Hunterston B Nuclear Power Station - report Q3 2009

1 July 2009 to 30 September 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.
L20 7HS

Inspections

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

10 to 13 August; 10, 11 and 15 to 17 September 2009.

During the quarter two HSE FOD (Glasgow) inspectors and four HSE ND (NII and OCNS) inspectors visited site so as to consider ‘conventional safety’ matters, security matters and to observe a shift ‘emergency response’ exercise.

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:

Training
Emergency Arrangements
Modifications to Plant
Operating Rules
Operating Instructions
Safety Mechanisms
Periodic Shutdown

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.

Site Stakeholder Group (SSG) Meeting

The Hunterston B NII inspector attended the Hunterston SSG meeting held at the Brisbane House Hotel, Largs on 17th September 2009. After a brief presentation, with reference to HSE/NII Quarterly Reports, questions raised were answered.

Emergency Arrangements Joint Working Group (EAJWG) Meeting

The EAJWG meeting took place at the Hunterston Strategic Co-ordination Centre, Prestwick Airport on 13th August 2009; NII was represented by the HNB NII Inspector. The meeting was chaired by British Energy Corporate Emergency Planning Group Head and attended by Hunterston power stations staff, Scottish Government civil servants, Council Emergency Planners, representatives of various parts of the emergency services, SEPA and HPA. The meeting was routine.

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.

During preparations for the current outage it was determined that the safety case for in-vessel work when shutdown and in air requires the filtered vent route to contain a specific filter of a type that Hunterston has not been using. NII is mainly concerned regarding the mismatch between safety case and actual plant that has been allowed to develop as there should not have been any additional release of reactivity as a result of the wrong filter being used. BE has changed the filter and tightened its procedures so as to avoid a reoccurrence of this type of situation.

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.

The following LIs were issued this quarter:

LI 521 gave HSE agreement to the use of new Neutron Flux Detectors.
LI 522 approved Tech Spec NSR changes so as to allow Off Load Depressurised Handling of Irradiated Fuel Stringers.

No Enforcement Notices were issued.

Proposed changes to HSE's Nuclear Directorate

Government has decided to restructure HSE’s Nuclear Directorate (ND) to improve further its organisational framework for the sustained delivery of robust, effective and efficient nuclear regulation in the UK. This will place the ND in a better position to meet the anticipated future challenges.

Several factors have come together to make now the right time to restructure ND and create a new independent Nuclear Statutory Corporation (NSC) under the auspices of HSE. These include changing requirements of ageing nuclear power reactors; on-going decommissioning and active management of legacy nuclear plants; assessment of potential new nuclear power stations; growing competitiveness in the global nuclear skills market and the need for improved regulation driven by increased expectation from society for better accountability, transparency and efficiency from public sector bodies.

In addition to this was the government-initiated exercise conducted by Dr Tim Stone which examined the UK’s nuclear safety regulatory regime and identified a number of recommendations for improvement, including the need for structural changes to ND. The Summary Recommendations and the Government’s response were published at the end of January 2009 (available on HSE’s website).

HSE is working on the legislative measure that needs to be in place to create the NSC. These changes will be made through a Legislative Reform Order (LRO) under the Legislative and Regulatory Reform Act 2006.

Informing this, a joint consultation exercise was carried out by DECC and DWP that sought views on the proposed changes. The 12-week consultation period ended on 22 September 2009 and submissions are currently being assessed.

These new arrangements 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.

These reforms are designed to lead to improvements in the transparency, accountability and consistency of regulatory activities, thereby seeking to enhance the confidence of all stakeholders, both duty holders and those with wider interests. The reforms would be expected to offer clear and direct benefits to industry and workers as well as society as a whole, which would benefit from efficient and continued robust and effective regulation of nuclear hazards.

Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.

An internal change programme is currently operating within ND to ensure that the ND is ready to operate when permitted by Parliamentary approval as a statutory corporation from spring 2010. This programme has identified key areas of action and deliverables, which will sit alongside the current business improvement programme and will ensure that operational business improvements are delivered alongside the set up of the new corporation.

It is important to recognise that this programme does not in anyway compromise the current business activity that is delivered through ND and strives to improve operational effectiveness and stakeholder engagement.