Office for Nuclear Regulation

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Inspection of LC36 Baseline at Hunterston A

Executive summary

Purpose of intervention

This report covers an inspection of the implementation of Magnox Corporate Arrangements for LC36 undertaken as part of a series of planned interventions in accordance with the Task Sheet LMfS Resource for Future Magnox Ltd Organisational Changes(ONR-DFW-MAR 056)

Interventions Carried Out by ONR

This intervention consisted of an inspection of the implementation of the revised LC36 baseline arrangements at Hunterston A.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The inspectors found that the process for developing the baseline was in accordance with the licensee’s arrangements and contained adequate detail on the justification for inclusion or exclusion of posts on the baseline; however we noted that there was no similar justification for the trigger levels on the baseline.

The inspectors identified one post that should be included on the baseline and identified that the intelligent customer requirements for the site should be recorded on the baseline.  The inspectors also identified that the baseline indicators were not included in the organisational baseline validation and it could not be demonstrated that they were reviewed collectively.

The inspectors considered the vulnerability analysis to have been effective in identifying vulnerabilities in the organisation, but were of the opinion that the mitigation actions proposed for some posts could not be implemented in the current programme of changes happening within Magnox. The impact of not addressing the vulnerabilities should be assessed through the management of change process.

Conclusion of Intervention

It was the inspectors’ opinion that the issues raised during the baseline inspection at Berkeley (ref: ONR-DFW-IR-15-052) had been taken into account in determining the nuclear baseline at Hunterston A and have been appropriately addressed. A number of shortfalls however had been identified against the Nuclear Industry Code of Practice and the Licensee’s arrangements and an ISS rating of 4 ‘below standard’ is appropriate. 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.