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 2019/20.
In my capacity of nominated site inspector for Hartlepool Power Station and supported by a team of ONR inspectors, I performed an inspection 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.
No system based inspection was undertaken hence, this is not applicable for this intervention.
I consider that although the majority of the observed elements of the demonstration met regulatory expectations, a partial redemonstration during a shift exercise is required. The command and control in the (simulated) central control room will be the main focus of the redemonstration; the same shift is to be used to ensure learning has been applied, and the site-based INA team can undertake that assessment.
In addition, the station should write to ONR to justify its decision-making relating to the time available to inject the manual portion of the 2nd stage Secondary Shutdown (SSD) system. The rationale for this decision was unclear when considering relevant Technical Specifications and Station Operating Instructions which appeared to contradict the decision made.
A level 3 regulatory issue has been endorsed to track both of these elements to completion. A nominal date for completion has been set as end of June 2020 for both aspects, though this is to be confirmed with the station.
The lack of command and control presence observed in the (simulated) Central Control Room during the emergency exercise demonstration and the lack of clear basis for a key nuclear safety decision (when compared with the station’s Technical Specifications and Operating Instructions) have resulted in an AMBER inspection rating ‘Seek Improvement’ against LC 11 ‘Emergency Arrangements’ on this occasion.
A level 3 regulatory issue has been raised to track these to aspects to completion. A partial redemonstration of the central control room during a shift exercise will be undertaken and the station is to write to ONR justifying the key nuclear safety decision made during the exercise. A separate letter is to be written to the station confirming these findings.
I believe that no additional regulatory action is needed over and above the planned interventions at Hartlepool Power Station.