EDF Energy – Nuclear Generation Ltd – Hunterston B planned Intervention
- Site: Hunterston B
- IR number: 15-095
- Date: September 2015
- LC numbers: 11
Purpose of intervention
The purpose of this intervention was to undertake Licence Condition [LC] compliance inspections at EDF Energy Nuclear Generation Ltd’s [NGL’s] Hunterston B power station, in line with the planned inspection programme contained in the Hunterston B Integrated Intervention Strategy [IIS] for 2015/16.
Interventions Carried Out by ONR
This intervention included planned compliance inspections against the following Licence Conditions:
Licence Condition 11 – Emergency Arrangements. During this intervention, the CNS site inspector and I attended an annual review of the station’s emergency arrangements.
As part of the LC11 inspection, I undertook, together with an inspector from the Emergency Preparedness & Response [EP&R] programme and a Principal CNS Inspector, an inspection against a generic emergency preparedness capability map. Hunterston B was selected as one of four NGL stations to be subject to a verification inspection against information populated within its capability map; this was in response to a request from UK Government for ONR to provide assurance as to the capability of all licensed sites to respond to a nuclear emergency.
I represented ONR at the biannual Hunterston Emergency Planning Consultative Committee at the strategic coordination centre at Prestwick airport.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system based inspection was undertaken during this intervention.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The station presented a comprehensive report on status of emergency arrangements at Hunterston B, including a review of Level 1 safety and counter-terrorist [CT] demonstrations occurring in the past 12 months. We discussed aspects of the scenarios under development for next year’s demonstrations. It is evident that the station continues to invest in its equipment and facilities and has been proactive in benchmarking internally and externally. The station has also demonstrated examples of forward-thinking, notably by encouraging emergency controllers to share experiences and good-practice techniques of command and control.
Inspectors made the following observations and findings in relation to the station capability map:
- Finding 1: The Hunterston B response to the capability map presents adequate arguments and evidence to satisfy six out of the seven capability outcomes. In each instance, inspectors were able to identify appropriate alignment to arrangements and relevant sections of the onsite emergency plan and emergency handbook.
- Finding 2: The licensee did not provide any specific evidence of arrangements to manage and minimise the long-term effects of any unexpected event [Outcome 7 – Recovery]. The licensee claims that capability is in place and available if required, but not specifically claimed in its arrangements. Inspectors were nonetheless able to identify some station-specific evidence as to the ability to recover from an event or incident that has resulted in less severe consequences, and constrained within the site boundary. We acknowledged the licensee’s commitment to implement elements of good practice onsite recovery planning, being developed by the Nuclear Emergency Arrangements Forum [NEAF], into its emergency arrangements during 2016.
- Finding 3: Inspectors recognised the extensive work undertaken to implement elements of the Japanese Earthquake Response [JER] programme following events at Fukushima in 2011. Beyond design basis capability has been subject to extensive regulatory interaction and ONR has previously acknowledged the transition of outstanding elements of this programme into normal business. Inspectors were satisfied that an appropriate quality plan is in place to govern the integration of equipment maintenance, training and procedures into the station emergency arrangements during 2016.
- Finding 4: From a security standpoint, inspectors considered that the linkage between Maximum Credible Release Accident and security threats will be considered more fully during Vital Area reviews. Arrangements for the integration of LC11 and Counter-Terrorist [CT] responses require further development and inspectors noted that there is no dedicated on-site training resource for CT response. Inspectors nonetheless noted that over the past year the station has made a considerable progress against these shortcomings.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
Conclusion of Intervention
We judged, based on review of emergency preparedness and an inspection of the Hunterston B capability map, that an IIS rating for LC11 of ‘3 – Adequate is appropriate.
There are no findings from this inspection that could significantly undermine nuclear safety or security.