- Site: Hartlepool
- IR number: 20-082
- Date: October 2020
- LC numbers: 7
Executive summary
Purpose of Intervention
The purpose of this inspection was to evaluate the adequacy of implementation of EDF Energy Nuclear Generation Limited’s (NGL) arrangements for ‘the notification, recording, investigation and reporting of … incidents on the site…’ at Hartlepool nuclear power station.
Also, on 21st October, I and two ONR project inspectors attended (remotely) the Outage Intentions Meeting (OIM) for the statutory outage for Reactor 1 (R1) in 2021.
Interventions Carried Out by ONR
In my capacity as the nominated site safety inspector for Hartlepool Power station I performed an inspection against Licence Condition (LC) 7 – Incidents on the site.
The inspection included several sessions with the Corrective Action Programme Co-ordinator (CAPCo) to gather data on the effectiveness of the CAP/Organisational Learning (OL) process (the principal mechanism through which NGL comply with the requirements of LC7), a session with the lead OPEX communicator, several sessions covering a sample of investigation reports, a session covering low level event trending and a session covering the resourcing and experience within the Performance Improvement (PI) team.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system-based inspection was undertaken hence, this is not applicable for this intervention.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The fleet arrangements for compliance with LC7 are considered adequate and engagements with HRA staff demonstrate that they have a sound understanding of them. I consider that HRA complies with the requirements of the arrangements and I found no regulatory shortfalls during this inspection.
The OL function does however seem to be driven by the PI department and is not consistently embedded across the station. Several fleet metrics suggest HRA is not meeting the expectations with timeliness of reports and action close out.
Resourcing within the PI department has suffered due to several personnel leaving the station with several roles still vacant. There is an action plan to deal with this as well as other areas relating to the PI department which I will continue to monitor.
Generally, investigation quality was appropriate however there was one example where this fell below the expected standard and has required further review by site post my inspection. I believe this does not represent the expected standards of the station but will review the station response to this event.
Due to lack of resource the PI team have stopped completing weekly and quarterly trend reports and there is no station trend review board. I believe this limits the opportunity to identify adverse trends proactively and to act before the trend deteriorates.
Overall, however I am of the opinion that Hartlepool Power Station is meeting the regulatory requirements of LC7.
Conclusion of Intervention
Based on the sample inspected, I rate the inspection as GREEN – no formal action. This is in line with the established ONR guidance:
- “Relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks”,
- “No significant shortfalls identified in the delivery of safety or security functions”,
- “Relatively minor, if any, deficiencies in compliance arrangements.”
I believe that no additional regulatory interventions are needed over and above those already planned at HRA Power Station.