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 Inspection plan and carry out the planned Compliance inspections
This report covers interventions at Hunterston A to address Compliance inspection as follows:
Only the Compliance inspections and follow-up inspections are included in the executive summary as all other interventions are for information only.
LC 12 - The purpose of this intervention was to undertake an inspection of the licensee's arrangements and implementation under LC12. LC12 "Duly authorised and other suitably qualified and experience persons" requires licensees to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions. In conclusion, for Site Licence Condition 12, ONR considers an Amber Rating to be appropriate with an associated Level 4 issue to address the underlying definition of DAP and the understanding of control and supervision within the arrangements under HNA/MCP 011.
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 proposed 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. For LC 19 "Construction or installation of new plant" , ONR considers an inspection rating of Amber to be appropriate as although a significant amount of work has been undertaken, there are still areas not addressed under the existing issue. Magnox agreed that it had some further work to do to close the existing issue which was raised during ONR's last inspection. ONR was satisfied that Magnox has continued to work with the contractor to align the contractor's way of working to meet Magnox's arrangements under LC 19.
LC 20 - The purpose of this intervention was to undertake an inspection of the licensee's arrangements and implementation under LC20. LC 20 "Modification to design of plant under construction" requires licensees 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. In conclusion for Site Licence Condition 20, recognising the limited scope of the inspection, I consider a Green Rating to be appropriate. Future LC 20 inspections should seek to consider the concession and non-conformances and also LTQRs for the facility associated with concessions and non-conformances.
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 carried out a sample inspection on a number of modification documents. There were some areas of improvement which the site agreed to address and I will follow up progress on these in a future inspection. In conclusion for Site Licence Condition 22, I consider a Green Rating to be appropriate
LC 24 - The purpose of this intervention was to undertake an inspection of the licensee's arrangements and implementation under LC24. LC24 "Operating Instructions" requires licensees carry out operations that might affect safety in accordance with written instructions, and that those instructions should implement any operating rules that might be relevant. In conclusion, for LC 24 "Operating instructions", this inspection was carried out to follow up an issue raised from the last LC 24 inspection regarding the need to put in place procedures to control hand annotation of POI's. I consider an inspection rating of Amber to be appropriate, although the ONR inspector did not find any uncontrolled hand annotations of POIs, the site had not addressed the existing level 4 issue raised in July 2015 as no procedures have been put in place. Additionally I will raise a further level 4 issue on the site with regard to the review of the MAETP/AETP POIs and the control of the validations and verification process as there appear to be deficiencies in follow up of the process to ensure it has been done and the quality of the process itself.
Two additional level 4 issues will be raised and formally communicated to the site with regard to LC 12 and LC 24 and a re-inspection of LC 19 will be scheduled.