Office for Nuclear Regulation

Hartlepool - Planned Compliance Inspection

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection activities at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station, in line with the ONR’s inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS) for 2018/19.

Interventions Carried Out by ONR

In my capacity of nominated site inspector for Hartlepool Power Station, accompanied by a Health and Safety Executive - Hazardous Installations Inspectorate inspector, I performed and intervention to examine the licensee’s implementation of its compliance arrangements with regard to licence condition (LC) 11 ‘Emergency Arrangements’.

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

In addition to the compliance inspection, I also met with Independent Nuclear Assurance staff, attended the Health and Safety Advisory Committee meeting (including a plant walkdown) and observed routine management meetings.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable – no system based inspections were completed during this intervention.

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

I determined that the Emergency Preparedness Engineer’s understanding of the key arrangements was appropriate.  I sampled key licence compliance arrangements and the output of these arrangements, such as the Emergency Plan and the Emergency Handbook.  In addition I sampled output required by Control of Major Accident Hazards regulations, including the Major Accident Prevention Plan and its supporting Process Hazard Review.

An updated version of the Emergency Plan is currently with ONR for Approval under LC11(2); the extant plan remains acceptable for use in the intervening time; though an auditable trail for regular review of the plan should be established.
Development of Emergency Response Plans (ERP) to major accident hazards is underway, three (of 10) were seen, with completion of the remainder by the end of 2018; testing and validation will continue through 2019.  Opportunities to improve the ERPs were identified and share with the licensee.

There was not sufficient evidence seen during the inspection to indicate that risks to the site from nearby facilities were well understood and an appropriate emergency response developed.  Although the Emergency Handbook does have actions to take in the event of incidents from nearby facilities affecting the site; it was not evident how these had been derived and considered appropriate.  I have raised a regulatory issue to seek improvements in this area.

Based on the evidence sampled, I am satisfied that legal requirements have been met.  Overall, I consider the standard of compliance to be sufficient to award an inspection rating of GREEN.

Conclusion of Intervention

Overall, I judge that the standard of compliance was consistent with relevant good practice and I am satisfied that the licensee is complying with its legal duties.  Items for potential improvement were fed back to the station; I have raised one regulatory issue relating to the station’s knowledge of the risks posed to the station by neighbouring facilities and the reasonably practicable emergency response/mitigating measures therefore required.

There are no findings from this inspection that could undermine nuclear safety at this time.  Therefore, no additional regulatory action is needed over and above the planned interventions at Hartlepool Power Station.