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1.
Introduction
In November 2015 a large supply fan (S3F2S) in the Shielded Facilities Ventilation
system at Wylfa Power Station was found to be rotating the wrong way. The fan is
designed to provide clean air to areas within the Reactor Equipment Building, but
was effectively extracting air from these areas (albeit at a much lower rate).
2.
Relevant permissions
The relevant permission is the radioactive substances permit for Wylfa Power Station,
EPR/GB3235DL/V002, which was issued to Magnox Ltd on 11 November 2015.
3.
The event was identified by Magnox Ltd staff during project work on heating
modifications in preparation for the transition to defueling. Staff who had repaired a
P2 defect on the heater bank between the dust filters on the intake & supply fan
S3F2S noticed, during leak checking when the plant was being returned to service
(the fan had been taken out of service to enable the repair) that warm air was
coming out of the inlet ducting.
Subsequent investigations revealed that fan S3F2S was turning the wrong way. This
is considered most likely to have been happening since June 2014, when the fan
was last returned to service following work on the motor (ie for a period of ~17
months).
The fan is located on the 108 level, in a room with one other (smaller) supply fan,
supply & extract ductwork, & the discharge monitoring equipment all part of the
Shielded Facilities Ventilation (SFV) system. Fan S3F2S is part of the supply side of
the SFV system. It is approx 5 in diameter & is rated at 28,000 cubic feet/minute.
The fan is fully enclosed within steel ducting, with no access for visual inspection.
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Initial monitoring of the inlet filters (which were downstream of the fan while it was
operating in reverse) using contamination probes did not indicate any detectable
contamination. Further monitoring was carried out within the ventilation system to
provide reassurance that there was no detectable activity, including monitoring of the
grilles. The dust filters were removed for further monitoring. They were assayed in
Wylfa supply fan extracting - November 2015
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the Rados bag monitor normally used to demonstrate that waste arising within the
Reactor Equipment Building is out of scope of the radioactive substances
regulations, & samples subjected to gamma spectrometry. The dust filters failed bag
monitoring, with 600-900 Bq of Co-60 present on each of the 12 filters.
Bag monitoring of the dust filters from the intake of the smaller adjacent fan (S3F1S,
which is located in the same room) also indicated the presence of low levels of Co60 activity. Levels on the S3F1S filters were around 25% of those found on the
S3F2S filters. This clearly indicates that some particulate radioactive material has
been discharged via the inlet supply for fan S3F2S.
4.
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Fan S3F2S was taken out of service in November 2013 because the motor was
tripping out. The fan was removed & sent off-site for a rewind. It was returned to
site in January 2014, but not refitted until April 2014 following a request from
Operations (who wanted the supply ventilation available for when Reactor 1 was
gassed up following an outage). The plant was handed over from Maintenance to
Operations in April for re-commissioning. The need for a rotational check is normally
specified in the safety document & handover certificate. However, return to service
was only attempted in late May 2014 & was not completed then because a separate
defect (damaged fuse holder) was then identified on the electrical system. This was
repaired in early June 2014.
Fan S3F2S was out of service for an extended period of time (almost 6 months).
The fact that the rotational check on the fan had not been completed when
Operations attempted to return to fan to service in late May 2014 was lost, & the
rotational check was not completed when the fan was returned to service in early
June 2014.
Magnox Ltd concluded that the root cause of the event was an inadequacy in the
handover procedures for plant. They also identified five contributory causes:
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5.
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This clearly covers the exhaust side of the SFV only. The HEPA filters on the
exhaust are part of the stations BAT arrangements for ensuring that discharges of
gaseous radioactive waste (particulate) to the environment are minimised. Required
availability of the SFV HEPA filters & discharge sampling equipment is specified in
SOI A11.
While the dust filters on the inlet to S3F2S provided some abatement of particulate
discharges (as evidenced by the fact that Co-60, an activation product which is
characteristic of the fuel route, was detected on the inlet filters), their efficiency is
much lower than HEPA filters & (because Co-60 was also detected on the dust filters
on the inlet to the adjacent fan) it is clear there has been some release via this route.
I consider that a discharge via fan S3F2S, in the supply side of the SFV
system, was a discharge via an unauthorised route. This therefore represents
a non-compliance with condition 3.1.1 of the permit.
Fan S3F2S supplies a number of areas with the REB, including fuel route (fuelling
machine & loading/unloading facilities for the dry store cells 2 & 3), active waste
facilities & the Active Effluent Treatment Plant.
Given the above, I do not consider that conditions 2.3.4(a) & 2.3.5 are relevant,
because the supply side of the SFV system is not identified as equipment provided to
meet the BAT conditions. In addition, condition 2.3.6 is not relevant because it
specifically relates to acceptance into service checks on (discharge) measuring
equipment.
Environmental impact
Monitoring of the dust filters indicates that very low levels of particulate activity were
present, typically 600-930 Bq Co-60 per filter accumulated over an 18 month period
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(total for 12 filters ~10.8 kBq). Discharges of radioactivity associated with particulate
matter via the permitted Shielded Facilities Vent outlet (outlet A7 in the RSR permit)
are typically 0.08-0.2 MBq/month (from Apr-Sep 2015 returns).
The levels of activity released are very low, & there is no indication from routine
monitoring data of any detectable increase of activity in the environment. The
environmental impact of the event is insignificant.
Adequacy of maintenance arrangements
The fan is subject to a 4 yearly overhaul of the motor, which was last completed in
October 2013. Rewinding of the motor can result in a phase change, & the
requirement for a rotational check to be completed when the fan is returned to service
following a motor rewind is captured in the safety document. Ensuring the correct plant
configuration is entirely dependent on this check being carried out when the fan is
being returned to service. Due to the size of the fan & its enclosed nature, there are no
routine surveillances in place to check the fan rotation or the direction/rate of air flow
within the SFV system.
The inlet dust filters should be changed every 2 years (but this is not a Maintenance
Schedule or Environmental Maintenance Schedule routine, so may not be rigorously
done). The differential pressure across the filters is checked routinely by operators.
Although there are no (nuclear) safety case claims on supply fan S3F2S, the fan is
designated as Plant Class 2. Magnox define four classes of plant (Plant Class 1-4)
by reference to the consequence of the plant failing. The consequences can be in
terms of radiological hazard, injury to persons, breach of licence condition or
environmental permit requirements, cost penalty, etc. Plant Class 1 is the highest
significance, & is anything related to maintaining the primary circuit gas pressure
boundary (eg boron dust injection system, gas circulators). Plant Class 2 is plant with a
major but less serious radiological risk (eg an isolatable section of the pressure circuit,
acid/caustic bulk tanks). The supply fan is therefore recognised to be a reasonably
significant plant item, & I find it somewhat surprising that it could be out of service for
almost 6 months without any questions being raised.
Adequacy of plant handover arrangements
Handover certificates (WYA/ED/F004) record any actions that are required to be
completed to return plant to service in the correct configuration when FIN,
Maintenance, Projects or Engineering hand the plant item back over to Operations.
The handover certificate requires a signature to confirm that the plant has been
inspected & considered fit for use, & another signature to confirm that any
outstanding work (including any pre-start or functional checks) has been completed.
They are not permanent records, & only have a retention period of one year (despite
maintenance intervals for some plant being longer than this, eg 4 years).
Magnox Ltd have not been able to establish whether a handover certificate was ever
created for the return to service of the supply fan.
If it was, it shouldnt have been signed off if the functional check(s) hadnt been
completed, so the plant (S3F2S) should not have been available for operational
service.
Wylfa supply fan extracting - November 2015
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If it wasnt, then clearly the handover arrangements are not robust or are not always
followed by Maintenance &/or Operations.
This raises a number of issues about the adequacy of the system in place for
tracking plant availability, which I will follow up at a future inspection.
I consider that there was an inadequacy in the management arrangements which
failed to ensure that the status of Plant Class 2 plant was adequately recorded
during handover for re-commissioning. This represents a non-compliance with
condition 1.1.1(a) of the RSR permit.
6.
Classification of event
CICS classification
As this event is associated with a relatively long-term plant condition, resulting in an
insignificant environmental impact, I have considered it as a non-compliance with the
RSR permit rather than as a pollution incident, & have not classified it under CICS.
Compliance Classification Scheme
The reference documents for determining the CCS classification of this event was
156_10_SD02 (version 3, issued 09/12/2014): CCS scoring guide for radioactive
substances facilities regulated under the Environmental Permitting Regulations
2010.
Having reviewed the guidance, I consider that this event represents noncompliances with the following conditions of permit number EPR/GB3235DL:
I will ask
to enter this event onto NRWs CCS database with two
Category 3 breaches as above.
7.
Enforcement response
The reference documents for determining the enforcement response to this event
were:
Operational Instruction 1430_10 Offence Response Options (issued 01/06/2015)
Policy 1429_10 Enforcement & Sanctions Statement (issued 18/12/2014)
Operational instruction 1428_10 Enforcement & Sanctions Guidance (issued
08/10/2015)
Wylfa supply fan extracting - November 2015
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The normal enforcement action for minor breaches with no environmental impact is
to provide advice & guidance or, where this will not achieve the necessary outcome,
to issue a warning.
Although the environmental impact of this event was insignificant, it was entirely
avoidable if the normal return to service procedures had been followed. I believe
that on this occasion the deficiencies in the management arrangements are
significant enough to justify a warning letter. I will recommend this action in a ROC
form to be considered by the NRW Area Enforcement Panel.
I consider that Magnoxs proposed corrective actions in particular, review of the
plant handover process should be sufficient to address the root cause of this event,
but I will follow up at a future site visit to ensure they can demonstrate that the new
process is sufficiently robust. I will place an action, via a RASCAR, for Magnox to
complete their corrective action programme as detailed in WYA/REP/10073.
Nuclear Regulator
Signed:
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