- Site: Hartlepool
- IR number: 20-002
- Date: April 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.
Interventions Carried Out by ONR
The inspection, led by the Hartlepool Site Inspector and accompanied by the Group Head of the site-based Independent Nuclear Assurance team, included a session with the Corrective Action Programme (CAP) Co-ordinator and six 40-minute interviews with members of the senior leadership team (SLT).
The inspection gathered data on the effectiveness of the CAP/Organisational Learning process (the principal mechanism through which NGL comply with the requirements of Licence Condition (LC) 7) and examined the degree of SLT individuals’ engagement with the CAP process.
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 Hartlepool staff demonstrate a sound understanding of them. I consider that Hartlepool generally complies with the requirements of the arrangements and I found no regulatory shortfalls during this inspection.
However, I believe that there are members of the SLT that do not value the process as should be expected. In my opinion, without full senior leadership engagement, the wider staff-base cannot be expected to engage fully with the process. Thus, the benefits to be gained from the process are reduced. Possibly as a result, performance indicators suggest that the health of the process is declining and action should be taken to reverse this decline.
The governance and oversight of the process by the SLT should be examined to ensure it is suitably robust, as there were examples found where the intent of the SLT was not carried through into the delivered actions. Similarly, the auditable trail for decisions made within the LC7 process should be improved.
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 Hartlepool Power Station.