Hunterston B planned Intervention
- Site: Hunterston B
- IR number: 15-048
- Date: June 2015
- LC numbers: 6, 14, 24, 24
Purpose of intervention
The purpose of this intervention was to undertake Licence Condition [LC] compliance inspections at EDF Energy Nuclear Generation Ltd’s [NGL’s] Hunterston B power station, in line with the planned inspection programme contained in the Hunterston B Integrated Intervention Strategy [IIS] for 2015/16.
Interventions Carried Out by ONR
This intervention included compliance inspections against the following Licence Conditions:
- LC6 – Documents, records, authorities and certificates
- LC14 – Safety Documentation
- LC24 – Operating Instructions
- LC25 – Operational Records
I also undertook routine interactions with the station independent nuclear assurance evaluators.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system inspection was undertaken during this intervention
Key Findings, Inspector's Opinions and Reasons for Judgements Made
In relation to Licence Condition 6:
- I examined compliance with arrangements for preservation of records required in pursuance to the conditions attached to the nuclear site licence;
- I judged the station to be demonstrably compliant with the company specification for LC6 and site standing order in relation to record retention and record condition monitoring;
- I observed inconsistencies in the rigour to which onsite and offsite records are subject to condition monitoring. The station has committed to review and address this observation.
In relation to Licence Condition 14:
- I examined compliance with arrangements for safety documents production, with specific attention on the training of station personnel to author and verify such documents.
- I judged that training packages for on-station personnel require strengthening with respect to available hazard identification and analysis tools, particularly safety case authors those working outside of central safety case governance arrangements. I have referred these findings for discussion with NGL at a corporate level, noting existing interactions under LC22.
In relation to Licence Conditions 24 and 25:
- I evaluated continuous use station operating instructions relating to Central Control Room response to reactor unit trips, and adherence to company arrangements;
- I sampled operational records associated with continuous use station operating instructions;
- I sampled fuel route records associated with spent fuel flasks despatched to Sellafield;
- I examined urgent defect notifications issued to the competent authorities from third party inspectors [Bureau Veritas] during statutory inspections under LOLER and PSSR since 2013.
- I judged that the translation of original format station operating manuals to current station operating instruction format has led to a more streamlined instruction logic; supporting narrative is now provided in a separate but related ‘basis of document’ that provides succinct background. This appears to be a successful translation that better aligns to the increased rigour of command and controls behaviours required in a post-trip situation.
- I verified, based on sampling, consistency in the station’s nuclear material accountancy system and paper records of skip positions; reactor channel number; fuel assembly number and isotopic data associated with flasks despatched to Sellafield.
- I observed that since ONR became the competent enforcing authority for defect notifications under LOLER and PSSR, such notifications have been submitted by third party inspectors to different recipients within ONR and HSE. The station has committed to ensure third party inspectors report to a single point of contact within ONR.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
Conclusion of Intervention
- From an LC6 perspective, I have allocated an IIS rating of 3 – Adequate.
- From an LC14 perspective, I have allocated an IIS rating of 4 – Below standard. I have raised a regulatory issue by which to monitor improvements.
- From an LC24 and LC25 perspective I have allocated ratings of 3 – Adequate.
There are no findings from this inspection that could significantly undermine nuclear safety.