demonstrated that that Reactor 1 core is in an adequate condition to be returned to service until its next periodic shutdown.

From the activities he sampled relating to the integrity of the graphite core, the ONR graphite specialist identified no issue that would prevent ONR granting Consent to start-up Hartlepool Reactor 1.

3.8 Control and Instrumentation (C&I) Systems

An ONR specialist control and instrumentation inspector carried out an inspection and assessment of Reactor 1 outage related C&I activities as part of the programme of outage related safety inspections. The specialist inspector prepared an intervention record29 and an assessment report30.

He included a review of the OID4 and inspection of outage related maintenance activities, including any emergent work. This has covered reactor safety circuits and other C&I systems and equipment that are important to nuclear safety to Reactor 1. In addition, he reviewed progress of a number of relevant plant modifications that were implemented during this outage. The main focus was to verify that required activities have been carried out in relation to C&I systems and equipment important to nuclear safety at Reactor 1 in order to confirm that it remains fit for its intended purpose.

The most safety significant action30 related to the reliability of replacement feed flow instrumentation. The newly installed instruments were found to be inaccurate (INF1 2014/291). The ONR specialist has assessed38 and concurs with NGL’s decision to return the plant to its previous state and was content with the arguments presented. Therefore, this action was closed.

Interacting with the licensee’s project and C&I engineering staff he confirmed that work was being undertaken in accordance with the station work management system, recorded appropriately in station documents and confirmed as complete by suitably qualified and experienced persons.

His assessment has revealed no matters of significant safety concern that are not already being adequately addressed. The station has confirmed that the remaining outage work will be managed under their established outage arrangements.

In respect of the maintenance and modification work undertaken on C&I systems and equipment important to nuclear safety as part of the 2014 periodic shutdown, he identified no matters that should prevent ONR from granting Consent for R1 to return to normal operational service.

3.9 Site Inspector oversight

As nominated site inspector, I undertook regulatory oversight of Hartlepool’s overall outage programme, and coordinated ONR’s specialist inspections during the course of the outage.

I produced a task sheet8 defining the objectives and resource plan for ONR’s assessment of the outage.

I received the OID4 on 7th February 2014 and sought comments from the operating reactor delivery management group leads. NGL was requested to provide further information, the statutory outage weld intentions document and reactor internal inspections specification31.

I attended the outage intent meeting12 with the structural integrity lead inspector4. The station tabled their pre-outage milestone plan13 (POMP) and level 1 plan32. The POMP was reviewed regularly to monitor progress of the

preparatory work, which indicated the quality controls that were in place. The milestones indicated that the preparatory and assurance tasks were being promptly executed.

I presented a programme of ONR inspections to NGL prior to commencement of the outage33. I shared this inspection programme with the stations internal regulator (INA) who furnished a copy of their Concurrence Part A5 which defined the programme of inspections they intended for the outage to assure themselves that the conduct of the outage was satisfactory. I judge the scope to be appropriate and used it to inform ONR’s inspection programme. The results of the INA inspections will be presented in their Concurrence Part B.

I can confirm that the programme of inspection is complete and all the ONR specialists have written intervention records and, where appropriate, assessment reports.

3.10 Events

Midway through the outage I reviewed the rapid trending review with the internal regulators. I also reviewed the operational feedback at the start up meeting. In summary I judged that the event reporting was sufficient and reflected favourably on the conduct of the outage. In general the level of reporting indicated an average outage despite the much increased workload and up to 1600 staff on site.

Since the start up meeting a number of additional events have been formally reported to ONR through ONR’s “INF1” reporting process.

Even considering the unprecedented circumstances there was a high INF1 reporting level. Control of work was a reoccurring theme in these events, both local to the work (working on wrong equipment) and procedural errors.

I consider NGL’s initial responses to these events to be appropriate. However, the events will be considered as part of the post outage review meeting.

INF1 2014/434 reports a hydran oil leak on a badly fitted pipe connection on TG1. ONR will inspect this event in light of a similar return to service event in 2013 where a hydran oil pipe (TG2) was lagged into hot steam pipework causing a fire in the turbine hall. In the start-up meeting3 I reminded the station of the formal advice issued34, 35 from ONR regarding the fire events and pressure systems regulations with the critical return to service phase yet to come.

To emphasise the importance ONR put on a hazard free return to service the ONR Fire Safety Inspector undertook a Regulatory Reform (Fire Safety) Order 2005 Inspection39 at Hartlepool immediately preceding the outage. NGL40 were requested to consider additional measures for return to service of turbine 1. This was discussed further at an additional meeting41 at Hartlepool. Finally, Hartlepool described42 the additional fire safety measures put in place to return Reactor 1 and Turbine 1 into service. They included thermal imaging cameras, enhanced inspection of inaccessible areas and dedicated return to service fire walkdowns. The ONR specialist inspectors found the arrangements suitable43.

During the outage there has been one RIDDOR reportable event:

RIDDOR, 2/11/14 – Fork lift truck ran over a banksman’s foot HSE local office and ONR internal conventional safety team decided the event was

outside of their investigation criteria36.

3.11 Start-up meeting

The ONR operating reactor delivery lead (ONR DL) and nominated site inspector attended the 2014 Hartlepool Reactor 1 start-up meeting1. The start-up meeting was held against a standing agenda. The meeting was chaired by the TSSM and attended by the Station Director, the management team and engineering leads. A pre-meeting with engineering leads had discussed the details of the outage.

The Station Director gave the background to the outage and the decision to shut down both Hartlepool reactors following the discovery of an anomaly in a boiler spine in Heysham 1 Reactor 1. The late emergence of this work had the potential to disrupt the planned outage. However he felt the station had coped well with the unplanned work to complete the work on both reactors. ONR concurred with this view.

NGL stated that all safety related work was still planned to be completed. This included all work agreed in the OID and all maintenance scheduled activities and statutory examinations. The boiler tube safety case improvements had been progressed. The chloride ingress protection was now complete and the reactor vessel flooding detection system will be complete by the end of the year. The results of the examinations received so far had been sentenced and did not pose a threat to return to service.

The ONR DL commented on the positive attitude and ownership demonstrated by the staff he met on the tour. However, the presence of combustible material incorrectly stored in the turbine hall was surprising given the emphasis placed by the station on fire hazards. ONR emphasised the return to service phase of the outage remained and this would be a significant indicator of the success of the outage. ONR stated that all of the planned inspections by specialists were complete and there were no issues identified which might affect ONR’s Consent to start up. The associated assessment reports were well advanced and, pending receipt of the final documentation, there were no start up issues extant.

I judged that the start-up meeting achieved its objectives. NGL had gone on record stating the outage was being completed to plan and there are no anomalous results. ONR specialists had completed their inspections and report no issues which would prevent start up.

4 SUMMARY OF MATTERS ARISING FROM ONR’S WORK

I have considered the licensee’s request to ONR for a Consent under LC 30(3) to start-up Hartlepool Reactor 1 on completion of its periodic shutdown. I have followed ONR procedures10 for delivering a permissioning project, as detailed in HOW2. To inform my work I have taken note of the statements associated with safety contained in the request letter1, the findings of the outage associated work undertaken NGL’s internal regulator, INA, and the findings and opinions of ONR specialist inspectors.

Each ONR specialist inspector has produced an intervention record and an assessment report (where appropriate) that presents the inspection findings, inspector’s opinions, judgements and recommendations.

The structural integrity specialist inspector recommends that to demonstrate satisfactory completion of the weld inspection programme and completion of the work of the Outage Assessment Panel, and satisfactory completion of the boiler inspection programme and completion of the work of the Boiler Assessment Panel, the Independent Nuclear Safety Assessment (INSA) statement for the Return to Service Engineering Change (EC 349380/000 Version 02) should be submitted as part of the application for Consent to return to service. I confirm receipt of the INSA1 approved EC 349380/000 Version 02 on 18th November 2014.

The structural integrity specialist inspector recommends that to demonstrate satisfactory completion of the Pressure Systems Safety Regulations (PSSR) inspections, he recommends that statements from the Competent Persons (Bureau Veritas) should be submitted as part of the application for Consent to return to service. The specialist ONR civil engineering inspector has confirmed receipt and has assessed the APEX start up statement1. I also confirm subsequent receipt of the Bureau1 Veritas letter dated 13th November 2014 that notes the required statutory inspections of pressure plant associated with the Reactor 1 reactor statutory outage have been carried out in accordance with the relevant legislation. I am content with Hartlepool’s proposal to report outcome of all outstanding PSSR inspections as part of its post-restart 28-day report.

The Graphite specialist inspector recommends that the site inspector should confirm that the Graphite Return to Service EC353749 is complete and has been subject to an INSA before reaching a decision as to whether to recommend that consent to return to service is granted. I confirm receipt of the INSA for approved EC 353749 on 18th November 2014.

Other recommendations made by specialist inspectors are sufficiently captured as new regulatory issues, none of which have been deemed sufficiently significant for ONR to withhold Consent to start-up Reactor 1.

Each specialist inspector assessment report contains a statement supporting issuing Consent to start-up Reactor 1.

I have consulted the Environment Agency to establish if they had any specific objections that would prevent ONR from issuing Licence Instrument 548, Consent to start-up Hartlepool Reactor 1. The Environment Agency11 has confirmed they do not object to ONR issuing Consent.

Two planned modifications have been postponed. Installation of new feed flow instrumentation was reversed when a common mode of failure was revealed in the new devices. This was agreed by the ONR inspector38. Installation of a cowl to divert cooling air over the hot box dome was curtailed after installation difficulties were experienced. Although the hot box dome temperatures are a safety issue at Heysham 1 and Hartlepool, Hartlepool Reactor 1 is currently well below the technical specification limit and this limit does not permit operation with excessive dome temperatures.

In summary, ONR have scrutinised the scope of the outage and found it to be appropriate. Where the ONR specialist inspectors have inspected the conduct of the outage they have found the work planned was in progress and inspection results either within the acceptance criteria or correctly sentenced. Project work where sampled was being adequately implemented. Our inspection of the NGL quality management system for the outage was found to be a good standard. The Station Director1 has written to ONR requesting ONR issue a Consent to start up Reactor 1. This

letter lists the extant work and certifies completion of all maintenance schedule activities before return to service.

5 CONCLUSIONS

The Hartlepool Reactor 1 periodic shutdown has been undertaken in accordance with the requirements of the work scope outlined within Hartlepool’s OID and start-up report.

The licensee has followed their arrangements in undertaking the outage, culminating in the Hartlepool Station Director writing1 to ONR requesting Consent to start-up Reactor 1. In his letter, the Station Director confirms that following completion of outstanding work, Reactor 1 will be safe to return to service and operate for a further period. As required by the station’s arrangements he will personally review the OSRC recommendation prior to sanctioning the commencement of start-up and will perform a walk-down prior to start-up to satisfy himself that Reactor 1 is safe to return to service.

INA will submit its Concurrence Part B report to Hartlepool’s OSRC as part of the Station’s consideration as to whether Reactor 1 is fit for return to service, in accordance with NGL’s company arrangements. The report will only be issued if INA considers that there are no issues remaining with respect to the requirements of Concurrence Part A. Therefore, I am content with NGL’s proposal to defer issue of the Concurrence Part B after ONR grants Consent under LC 30(3) and that this constitutes an additional internal hold-point to returning Reactor 1 to service.

ONR inspectors have sampled the LC28 EMITs and LC22 modification activities throughout the shutdown and judged them to be adequate, and all support issuing Consent to start-up Reactor 1.

I have prepared a Consent, Licence Instrument 548, for review in conjunction with this PAR. The licence instrument is one of the standard formats given within ONR procedures and does not require review by the Solicitors Office.

I judge that, based on the evidence presented within this report, the outage activities on Reactor 1 have been satisfactorily completed and there is nothing to prevent ONR granting Consent to start-up Hartlepool Reactor 1.

6 RECOMMENDATIONS

I recommend that the Superintending Inspector should:

Sign this Project Assessment Report to confirm acceptance for the ONR technical and regulatory arguments that support issuing Licence Instrument 548.

Sign this Project Assessment Report approving its release for publication, after redaction where appropriate.

I further recommend that the Deputy Chief Inspector signs Licence Instrument 548, which grants Consent under Licence Condition 30 (3) to start-up Hartlepool Reactor 1.

7 REFERENCES

1 TRIM 2014/427710 Application for Consent to Start-Up Reactor 1 under Licence Condition 30(3) NSL HRA 51051R 18th November 2014.

Enc:

Appendix 1 – Start-Up Meeting Minutes

Appendix 2 – MS Exceptions List

Appendix 3 – APEX start-up report

Appendix 4 – EC 349380 - Safety Case for Returning Reactor 1 To Service With Respect to NDT Inspections and Boiler Closure Unit Inspections Undertaken During The 2014 Statutory Outage

Appendix 5 – Penetrations Letters

Appendix 6 – PSSR Letter

Appendix 7 – INSA Certificate for EC353749 Justification for the Return to Service of Hartlepool Reactor 1 following the Graphite Core Inspections at the 2014 Periodic Shutdown

Appendix 8 – Outstanding Modifications list

Appendix 9 - INA Statement

2 TRIM 2014/365450 NGL - CNRP - Intervention Record - 14-157 - Hartlepool Intervention Plan - 23 to 25 September 2014

3 TRIM 2014/394702 Reactor 1 2014 Statutory Outage - Start-up meeting briefs – October 2014.

4 TRIM 2014/263973 Outage Intentions Document for Unit 1 2014 Statutory Outage for Hartlepool June 2014

5 TRIM 2014/375541. Independent Nuclear Assurance. Concurrence Part A. July 2014

6 TRIM 421590 CONSENT Licence Instrument 548. November 2014

7. TRIM 2014/358565. SRD/PROC/009 - NGL concurrence part B company arrangements

8. TRIM 2014/222438. Intervention Task Sheet. TS206 rev0. TS206 - Hartlepool R1 Statutory Outage 12/6/2014

9 TRIM 2014/0426357. Hartlepool 2014 Reactor 1 Statutory Outage. Issues Tracking

10. NS-INSP-GD-030 Revision 2 LC30 PERIODIC SHUTDOWN Nuclear Safety Technical Inspection Guide December 2012

11. TRIM 2014/0419716. Environment Agency Comments on Reactor 1 restart consent. R Arkle. 7 November 2014

12. TRIM 2014/0426206. Minutes. Hartlepool Outage Intents Meeting

13 TRIM 2014/375152 Pre Outage Milestone Plan 13 March 2013

14 TRIM 2014/340034 Intervention Record ONR-HAR-IR-14-145 Rev 0. Site inspection to support reactor outage intervention strategy focussing on LC17. 4 September 2014

15. TRIM 2014/348843 EDF NGL - Hartlepool - Assessment Report - 14-062 - Assessment of the Quality Management Systems Oversight Arrangements for the Hartlepool R1 Statutory Outage 2014 - 19 September 2014

16. TRIM 2014/359153 Intervention Record 1 ONR-HRA-IR-14-155. CNRP NGL Civil Engineering Inspection undertaken during the 2014 periodic shutdown of Hartlepool Reactor. October 2014.

17. TRIM 2014/340951 Hartlepool Assessment Report -14-059 rev0. Assessment of the Hartlepool Reactor 1 pre-stressed concrete pressure vessel. 30 October 2014.

18 Civil Engineering APEX start up statement is included in reference 1.

19. TRIM 2014/353127 ONR-Hartlepool - Intervention Record - 14-150 - Statutory Outage Ionising Radiations Regulations 1999 Compliance Inspection - 24 September 2014

20. TRIM 2014/323936 EDF NGL - Hartlepool - Intervention Report - ONR-HRA-IR-14-135 - Mechanical Engineering Inspection of Maintenance during Hartlepool Reactor 1 periodic shutdown - 27 August 2014 1/9/2014

21. TRIM 2014/352536 EDF NGL - CNRP - Intervention Record - 14-148 - Unit 1 Periodic Shutdown-Inspection of Electrical Related Aspects - 18 September 2014

22. TRIM 2014/359820 Hartlepool power station – Structural Integrity Compliance Inspection of Licence Condition 28 during reactor12014 periodic shutdown - 24 September 2014

23. TRIM 2014/362628 EDF NGL - Hartlepool - Assessment Report - 14 - 065 - Assessment of Structural Integrity Aspects for R1 Statutory Outage 2014 - November 2014

24. TRIM 2014/67375 Outage Intentions Document for Unit 1 2014 Statutory Outage for Hartlepool - weld inspections 17 February 2014

25. Statements from the Independent examiners (Bureau Veritas) is included under cover of reference 1.

26. TRIM 2014/332746 EDF NGL - CNRP - Intervention Record - 14-129 - Hartlepool Reactor 1 2014 periodic shutdown - Inspection of the structural integrity aspects of the graphite core inspection programme - 2 September 2014

27. TRIM 2014/349933 ONR-HRA-AR-14-047 Hartlepool Reactor 1 2014 periodic shutdown graphite core assessment 22 September 2014

28. HOW2 Graphite Core Technical Assessment Guide.

29. TRIM 2014/381831 ONR-CNRP-IR-14-158 rev0 – Reactor 12014 Statutory Outage: Control and Instrumentation Inspection- 8 October 2014.

30 TRIM 2014/393854 ONR-CNRP-AR-14-072 rev0 – EDF Energy Nuclear Generation Hartlepool Reactor 1 Outage Assessment. Control and Instrumentation 24 October 2014.

31. TRIM 2014/90804 CNRP NGL Hartlepool Reactor 1 weld 2014 statutory outage weld intentions document - January 2014

32. TRIM 2014/375154 Hartlepool Outage Milestone plan – 13 March 2014

33. TRIM 2014/375271. Outage Inspection Calendar. 14 July 2014

34. TRIM 2014/200772 NGL - Hartlepool - HRA 71248 R - ONR Reactive Fire Event Inspection - 23 May 2014.

35. TRIM 2013/461399 Compliance with Pressure System Safety Regulations – 13 December 2013.

36. TRIM 2014/417385 RIDDOR – Injury – Hartlepool - 11 November 2014

37. TRIM 2014/0399532 ONR-CNRP-PAR-14-015. A safety case for return to service of Heysham 1 Reactor 2, Hartlepool Reactor 1 and Reactor 2 at reduced temperature operation following the discovery of a defect on Heysham 1 Reactor 1 boiler spine 1D1 – November 2014.

38. TRIM 2014/415484 HRA 2014 R1 Outage (C&I specialist judgement on feed flow Y instrumentation backfit of old transducers). 27 October 2014.

39. TRIM 2014/303262. ONR-FIR-IR-14-112 rev 0. Hartlepool Power Station. Site inspection to ensure compliance with the Regulatory Reform (Fire Safety) Order 2005. 12 August 2014.

40. TRIM 2014/427739. Email ONR to NGL. Turbine Start-up – Fire Safety Considerations. 3 October 2014.

41. TRIM 2014/371025. ONR-COP-CR-14-170 Meeting to discuss the progress of the integrated fire system project. 8 October 2014.

42 TRIM 2014/376300. Email NGL to ONR. Re:Turbine start up – fire safety considerations. 10 October 2014.

43 TRIM 2014/376302. Email ONR to NGL. Re:Turbine start up – fire safety considerations. 13 October 2014.