Executive summary
Date(s) of inspection:
October 2025
Aim of inspection
ONR Licence Condition 28 (LC28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety. For any plant or process that is shut down for the purpose of enabling these activities, LC30 requires ONR to provide consent before said plant or process is started up again.
The aims of this inspection are:
- To provide regulatory confidence in the implementation of the Heysham 1 Reactor 2 Outage Intentions Document in relation to structural integrity LC28 compliance.
- To provide evidence to inform the ONR decision relating to the issue of a Licence Instrument for a Consent for return to service (RTS) of Reactor 2 at Heysham 1 on completion of the work undertaken during the outage.
- A specialist assessment of the safety case for return to service (RTS) will also be conducted in an assessment report AR-01817 and inform the overall recommendation to the Project Assessment Report (PAR).
Subject(s) of inspection
- LC 28 - Examination, inspection, maintenance and testing - Rating: AMBER
Key findings, inspector's opinions and reasons for judgement made
This was a two day inspection, timed to take place approximately half way through the planned 2025 statutory outage. I undertook a plant walk down during my visit, escorted by station staff. They were able to provide satisfactory explanations of both the operation of the systems and the inspection/maintenance of the systems planned or already performed during the statutory outage.
I was able to obtain sufficient evidence to demonstrate compliance with LC 28 and Pressure Systems Safety Regulations (PSSR) arrangements from a structural integrity perspective during the time of the inspection with one exception. I judged that the inspections carried out on the reheater inlet tubeplate were insufficient to satisfy the safety case requirement implemented to ensure that the risk created by the failure to meet R5 Vol 2/3 shakedown limits for the prevention of ratcheting remains ALARP. I have therefore raised a a regulatory issue (RI-12794) for the Licensee to address this shortfall. I will assess the response to this regulatory issue in my assessment report (AR-01817).
Conclusion
Based on the evidence sampled, I judged that there were areas for improvement that could be managed through regulatory advice. Examples include: a lack of progress with the steam and feed pipework hanger remedial work; and the Written Scheme of Examination (WSE) 1055 requiring an update to reflect the revised Safe Operating Limit (SOL). I am content that the dutyholder has adequate arrangements in place to update the WSE 1055 and I intend to follow up the lack of evidence for the hanger survey remedial work in my assessment report AR-01817.
There was also a significant level of uncertainty regarding the adequacy of the reheater inlet tubeplate for safe continued operation due to a failure to meet R5 Vol 2/3 shakedown limits for the prevention of ratcheting. I sampled the remote visual inspections and I judged that they would not be capable of detecting the effects of plastic strains in the tubeplate as (1) the quality of the video footage I sampled was insufficient; (2) the deformations expected at the surface are likely to be too small for visual inspections to detect and; (3) the surface of the plate may not be representative of the actual state of the material throughout the thickness of the plate. Overall, in my opinion, the inspection evidence provided during the inspection was insufficient to support return to service and I decided to raise a Level 3 regulatory issue (RI-12794) to capture this shortfall in LC 28 compliance. I will assess the adequacy of the response to this regulatory issue in my assessment report (AR-01817).
Based on the inspection findings and the guidance in ONR-INSP-GD-064, an inspection rating of AMBER was selected.