Office for Nuclear Regulation

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Hunterston B - Themed inspection

Executive summary

Purpose of Intervention

This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Hunterston 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 accord with the planned inspection programme contained in the Hunterston B Integrated Intervention Strategy (IIS) for 2019/20.

Interventions Carried Out by ONR

As part of this intervention I, the nominated site inspector, with support from specialist Liabilities Management and Leadership and Management for Safety inspectors, carried out a Theme Inspection against:

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

I also held a routine meeting with the head of the station Independent Nuclear Assurance (INA) to receive an update on current INA areas of focus.

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 EDF’s transition plans towards defueling and decommissioning, the appointment of staff to transition roles and the immediate work priorities being implemented at Station, East Kilbride and Barnwood.  This will inform the development of ONR’s permissioning strategy to be applied to transition activities at the station and corporately.

ONR recognised that the EDF transition organisation continues to grow and that there is alignment between corporate transition roles and station transition roles.  However several of these roles are part time at present.

The Baseline Decommissioning Plan 2016 (BDP16) is being subject to significant review to align with current industry thinking on decommissioning interim end states.  A number of transition work activities are ongoing at station and at Barnwood.  ONR did not see a clear line of sight between the preparation and review of the overall transition and decommissioning plan and the implementation of the plan.  Some work activities are delayed and the current approach to management of the transition programme would benefit from review to achieve better alignment with a delivery based project organisation.

The station is aware of the scale and complexity of the organisational change required by the transition programme.  Furthermore there are transition demands being placed on staff that must be carefully balanced against the need to maintain focus on safe generation as the station prepares itself for a possible return to service following a prolonged outage period.   Recommendations have been made to address these issues, which include the need to prepare an overarching organisational change submission to control the strategic phases of the transition.  These recommendations will be addressed through normal interactions with the station.

Conclusion of Intervention

From this inspection of LC 32, 35 and 36 that examined the station preparations for end of generation at Hunterston B, there were no findings that could significantly undermine nuclear safety.  Therefore a rating of Green, no formal action, was assigned to the inspection.