Office for Nuclear Regulation

Hartlepool - LC7 inspection

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake a compliance inspection 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 for 2018/19.

Interventions Carried Out by ONR

In my capacity of nominated site inspector for Hartlepool Power Station, I undertook two inspections (alongside specialist inspectors) to examine the licensee’s arrangements and implementation thereof with regard to:

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 planned inspections, I also attended the Emergency Planning Consultative Committee; held an update on the progress of station-based regulatory issues and met with the Independent Nuclear Assurance team.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

LC7 – Incidents on Site - I sampled evidence for the implementation of LC compliance arrangements, including; completed investigation reports, follow-up on a cancelled condition report (CR), follow-up on learning from Operating Experience (OPEX) across the fleet and screening/categorisation of CRs.

NGL was able to demonstrate compliance with the corporate arrangements, providing evidence through querying the live Asset Management System for all sampled completed CRs starting with recording/identifying, screening/categorising, follow-up investigations, review, corrective actions and relevant cross references to organisational learning etc.

The OPEX and Organisational Learning (OL) process and their implementation were sampled to gain the confidence that the LC7 expectations are met.

I noted some good practices, including improvement in the timeliness of the investigations, specially the turnaround time for ACIN and EFIN in comparison with the other stations and the tracking OL process through the OL dashboards.

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

Concerning Radioactive Materials Transport I sampled the Hartlepool arrangements for the safe transport of radioactive material, against the requirements of the Carriage of Dangerous Goods (CDG) and Use of Transportable Pressure Equipment Regulations 2009, focusing on the following themes: Management system, Package maintenance and operations, Package preparation and consignment, and Training and competence.

During the plant walkdown, I made several observations that were fed back to the station for action.  These items will be followed up by the site inspector at the next scheduled site visit.

Significant amounts of graphite debris were observed on the pond floor and to a lesser extent on the flask location foot pads.  A level 4 issue will be raised to track the station’s plans and progress for addressing this.

It was determined that the fleet-wide compliance arrangements for the authorisation of a Radioactive Materials Transport Engineer (RMTE) and a Radioactive Materials Transport Consigner (RMTC) had not been followed.  In the case of the RMTE; the authorisation interview required (with the station Head of Radiological Protection and a Company Dangerous Goods Safety Advisor) had not occurred, yet the individual had still been signed off as authorised.  In the case of the RMTC, no authorisation evidence could be provided.  We had no concerns over the competence of the individuals to fulfil the roles being undertaken; they had completed the relevant training.

We determined that a contributing cause of these shortfalls stemmed from the Role and Training profiles (RTP) for each role not clearly stating that authorisation is a mandatory requirement of the role.  The RTPs for the roles are controlled at a corporate level.  Therefore, fleet-wide improvements are required; a level 3 regulatory issue will be raised.

As a result of the shortfalls discovered in the training theme, an inspection rating of AMBER was awarded.

Conclusion of Intervention

There are no findings from this intervention that directly undermine nuclear safety at this time.  However, regulatory issues have been raised to track the progress made by NGL on findings related to:

At this time, no changes are required to the planned interventions at Hartlepool Power Station.