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 mainly to address Compliance inspection and follow-up of regulatory actions placed on the site from previous inspections as follows:-
Only the Compliance inspections are included in the executive summary as all other interventions are for information only.
LC 7 - The purpose of this intervention was to undertake a LC 7 inspection of the site arrangements. We undertook a compliance inspection of Hunterston A’s local arrangements for compliance with Licence Condition 7. Where relevant and for informational purposes only, we also consulted the Magnox corporate arrangements for compliance with this Licence Condition. We judge the arrangements under Licence Condition 7 to be below standard. While the fundamental requirements for this license condition are met, there were a number of procedural weaknesses observed. In some cases, written arrangements do not accurately reflect the processes and procedures followed by site for compliance with this license condition. We were informed that similar observations had been noted by site during a recent audit and that a project was underway to ensure that corporate and site arrangements would be aligned when the new investigation types were implemented in January 2015. However, site procedures were not marked as being in hiatus and we were unable to obtain a written statement to this effect.
LC 11 – The purpose of the intervention was to undertake an LC 11 inspection regarding emergency arrangements primarily regarding Post Fukushima consideration implementation and close out. We undertook an inspection of Hunterston A’s arrangements for compliance with LC 11 – Emergency Arrangements. This inspection consisted of two parts – (1) inspection of the site’s post-Fukushima ISO freight and satellite phones by the nominated site inspector and a specialist inspector and (2) observation of a table-top exercise by the specialist inspector. Taking into account the post-Fukushima equipment inspection and the table top exercise observation, we judge the licensee’s arrangements for LC11 to be adequate. In most cases, the arrangements met the requirements of the guidance, although we were able to suggest minor points for improvement. One caveat is that misinformation was originally provided during the inspection when the specialist inspector was informed that the information on the Hunterston A design basis flood she had brought to site was incorrect. It was later determined that this information was indeed correct. It is the opinion of the Inspector that this may have been caused by a desire to tell a “good news story” by the Licensee.
LC 22 – This purpose of this intervention was to consider LC 22 in line with the relevant ONR documentation. We undertook a compliance inspection of Hunterston A’s local arrangements for compliance with Licence Condition 22. Where relevant and for informational purposes only, we also consulted the Magnox corporate arrangements for compliance with this Licence Condition. This considered the high level corporate arrangements in MCP-99 and the site specific implementation of those arrangements in HNAMCP-99/5, which provides the detailed delivery arrangements for the philosophy presented in MCP- 99. We judge the arrangements under Licence Condition 22 to be below standard. We observed procedural weaknesses and a lack of clarity relating to the governance process for the high category modifications and the clarity and delivery of adequate governance for high category modifications is considered fundamental to the arrangements. In some cases, written arrangements do not give the full picture regarding processes and procedures followed by site for compliance with this licence condition. ONR’s opinion is that this should be easily fixed, but does need to be done. The issue here is that should something happen it is not possible for the site to demonstrate it followed an appropriate due process, as this has not been defined by the site arrangements.
The inspection raised issues regarding the arrangements under LC 7 and LC 22 and thus a letter will be sent to site and issues placed on the issues database for closure. The issues should be relatively simple to close, but delivery needs to be timely. It is the opinion of the Inspector that there is a further issue regarding management behaviours on site and this may be developing. This will need to be monitored and considered with the ONR corporate inspector with regard to leadership for management and safety.