The purpose of this planned intervention was to undertake compliance inspection activated at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station. The intervention was undertaken in line with ONR’s inspection programme contained in the Hartlepool Integrated Intervention Strategy for 2019/20.
In my capacity of nominated site inspector for Hartlepool Power Station I performed inspections against Licence Condition (LC) 7 – ‘Incidents on the Site’, and LC 36 – ‘Organisational Capability’. The LC 36 inspection was led by a Leadership & Management for Safety specialist.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
In addition to the compliance inspection, I also undertook several other activities; attendance at the Health, Environment & Safety Advisory Committee where I engaged with some of the station’s safety representatives; a review of the current Regulatory Issues Database with the acting Technical & Safety Support Manager; met with the station-based Independent Nuclear Assurance team; and undertook a general plant walkdown.
I also attended a session relating to the ongoing decision to defer (or not) the exchange of a gas circulator and its associated liner inspection, as well as the feedback session of a conventional health and safety inspection. However, these items are reported separately (ONR-OFD-CR-19-384 and ONR-OFD-IR-19-058 respectively).
Not applicable; no system based inspections were undertaken during this intervention.
The corporate process is well established and NGL staff were able to demonstrate sound knowledge and implementation of that process at Hartlepool. Incremental improvements are being made; however, through an apparent sub-optimal level of Senior Leadership Team (SLT) engagement with the overall organisation learning process, I judge that the value of the process is not being maximised. The level of SLT engagement will be examined in more detail at a further LC 7 inspection in March 2020. In addition, I judge that the longer-term sustainability of the process presents a risk to the station, with reliance on a small number of passionate individuals to make the process work. These elements were fed back to station management; regulatory issues have not been raised as present legal compliance is evident and a further LC7 inspection is planned for March 2020 where these aspects will be directly inspected.
Hartlepool is meeting relevant good practice when compared to ONR guidance. The Human Resources Manger is well informed and is developing robust and evidence-based plans and proposals. We found resilience of the Emergency Scheme to be well managed. We judged the Operations resilience plan to be credible but challenging. We found organisational changes to be appropriately categorised, but scope for further improvements was identified with regard to senior management standards and expectations; quality of risk assessments; effectiveness of proposed mitigation measures (which are not dependant on current individuals in post); ensuring enabling activities have been delivered prior to the proposed change; and more structured oversight by the People Delivery Team. As we noticed improvements in more recent management of change assessments, and coupled with the recent change in HR manager, we did not raise a regulatory issue at this time. We will undertake an LC36 inspection in 2020/21 to confirm that the improvements planned are embedded.
Overall, I judge the standard of compliance across the licence conditions inspected met regulatory expectations and the licensee is complying with its legal duties. Items for improvement were fed back to the station, though none were significant enough to warrant the raising of a regulatory issue at this stage.
There are no findings from this intervention that could undermine nuclear safety at this time. Therefore, no additional regulatory action is needed over and above the planned interventions at Hartlepool Power Station.