Office for Nuclear Regulation

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LC 35 - Preparations for end of generation, decommissioning and routine site inspector interactions

Executive summary

Purpose of Intervention

This was a planned inspection of EDF Energy (EDFE) Nuclear Generation Ltd.’s Hinkley Point B Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).

The work was carried out in accordance with the planned inspection programme contained in the Hinkley Point B Integrated Intervention Strategy (IIS) for 2019/20.

Interventions Carried Out by ONR

As part of this intervention the nominated site inspector for Hinkley Point B  and I, a specialist Liabilities Management inspector, carried out a compliance inspection against:

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate

No system based inspection was undertaken hence, this is not applicable for this intervention.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The inspection provided ONR with a greater understanding of the development of and progress against EDFE’s transition plans for Hinkley Point B towards defuelling and decommissioning, the appointment of staff to transition roles and the immediate work priorities being implemented at the station and EDFE’s corporate centres.  This informs the implementation of ONR’s permissioning strategy (which has previously been shared with EDFE) to be applied to transition activities at the station and corporately.

The station demonstrated a good understanding of what work is required to prepare for end of generation (EoG), defuelling and decommissioning, and shared its work plans, which are due to be consolidated into a Decommissioning Programme Plan (DPP) by mid-2020.  The station is making good progress against those aspects of the work programme it is responsible for, and sees no significant risks to being ready to support commencement of defuelling after EoG.  We suggested the station consider how it could better communicate the good progress it is making both internally and to external stakeholders, as this will build confidence.  We will engage with the station when the Hinkley Point B DPP is available, to satisfy ourselves it is complete and well underpinned, and to confirm alignment with ONR’s permissioning strategy.

The station recognises that significant organisational change will be required to transition from operations to defuelling and decommissioning, and is putting in place a lifetime transition function, which is being resourced.  The site inspector will engage with the station on LC36 aspects of the change as part of his routine regulatory interactions, recognising supporting operations and preparing for EoG put competing demands on staff that have to be balanced.  The remit of the lifetime transition organisation is broader than defuelling, which we considered to be sensible because preparations for decommissioning need to be completed during defuelling. 

The station’s immediate focus is on preparations for defuelling, though it is facilitating a programme of site specific works to enable radioactive waste to be safely managed during decommissioning.  EDFE’s corporate centre is leading on development of the radioactive waste management strategy and the design of the radioactive waste management facilities to be constructed on the station – this work is relatively immature, reflecting EDFE’s view they are not required until after ‘fuel free verification’ (FFV) has been demonstrated.  ONR will engage with EDFE and the station as part of routine regulatory interactions when the plans are sufficiently well developed to do so.  We were satisfied that the present risk of radioactive waste management facilities not being available at Hinkley Point B when required is relatively low (taking account of the programme of site specific enabling works).

We advised the station to consider how it could use information it routinely collected under its existing LC compliance arrangements (for example on radioactive leaks) to inform decommissioning planning.  We also advised the station to consider how it will apply the lifecycle asset management planning (LAMP) process to identify what plant will be required to support the defuelling, decommissioning, etc., and consider how to most effectively present the output to ensure it is clear appropriate asset management regimes are in place.  The station noted these points.

Conclusion of Intervention

From this inspection of LC35 that examined the station preparations for end of generation at Hinkley Point B, there were no findings that could significantly undermine nuclear safety.  Therefore a rating of Green, no formal action, was assigned to the inspection.