Date(s) of inspection:
- January 2023
Aim of inspection
The inspection will primarily seek assurance that station conventional health and safety (CHS) capability is suitable for the current defueling/deconstruction phase of activity.
Subject(s) of inspection
- MHSWR – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Hunterston B (HNB) power station, undertaken as part of the intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR). The work was carried out in accordance with the planned inspection programme contained in the HNB Integrated Intervention Strategy (IIS) for 2022/23.
The inspection was conducted to provide regulatory confidence in HNBs conventional health and safety (CHS) resource and capability. The inspection was conducted over two days and an inspection agenda was prepared and shared with the station prior to the inspection.
The key regulatory activities undertaken were focussed primarily on determining station compliance with the health and safety assistance requirements of Regulation 7 of the Management of Health and Safety at Work Regulations 1999 (MHSW). The inspection also sought an update on aspects of the stations management of asbestos and progress with fixed plant guarding work.
The inspection involved discussions with NGL staff and Trade Union Safety Representatives. ONR conducted site walk-downs accompanied by relevant station personnel and sampled associated records, followed by further remote correspondence reviewing additional documents provided by the station after the site visit.
The station provided an overview of their current CHS safety resource with the station having two qualified industrial safety engineers (ISE) working within normal operations along with a qualified construction health and safety advisor working within the Transfer & Deconstruction (T&D) team. The stations experience so far during their defueling work phase has been that this arrangement has been sufficient in providing adequate CHS assistance.
The T&D team have responsibility for the planning and delivery of the construction projects required for station defueling/early deconstruction and beyond into site transfer and deconstruction. They continue to review their CHS construction capability requirements as this work ramps up. The T&D team have appointed a health, safety, environment and quality (HSEQ) lead to coordinate compliance arrangements and are rolling out identified additional CHS training to enhance the teams overall CHS capability. The two station ISE also have construction experience and are likely to assist T&D if necessary.
The stations Technical and Safety Support Manager (TSSM) reported that the station currently has good CHS support from the NGL central CHS company safety advisors (CSA).
I was content with the CHS capability sampled but provided verbal advice on the need for the T&D team to continue to monitor CHS resource and capability requirements, particularly as construction work ramps up prior to the start of the deconstruction phase in 2025. The station has an ambitious time scale for project delivery and they will need to ensure they have the necessary CHS resource available.
I provided verbal advice that both the TSSM and Quality Management Group Head (QMGH) should complete the performance/preferred CHS training elements of their post training profiles (PTPs). These are not essential requirements of their PTP but will help station CHS resilience and self sufficiency. I also provided verbal advice that the HSEQ lead within the T&D team should complete a suitable CHS construction training course.
The prime purpose of the intervention was for the Office for Nuclear Regulation (ONR) to determine whether the station currently has sufficient CHS resource with suitable competent persons available to assist in undertaking measures needed to comply with the requirements of relevant statutory provisions. Based on the evidence sampled during the inspection I was satisfied that EDF NGL HNB currently has sufficient CHS competent persons available and the inspection is rated green.
The station are working to complete their fixed plant guarding programme and have made good progress but this work needs to be finished. I asked the station to provide a written update setting out the current position. I was content with progress on asbestos management.