- Site: Hartlepool
- IR number: 21-018
- Date: May 2021
- LC numbers: 17, 18
Executive summary
Purpose of Intervention
This intervention report captures ONR’s assessment of EDF Energy Nuclear Generation Ltd.’s radiological risk management arrangements at Hartlepool Nuclear Power Station. The intervention sought to establish if the licensee’s ability to comply with the Ionising Radiations Regulations 2017 (IRR17) and the REPPIR 2019 was affected by the number of Emergency Health Physicists being below the baseline level.
The aim of the Radiation Protection (RP) intervention was:
- To provide regulatory confidence in relation to compliance with IRR 17 and REPPIR 2019.
- To inform the ONR decision relating to the closure of Regulatory Issue (RI) 8444 – Emergency Health Physicists below the baseline staffing level.
Interventions Carried Out by ONR
The intervention focussed on the following during the opening meeting and plant inspection:
- Emergency response plan arrangements and role requirements for RP staff.
- Health Physics emergency response rota details and sustainability.
- Head of Radiation Protection (HoRP) responsibilities under MCP/014/300 Section 4.
- Inspections, interventions and audits carried out by the RP team.
- Role of Radiation Protection Adviser (RPA) and engagement by site with RPA.
- Impact of defueling on RP resource.
- Maintenance of standards in the RP and Radiation Protection Supervisors (RPSs) including training and competence.
- RP input into work planning including risk assessment
- Radiological event investigation and follow up including response to leakages and spillages
The nominated site safety inspector also undertook a number of engagements with the licensee representatives which are covered under section 3 of this report.
- Meeting with the licensee’s internal regulator, Independent Nuclear Assurance,
- Meeting with the Station Director, Plant Manager and TSSM,
- Follow-up of site events,
- Monitoring the onsite Covid-19 response.
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 inspection did not reveal any significant nuclear safety concerns that require action by the Licensee or further follow-up by ONR.
The inspection and discussions with the HoRP for Hartlepool and other representatives of the duty holder gave me suitable assurance that there is effective RP practice in place and an adequate level of compliance with the requirements of IRR’17 and the aspects of REPPIR 19 discharged by the Emergency Health Physicists.
Restoration of staffing numbers to the baseline is still required, which will be captured in a new RI. The existing RI (8444) will be closed.
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.