Hunterston A planned inspection
- Site: Hunterston A
- IR number: 15-137
- Date: February 2016
- LC numbers: 7, 11, 32, 34, 35
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:
- LC 7 – Compliance Inspection
- LC 11 – Compliance Inspection
- LC 32 – Compliance Inspection
- LC 34 – Compliance Inspection
- LC 35 - Compliance Inspection
The Ionising Radiations Regulations 1999 (IRR99) compliance inspection
Explanation of Judgement if Safety System Not Judged to be Adequate
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.
- LC 7 "Incidents on the site" requires the licensee to make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on site. I have rated this intervention as Below Standard. The inspection raised doubts about the quality of the investigations. A level 4 issue will be raised seeking to improve the quality of the investigations and actions such that they seek to avoid repetition of events and also consider the wider implications and learning from events.
- LC 11 "Emergency arrangements" requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects. I have rated this intervention as adequate. The licensee has taken on board the findings of the previous exercises and has implemented an improvement plan with some of the work still outstanding. Additionally there has been positive discussion regarding the revised arrangements and the potential demonstration needs going forward.
- LC 32 "Accumulation of radioactive waste" requires licensees to make and implement adequate arrangements for minimising so far as is reasonably practicable the rate of production and total quantity of radioactive waste accumulated on the site at any time and for the recording the waste so accumulated. I have rated this intervention as below standard. Given the breadth of waste issues on the site ONR will raise level 3 issue on the site detailing a number of actions to be addressed to achieve resolution. ONR will be carrying out further inspections to monitor the improvement of the situation.
- LC 34 "Leakage and escape of radioactive material and radioactive waste" requires licensees to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on the site is at all times adequately controlled or contained so that it cannot leak or otherwise escape from such control or containment. I have rated this intervention as adequate. Given the control shown and information on contaminated land and land quality issues, the position is adequate, but there will need to be further discussion with SEPA going forward this year to clarify the position for entry into care and maintenance.
- LC 35 "Decommissioning" requires licensees to make and implement adequate arrangements for decommissioning of any plant or process which may affect safety. I have rated this intervention as adequate. However, the next issue of the site decommissioning programme should be revised to meet ONR’s expectations as defined the ONR Technical Assessment Guide on Decommissioning.
The inspection against the requirements of IRR99 is reported in detail in the ONR Radiation Protection specialist inspector’s Intervention Record, ONR-DFW-IR-15-136, and has been rated as adequate by the specialist inspector.
Conclusion of Intervention
The inspections highlighted some compliance shortfalls and thus one level 4 issue and one level 3 regulatory issue will be raised on the site covering LC 7 and LC 32. This will be communicated to the site via a letter to confirm the issues and outline follow-up and closure processes. The Hunterston A nominated site inspector will follow up these issues as part of normal business.