Office for Nuclear Regulation

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Hunterston B - Compliance with Class 7 (Radioactive Materials) Transport Regulations

Executive summary

Purpose of Intervention

This intervention looked to assess regulatory compliance for the transport of class 7 dangerous goods at EDF Energy Nuclear Generation Limited (NGL) Hunterston B Power Station.

The Office for Nuclear Regulation (ONR) is responsible for regulating the transport of Class 7 dangerous goods (radioactive material) as the Transport Competent Authority appointed under Regulation 25 of The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG).

The intervention was undertaken in conjunction with NGL’s own Independent Nuclear Assurance (INA) Class 7 dangerous goods surveillance in order to both reduce regulatory burden on the Station and allow views and opinions on regulatory compliance to be shared.

Interventions Carried Out by ONR

Due to Coronavirus lockdown measures the intervention was carried out remotely by holding a series of structured video conference discussions with NGL Hunterston B staff involved in the transport of class 7 dangerous goods.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a System Based Inspection

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

Based on evidence gathered from a review of training records, consigning documentation, procedures together with information gathered from structured discussions, I found Hunterston Power Station compliant against transport legislation for carriage of Class 7 goods.  This view is based on Consigning staff being knowledgeable of Class 7 transport regulations, adequate training arrangements in place and no deficiencies identified from inspection of consigning documentation.  I also consider Station has suitable transport emergency arrangements for responding to an event by setting up the Station’s emergency central control and capability to dispatching a RadSafe team in support of Local Authority Emergency Services.  However, I consider improvements could be made here by introducing desk top exercises linked with the NGL Barnwood Central Emergency Support Centre.  The inspection found that currently the only opportunity Station staff have for preparing to respond to a transport emergency is the planned demonstration exercise that takes place every 8 years.  This finding will be addressed in the current ONR issue dealing with improvements in NGL’s transport emergency arrangements.

In the case of Station’s preparedness for potential defueling and increased spent fuel flasking operations, NGL has established the required flask throughput rates for the defueling programme.  The modifications to the flask hall and organisational changes to support an enhanced throughput are subject to an ongoing programme of work

Conclusion of Intervention

I consider NGL Hunterston Power Station is compliant with CDG legislation and has adequate transport emergency arrangements in place.  There were no findings from this inspection that could significantly undermine safety and no formal regulatory action is needed at this time.  Work is progressing on preparations for defueling Station’s reactors, with changes to plant (Flask Hall) and the Fuel Route’s organisation structures.