The purpose of this intervention was to undertake compliance inspections and information exchange meetings at EDF Energy Nuclear Generation Limited’s [NGL’s] Hunterston B [HNB] power station in line with the planned inspection programme contained in the HNB Integrated Intervention Strategy [IIS].
During this intervention we undertook a compliance inspection against Licence Condition 36 – Organisational Capability. This was a follow-up inspection to April 2014 and examined progress against changes to company arrangements. We also undertook a compliance inspection against Licence Condition 15 – Periodic Review to examine progress towards closure of historic regulatory and licensee-identified shortfalls from the second cycle of Periodic Safety Review undertaken at Hunterston B [PSR 2]. We also examined the station’s arrangements and progress towards the third cycle of PSR.
During this intervention I undertook additional information exchange meetings with Independent Nuclear Assurance [INA] and reviewed the draft exercise scenario for a forthcoming Level 1 Demonstration exercise to be carried out in accordance with the station’s arrangements under Licence Condition 11 – Emergency Arrangements.
No safety system inspection was undertaken during this intervention.
During the compliance inspection against Licence Condition 36, we undertook:
A review of lead team governance arrangements and personal accountabilities associated with ensuring adequate organisational capability.
Inspection of Hunterston B’s succession strategy to ensure organisational capability is sustained for safe continued generation.
A review of progress towards revision to the Hunterston B nuclear baseline in light of changes to company arrangements, and the annual review of the baseline undertaken in October 2014.
A review of progress against a 2012 surveillance undertaken by Independent Nuclear Assurance [INA].
A sample inspection of recent organisational changes justified through the station’s management of change arrangements.
We examined the station’s three-year resource strategy and judged that it represents a much improved framework for ensuring current near-term and longer-term challenges to the nuclear baseline are foreseen and managed. The strategy ensures improved flexibility for the station in managing demographic challenges with clear focus on talent management and pipeline recruitment. There is increased astuteness to external factors likely to challenge the nuclear baseline. We judged the station has a demonstrable governance framework for management of change and has now implemented changes to the company arrangements in a prompt and effective manner; notably the introduction of baseline roles to supplement baseline posts.
Hunterston B undertook an annual review of its nuclear baseline in October 2014. This review implemented changes to the company arrangements which now require nuclear baseline ‘roles’ to be defined in addition to ‘posts.’ This now addresses shortfalls identified in my previous LC36 inspection in April 2014. We sampled a Category C MoC associated with a change of role within the Fuel Route on 1st February 2014. The MoC risk assessment was appropriate and sufficient justification was included.
The station provided a progress report for corrective actions that remain outstanding following the second cycle of periodic safety review [PSR2]. We noted that there were twelve such corrective actions open out of 3,500 that were originally identified thus representing significant progress over the past twelve months. We sought and received assurances as to adequate progress and completion plans for the remaining corrective actions.
We reviewed the current delivery schedule for the third cycle of periodic safety review at Hunterston B – PSR3; we were advised by the station’s PSR3 lead that, based on current predictions, the submission will be formally submitted to ONR on the 20th January 2016. We noted that this was slightly beyond the original completion date for PSR3 [expected early January 2016].
The station PSR3 lead expressed confidence that the submission date would be achieved but contingent upon the station’s verification process operating in an efficient and effective manner. We were satisfied the risk of late delivery is tolerably low. We nonetheless advised that this is an important juncture for NGL to evaluate risks to delivery some twelve months ahead of formal submission to ONR.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
We judged, based on the evidence presented, that Hunterston B is compliant with Licence Condition 36 to a good standard, thus attracting an IIS rating of 2 – Good Standard. We judged that Hunterston B is compliant with its arrangements under Licence Condition 15, thus attracting an IIS Rating of 3 – Adequate.