Executive summary
Date(s) of inspection: December 2024
Aim of inspection
This was a planned compliance inspection under the Fire (Scotland) Act 2005 & the Fire Safety (Scotland) Regulations 2006 at the EDF Energy Nuclear Generation Limited (EDF NGL) Hunterston B (HNB) site.
The inspection was undertaken as part of the 2024/25 intervention strategy for Operating Reactors Sub-Division of the Office for Nuclear Regulation (ONR).
The aim of this inspection was for specialist fire safety inspectors to undertake an inspection at HNB to determine the adequacy of implementation of the Licensee’s claims associated with life fire safety, at the site's current stage of operation, to ensure that conventional fire risks are reduced as so far as is reasonably practicable. Fire hazards, if not controlled, can present risks to safety. It is therefore important that the risks from fire are adequately controlled.
The inspection also sampled the maturity of arrangements for the transition of fire safety from EDF NGL and to Nuclear Restoration Services (NRS) as part of site transfer.
The inspection was undertaken as part of the 2024/25 intervention strategy for Operating Reactors Sub-Division of the Office for Nuclear Regulation (ONR).
The aim of this inspection was for specialist fire safety inspectors to undertake an inspection at HNB to determine the adequacy of implementation of the Licensee’s claims associated with life fire safety, at the site's current stage of operation, to ensure that conventional fire risks are reduced as so far as is reasonably practicable. Fire hazards, if not controlled, can present risks to safety. It is therefore important that the risks from fire are adequately controlled.
The inspection also sampled the maturity of arrangements for the transition of fire safety from EDF NGL and to Nuclear Restoration Services (NRS) as part of site transfer.
Subject(s) of inspection
- Fire (Scotland) Act 2005 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection consisted of a review of the implementation of the licensee’s life fire safety arrangements including: a review of fire safety management and related documentation, a review of a sample of fire risk assessments and a plant walkdown, which focussed on areas of the Reactor Building, Control Building and Low Level Waste Store.
I also sampled the duty holder's arrangements for the transition of life fire safety compliance from EDF NGL to Nuclear Restoration Services (NRS) as part of site transfer. This represents an important aspect of fire risk management as the transition from defueling to decommissioning will be associated with an increase in the significance of conventional safety risk and also because current EDF NGL arrangements and NRS arrangements may differ in some regards.
I also sampled the duty holder's arrangements for the transition of life fire safety compliance from EDF NGL to Nuclear Restoration Services (NRS) as part of site transfer. This represents an important aspect of fire risk management as the transition from defueling to decommissioning will be associated with an increase in the significance of conventional safety risk and also because current EDF NGL arrangements and NRS arrangements may differ in some regards.
Conclusion
Overall, based on my sample, I judge that EDF Energy Nuclear Generation Limited has adequately implemented its arrangements with respect to compliance with the Fire (Scotland) Act 2005 and the Fire Safety (Scotland) Regulations 2006 and therefore award a Green rating for the inspection.
During the inspection I identified some observations /advice which were shared with and accepted by EDF NGL as part of inspection feedback. These matters do not impact on the overall adequate provision of safety or inspection rating.
Transition arrangements for life fire safety are currently at an early stage of development. I am therefore unable to make a judgement regarding the adequacy of life fire safety transition arrangements as they are not yet developed. I judge however that significant works remain outstanding in regards to ensuring adequate transfer of life fire safety compliance arrangements from EDF NGL to NRS.
I therefore consider that further sampling of the strategy and implementation plan for managed hand over of life fire safety compliance arrangements may be required as part of the transfer intervention strategy for Hunterston B. Such requirement may include demonstration of the adequacy of corporate arrangements and those at HNB. I have therefore raised the potential requirement for further demonstration of arrangements with the ONR Nominated Site Inspector (NSI) for HNB and also the AGR Transition and Transfer Project Inspector.
During the inspection I identified some observations /advice which were shared with and accepted by EDF NGL as part of inspection feedback. These matters do not impact on the overall adequate provision of safety or inspection rating.
Transition arrangements for life fire safety are currently at an early stage of development. I am therefore unable to make a judgement regarding the adequacy of life fire safety transition arrangements as they are not yet developed. I judge however that significant works remain outstanding in regards to ensuring adequate transfer of life fire safety compliance arrangements from EDF NGL to NRS.
I therefore consider that further sampling of the strategy and implementation plan for managed hand over of life fire safety compliance arrangements may be required as part of the transfer intervention strategy for Hunterston B. Such requirement may include demonstration of the adequacy of corporate arrangements and those at HNB. I have therefore raised the potential requirement for further demonstration of arrangements with the ONR Nominated Site Inspector (NSI) for HNB and also the AGR Transition and Transfer Project Inspector.