This report covers interventions in pursuit of the ONR integrated intervention strategy for Hunterston A, in particular to address regulatory issues identified as part of the inspection plan and carry out the planned Compliance inspections.
This report covers interventions at Hunterston A to address compliance inspections as follows:
The safety system, nuclear lifting and handling was judged adequate, although there are queries about the compliance of systems against certain Licence Conditions and the adequacy of the safety cases in certain areas with regard to compliance.
With regard to the LC 23 requirements, the site did not identify any limits and conditions necessary in the interests of safety for the ILW store Lifting system even thought there was the requirement on plant for interlocks and conditions to be met within the operating instructions. This drives the raising of the level 4 issue with regard to the safety case for this area.
With regard to LC 24 requirements, uncontrolled annotations were found on the point of work operating instructions. This further supports the findings of the June inspection of LC 24 and the level 4 issue raised on site as a result of the June inspection. This will be followed up under that work rather than raise a further issue as it directly related.
Only the Compliance Inspections and relevant follow-up meetings are included in this executive summary, as any system based inspections are covered in section 1.3 above and all other interventions were for information only
LC17:- the purpose of the intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC17. LC17 “Management system” requires licensees to establish and implement management systems which give due priority to safety. I consider the position to be adequate, although there are a number of areas for improvement in terms of audit trail control and close out of document changes.
The system based inspection highlighted some compliance shortcomings within the safety cases sampled. A level 4 regulatory issue will be raised regarding LC 23 consideration, which may be due to interpretation. A letter will be sent to site to communicate the actions required to remedy the shortcomings, and also list the other observations and areas for improvement identified. The Hunterston A nominated site inspector will follow up as part of normal business.