Office for Nuclear Regulation

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Site Inspection - Hunterston A

Executive summary

Purpose of intervention

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.

Interventions Carried Out by ONR

This report covers interventions at Hunterston A to address compliance inspections as follows:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

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

Only the Compliance Inspections and relevant follow-up meetings are included in this executive summary, as all other interventions were for information only

LC19:- the purpose of this intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 19. LC 19 “Construction or installation of new plant” requires that where a licensee proposes to construct and install any new plant which may affect safety the licensee shall make and implement adequate arrangements to control the construction or installation. I consider the position to be below standard with a number of findings regarding the control and supervision of the contractor and implementation of the contractor’s arrangements and QA.  A level 4 issue will be raised and also detailed engagement will take place with the site internal regulator to improve the QA position for the project.

LC 20 - the purpose of this intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 20. LC 20 “Modification to design of plant under construction” requires the licensee to ensure that no modification to the design which may affect safety is made to any plant during the period of construction except in accordance with adequate arrangements made and implemented by the licensee for that purpose. I consider the position to be adequate, although there are a number of areas for minor improvement, but the improvement made since the last inspection allow for the closure of a regulatory issue.

LC 22 - the purpose of this intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 22.  LC 22 “Modification or experiment on existing plant” requires licensees to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.  I consider the position to be adequate and the work done on defining the high hazard modification process allows for a regulatory issue to be closed.

LC 28 -the purpose of this intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 28.  LC 28 “Examination, inspection maintenance and testing” requires licensees to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.  I consider the position to be adequate and the work done regarding the improvement of the electrical systems allows for the closure of a regulatory issue.

LC 36 - the purpose of this intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 36. LC 36 “Organisational capability” requires the licensee to provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site. ONR considers the position to be below standard and a level 4 issue will be raised with the site regarding the impact assessment and the level of justification provided for one of the sampled changes to the site organisational structure and resources.

Conclusion of Intervention

The inspections highlighted below standard conditions in the areas inspected for LC19 and LC36 and two level 4 regulatory issues will be raised to address the inspector’s findings.  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 and the ONR LFMS specialist inspector will follow up these issues as part of normal business.  Additionally an adequate standard was confirmed for compliance with LC20; LC22 and LC28 and three, associated and previously raised, regulatory issues were closed.