Health and Safety
Executive / Commission
Nuclear
LLC reports
This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above site available to the public. It is for distribution to members of the Hunterston A Site Stakeholder Group (SSG) and covers activities associated with the regulation of safety at Hunterston A. These reports are distributed quarterly and are also available on the HSE’s website at http://www.hse.gov.uk/nuclear/llc/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate normally attend SSG meetings and will be happy to respond to any questions raised there or subsequently by members of the SSG. Any other person wishing to inquire about matters covered by this report should contact the HSE’s, Nuclear Directorate on 0151 951 3484/3290.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The Nuclear Installations Inspectorate (NII) Site Inspector made inspections on the following dates during the quarter:
Inspections are undertaken at site as part of the process for monitoring compliance with:
This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensee is required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period routine inspections of Hunterston A covered:
In general the arrangements made and implemented by Hunterston A in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.
HSE attended the site’s Annual Review of Safety on 27 January 2009. Whilst the review did not identify any significant issues for the site, HSE found that some areas of the review would need additional work at future reviews and we required the licensee to provide a more comprehensive engineering assessment.
Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee’s response including actions taken to implement any necessary improvements. Matters of particular note considered during the reporting period include the following.
HSE undertook a preliminary investigation into failure to maintain a filter in February 2008, which was completed during the reporting period. This concluded that, in addition to shortcomings in the maintenance process, the licensee had also not reported the incident correctly. It had, nonetheless, taken appropriate steps at the time to improve its arrangements and hence HSE’s action was limited to a letter to the licensee.
During an inspection of maintenance, the site inspector found another instance where the site had not correctly completed maintenance - this time on a crane hoist. The licensee categorised this as level 1 on the INES scale, which required formal reporting to HSE. HSE required the licensee to undertake a comprehensive review of maintenance records on a short timescale. This identified some further issues that the site is working to address.
The licensee is proposing to defer encapsulation of solid and liquid waste streams on the site. It has discussed its proposals with HSE and HSE is awaiting formal justification of the proposals to decide whether they are acceptable.
Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or requires some form of action to be taken; these are collectively termed Licence Instruments (LI). In addition inspectors may issue enforcement notices to secure improvements to safety. No LIs or enforcement notices were issued during the reporting period.
In early 2008 the Government initiated a review into the UK's nuclear safety regulatory regime, led by Dr Tim Stone. The recommendations and the UK's Government response were published at the end of January 2009. One of the major recommendations is the decision by Government to establish the Health and Safety Executive’s (HSE) Nuclear Directorate (ND) as a Statutory Corporation under the auspices of the HSE.
The creation of this new, autonomous body, (which will continue to incorporate the Office for Civil Nuclear Security and the UK Safeguards Office) will facilitate a more sustainable approach to regulating nuclear safety and security within a rapidly changing global nuclear environment and recruitment of high calibre of staff within a hardening market place for highly specialised skills.
The restructuring will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.
Enabling work continues for the initial scoping and planning of the work-streams and programmes necessary for the Statutory Corporation to come into being from April 2010. This project has required the temporary enhancement of ND’s senior management capability in order to deliver existing regulatory work and to create the Statutory Corporation.