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 planned compliance inspections against the following specific Licence Conditions:
I also met with the station’s independent nuclear assurance [INA] evaluators to discuss recent surveillances and other matters relevant to nuclear safety.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system based inspection was undertaken during this intervention.
We undertook an inspection of station compliance against its arrangements for controlling construction and installation of new plant, supported by a specialist project inspector. We also examined the station’s arrangements for commissioning and sampled their implementation as part of a combined LC compliance inspection. The inspection was structured as follows:
We considered the arrangements to represent a suitable routemap to the various elements of project initialisation and governance; safety case production and design progression. The arrangements also provide a connection to wider arrangements for modifications under LC 22 and commissioning under LC 21. The station has implemented an LC 21 specific site standing order that provides well-structured arrangements to deliver commissioning.
We made the following observations and judgements in relation to delivery of construction and commissioning phases of portfolio projects at the station:
Recognising the positive improvements to governance and accountability within the projects organisation, but noting the substantial delays to construction and commissioning in recent years for major projects, I intend to undertake quarterly Level 4 project meetings with the station engineering manager and Technical Safety Support Manager to monitor progress. This will be coordinated within the New Year.
I undertook a compliance inspection of the station’s implementation of arrangements made under Licence Condition 23 [operating rules]. The scope of the inspection was focused on the adequacy and implementation of the company arrangements to manage operational point in time risk to as low as reasonably practicable [ALARP], with respect to prioritisation of planned maintenance routines, emergent work and defects.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
I have allocated an IIS rating of ‘3 – Adequate’ for Licence Condition 19 on the basis that project governance arrangements at Hunterston B and investment delivery process have appropriate maturity and alignment to company arrangements. A higher rating was not awarded because we judged there is a need for improvements to the role of the project safety review group as the ‘controlling mind’, and a need for improved integration of projects department, design authority, and engineering to deliver nuclear safety – related improvements right first time.
I have allocated an IIS rating of ‘3 – Adequate’ for Licence Condition 21 on the basis that Hunterston B undertakes commissioning in accordance with mature station-specific arrangements. A higher rating was not awarded because we judged there is a need for the station’s commissioning strategies to be better integrated into the overall investment delivery process.
I have allocated an IIS rating of ‘2 – Good Standard’ for Licence Condition 23 on the basis that Hunterston B has demonstrably implemented adequate arrangements to manage operational point in time risk ALARP. No areas for improvement were identified for Hunterston B and a number of areas of good practice were identified.
There are no findings from this inspection that could significantly undermine nuclear safety and, at present, no additional regulatory action is needed over and above the planned interventions of Hunterston B power station as set out in the Integrated Intervention Strategy, which will continue as planned.