- Site: Hartlepool
- IR number: 22-039
- Date: June 2022
- LC numbers: 28
Purpose of Intervention
An inspection was carried out at Hartlepool power station on the 29 June 2022. The work was carried out in accordance with the planned inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS) for 2022.
ONR enforcement letter GEN71388R was issued to Energy Nuclear Generation Limited (NGL) on the 10 January 2020 due to concerns that NGL were placing excess reliance on Pressure Systems Safety Regulation 2000 (PSSR) related examinations to provide a demonstration that they are fulfilling their obligations under Licence Condition 28 (LC28). Enforcement actions required NGL to demonstrate that identified LC28 gaps were appropriately mitigated until closure and that its arrangements provided assurance that no further LC28 gaps existed due to over-reliance of PSSR activities.
ONR enforcement letter GEN71405R was issued to NGL on the 16 December 2020 as a result of shortfalls to compliance with Regulation 9 of the PSSR. In summary, enforcement actions required NGL to review full PSSR compliance across the fleet and evaluate its PSSR management arrangements to support sustained compliance.
NGL has undertaken a fleet co-ordinated programme of work including station evaluation and remediation activities and revisions to overarching management arrangements which are considered to address the above enforcement actions in totality.
The purpose of this intervention was to confirm the adequacy of the work conducted to comply with the requirements of Licence Condition 28, examination, inspection, maintenance and testing and compliance against PSSR.
Interventions Carried Out by ONR
The ONR inspection team comprised of a structural integrity specialist inspector and Operating Facilities’ Operating Reactors sub-division head of assessment.
The inspection team reviewed station activities undertaken to address enforcement action including; station management arrangements to ensure ongoing compliance, review of training activities for key PSSR stakeholders, sampling of LC28/PSSR compliance of the auxiliary steam system and examination of work management arrangements.
The inspection was rated against Licence Condition 28 (examination, inspection, maintenance and testing).
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The licensee has undertaken an appropriate review of LC28 activities which may have potentially relied on PSSR related inspection and have found no reliance. I was content that the approach adopted to review its activities was reasonable. The licensee also demonstrated that it has taken appropriate actions to take learning from operational experience to enhance LC28 inspection scopes.
PSSR shortfalls exist for the sampled auxiliary steam system, for this a risk assessment had been conducted and I am content with the licensee’s mitigations and plans to return to compliance.
As a result of the licensee’s recent efforts to undertake a 100% review of its written schemes of examination (WSE), specified by ONR enforcement letter GEN71405R, in total 30 out of 93 WSEs were identified with PSSR shortfalls. I was content that the licensee had a reasonable understanding of the immediate threats to enable continued operation, however, I have requested further demonstration of risks and plans to return to compliance at the earliest opportunity.
Given the elapsed time since ONR enforcement in December 2020 it is unacceptable for the licensee to have identified this significant number of PSSR shortfalls and to have remained unaware of the potential risks associated with these shortfalls.
Conclusion of Intervention
I am content that the licensee has demonstrated that actions specific to ONR’s enforcement letter GEN71388R relating to LC28 over reliance on PSSR activities are appropriate.
The licensee has been unable to demonstrate compliance to PSSR and in areas of non-compliance were unable to demonstrate a comprehensive understanding of the threat posed by these systems and how compliance would be returned at the earliest opportunity. I have identified recommendations for the licensee to provide evidence to demonstrate how they may address these concerns.
The licensee falls short of where I would have expected it to be at this stage following previous ONR engagement in relation to ONR enforcement letter GEN71405R. Consequently, I am not satisfied that sufficient evidence has been provided to close actions raised via Regulatory Issue 8462.
Based on the evidence sampled, I do not consider that adequate progress has been made to address the shortfalls identified. I judge that the licensee has failed to adequately deliver improvements previously identified in enforcement communication. Therefore, I consider that an ONR inspection rating of RED – Demand Improvement is appropriate.
I will apply the Enforcement Management Model (EMM) to determine the most appropriate enforcement action. Further engagement on this matter and judgements will be captured in the enforcement decision record and will take forward the recommendations made within this intervention record.