- Site: Hartlepool
- IR number: 19-177
- Date: February 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
This inspection forms one of three planned site-based inspections that aim to enable ONR to have confidence that:
- EDF Energy Nuclear Generation Limited’s (NGL) hazard & risk identification, assessment and control processes for conventional plant are adequate,
- The inspection & maintenance (including defect categorisation and prioritisation) processes for conventional plant are adequate,
- The operational methods in place for conventional plant are adequate,
And as a result,
- The asset condition and operation of conventional plant is adequate and risks (to people and nuclear & non-nuclear plant) are therefore reduced as low as reasonably practicable.
Interventions Carried Out by ONR
A team of four inspectors (two site inspectors, an Internal Hazards specialist inspector and a Conventional Health & Safety specialist inspector) and a nuclear associate examined Hartlepool Power Station’s arrangements for asset care and operation of high-hazard conventional plant. The inspection comprised a number of office-based sessions, reviewing the evidence provided and discussing relevant topics with NGL personnel. A substantial plant tour was also organised, allowing time to examine a number of high-hazard, conventional/process risk areas; oxygen, methane & hydrogen compounds and diesel, carbon dioxide & bulk chemicals storage.
In addition to the main intervention, the site inspector met with:
- the site-based Independent Nuclear Assurance team to discuss recent work and the conventional plant intervention, and
- the Technical & Safety Support Manager for an regulatory issues update meeting.
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
Two significant shortfalls with respect to relevant good practice (a lack of flexible hose whipping restraints and inappropriate lashing of compressed gas cylinders) were identified during the plant walk down, however both of these were promptly rectified by NGL before the end of the intervention. These items are not considered further.
During our plant walkdown and observations, we found that the tolerance of defects on the (non-nuclear elements of the) systems in scope appears to be too high and the overarching prioritisation process means that the relatively simple (but low priority) jobs are not corrected in a timely manner. Also, some defects require uncommonly entered plant states and we questioned the likelihood of these defects ever being corrected.
We saw an operations team member executing plant manoeuvres from memory, rather than through reference to an instruction (as is required). Upon inspection, the instruction was thought to be incorrect, but had not been updated since 2015. Similar aged instructions exist for other areas. In addition, the team member did not comply with directions given in the prejob brief. However, we must be clear that we had no immediate concerns with the safety of operations.
Therefore, we believe that this is an example of a potential cultural issue regarding the recognition and tolerance of risk; encompassing defect identification, general housekeeping and procedural use & adherence. The site inspector will work with the site-based Independent Nuclear Assurance team (who have drawn similar conclusions from their own work) to evaluate the extent of this type of behaviour, consider if it is a broader cultural issue and secure improvements where necessary. Following this work, the creation of a regulatory issue will be considered and any targeted improvement actions identified.
With respect to the COMAH element of the inspection, we were satisfied that Hartlepool had met its legal duties. Whilst the Major Accident Prevention Policy is generic, the Occupied Buildings Risk Assessment (OBRA) provided more detail required to understand the risks to people from major accident hazards. We recommended to the Fleet COMAH lead that this be rolled out across the fleet. However, we noted that the OBRA discounted some hazardous bulk chemical storage in the basement areas.
Progress made with the fleet-wide guarding survey has been good thus far, though we encouraged this to be sustained with potential solutions for reducing the 10 identified ‘red’ risk items to a temporary ‘amber’ status promptly, rather than waiting for a longer term solution to achieve ‘green’ status.
Four level 4 regulatory issues will be raised to track progress made against the potential shortfalls identified during the inspection:
- Review of defects requiring a ‘Double Reactor Outage’
- Progress with correction of defective rotating plant guarding
- Review and updating of certain plant instructions
- Review of the hazard posed by bulk hazardous chemical storage in basement areas
Conclusion of Intervention
Based on the sample inspected, but following the immediate and necessary improvements made by NGL, 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.”
The output of this inspection, together with those on the same theme at other stations, will be collated and assessed later in 2020 to give a fleet-wide appraisal.
I believe that no additional regulatory interventions are needed over and above those already planned at Hartlepool Power Station; though the scopes of existing inspections may be expanded to revisit some of the topic areas in the future.