Hunterston B Nuclear Power Station - report Q2 2009

1 April 2009 to 30 June 2009

Inspections
Routine matters
Non Routine matters
Regulatory activity

Foreword

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 Site Stakeholder Group (SSG) and covers activities associated with the regulation of safety at Hunterston B Nuclear Power Station. These reports are distributed quarterly and are also available on the HSE's website. Site Inspectors of HM Nuclear Installations Inspectorate usually attend SSG meetings and will respond to questions raised there by members of the SSG.

Inspections

The NII site inspector visited site on the following occasions during the quarter:

27 to 30 April; 13 and 14 May; and
8 to 11 June, plus 23 to 26 June 2009.

During the quarter one superintending inspector, two HSE inspectors and six NII inspectors visited site so as to attend an outage intention meeting, observe an emergency exercise, consider site hazards and investigate a number of incidents. They gave the site management team feedback that will add to efforts to raise safety standards at the power station.

Routine matters

Routine inspection

Inspections are undertaken at site as part of the process for monitoring compliance with:

The conditions attached by HSE/NII to the nuclear site licence;
The Health and Safety at Work etc Act (HSWA) 1974 and
Regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

This entails monitoring licensee's action on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and other matters which may affect safety. The licensees are 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 implementations. In this period routine inspections covered:

Emergency Arrangements
Reactor 3 Outage Intentions/Periodic Shutdown
Periodic Review (CO2 and H2 plant)
Operating Rules
Maintenance
Control and Supervision of Operations
Accumulation of Radioactive Waste
Disposal of Radioactive Waste
Leakage and Escape of Radioactive Material and Radioactive Waste
Compliance with Ionising Radiation Regulations

In general the arrangements made and implemented 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 action will be taken to ensure that appropriate remedial measures are implemented by reasonably practicable timescales.

Joint Scottish Environment Protection Agency/Nuclear Installations Inspectorate Inspection

The NII and Scottish Environment Protection Agency (SEPA) Inspectors carried out a joint inspection at Hunterston B on 24th June 2009 so as to look at compliance with a number of Licence Conditions, the site’s Discharge Authorisations and station records. The discharge of a quantity of unsampled low activity liquid was also investigated (see Section 3 below).

Level 1 Demonstration Emergency Exercise

The annual Level 1 demonstration exercise took place on 14th May 2009. Exercise ‘LUING’ was observed by 5 NII inspectors. An adequate demonstration of emergency arrangements was noted, improvements in many areas were evident, however, it was felt that the station needs a little longer to embed the changed arrangements. The NII site inspector will continue to monitor progress by witnessing shift (training) exercises during 2009.

Formal Regulatory Meetings

During this quarter there was one formal meeting; it was an Outage Intentions Meeting that took place on 29th April 2009. The site’s management team and staff, support by experts from the British Energy headquarters, presented details of the Reactor 3 outage that will commence later this year. For some of the planned activities to take place HSE permission will be required.

Site Stakeholder Group (SSG) Meeting

The Hunterston B NII inspector attended the Hunterston SSG meeting held at the Lauriston Hotel, Ardrossen on 25th June 2009. After a brief presentation, with reference to HSE/NII Quarterly Reports, questions raised were answered.

Other Regulatory Meetings

A meeting was held on 8th May 2009 to discuss options on a new diverse shutdown system that is being considered for Hunterston B. The meeting concluded that the only practicable option that could be installed before the site reaches the end of its operational life is one based on multi-articulated control rods. British Energy is now considering the design of such a system.

A meeting to discuss the main components of a safety case for off-load depressurized handling of irradiated fuel in a carbon dioxide took place on 11th May 2009. This case needs to be accepted by the regulator if British Energy is to introduce a new core graphite inspection process that is the same as that routinely used at the sister site at Hinkley Point B. British Energy hope to use new graphite inspection equipment during the Reactor 3 outage planned for later in 2009.

A new safety case for gas circulator endurance following certain faults is being developed; a progress meeting took place on 12th May 2009.

NII inspectors met with British Energy internal regulators on 29th May 2009 so as to discuss a number of safety issues. NII hope that such meetings will help to impact positively on safety across the BE fleet.

Non-routine matters

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 this period included:

The NII inspector carried out a joint investigation with an HSE Fire Inspector on 28th May 2009 into a roof fire that had occurred on site on 20th March 2009. A number of learning points came out of this event and as a consequence the station has improved arrangements associated with hot work activities.

An unauthorised, unsampled discharge of radioactive liquid waste took place on 15th May 2009 because a routine plant test went wrong. The event was initially investigated by NII on 9th June. There was a joint NII/SEPA investigation into the event on 24th June 2009. The discharged liquid was water from sinks and showers in the reactor building and therefore it was very low activity waste. The investigation identified a number of shortcomings that the Licensee is addressing. Following the event NII took no further action as SEPA were issuing a regulatory enforcement letter.

Regulatory activities

Under Health and Safety legislation the Site Inspector, 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 of require some form of action to be taken; these are collectively termed Licence Instruments (LIs). In addition inspectors may issue Enforcement Notices to secure improvements to safety.

No Licence Instruments or Enforcement Notices were issued during the period.

Changes to HSE's Nuclear Directorate

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) [commonly called NII] 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.