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Dungeness B - LC32 inspection

  • Site: Dungeness B
  • IR number: 19-006
  • Date: April 2019
  • LC numbers: 32

Executive summary

Purpose of Intervention

This was a planned intervention at Dungeness B Power Station, operated by EDF Energy Nuclear Generation Limited (EDF NGL) in accordance with ONR’s Intervention Plan for the site. 

The intervention was carried out to assess EDF NGL’s compliance with Licence Condition (LC) 32 (accumulation of radioactive waste).  This is a follow-up inspection based on the findings of a previous inspection carried out in July 2018 (ONR-OFD-IR-18-80) and subsequent enforcement letter (ENF-EL-010 DNB7137R). 

The intervention was carried out jointly with the Environment Agency (EA)

In addition to the above, the nominated site inspector also undertook routine engagements with the station.

Interventions Carried Out by ONR

The intervention focused on the licensee’s arrangements and their implementation for compliance against LC32, including progress to address regulatory issues 5113, 6544 and 6986.  The following ONR guidance was used as the basis for the inspection:

  • LC32 Accumulation of Radioactive Waste Technical Inspection Guide (NS-INSP-GD-032, Revision 4, July 2016)

The nominated site inspector undertook the following activities:

  • Followed up of reported events to ONR
  • Held engagement meetings supported by the ONR Delivery Lead for  Operating Reactors sub-division with the senior site management team
  • Undertook a plant visit of the station’s corrosion recovery activities

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The focus of the LC32 compliance inspection was the Licensee’s progress in delivering the improvement plan and progress towards addressing the shortfalls captured in previously raised regulatory issues and the associated enforcement letter. 

I noted significant improvements in the general housekeeping and waste storage arrangements within the old decontamination and laundry yards; I have elected to monitor this progress of regulatory issue 6986 for a period of time until a sustained period of compliance is maintained.

I sampled the arrangements for temporary laydown areas, which have been implemented to address regulatory issue 6544.  Based on the evidence sampled, I consider that this regulatory issue can be closed.

In relation to regulatory issue 5113, I sampled progress against the radioactive waste management plan.  The programme of disposals was being delivered to plan and a new radioactive waste inventory system (CRADLE) has now been implemented. The resources to support radioactive waste processing were being made available and plans to ensure this is sustainable long-term have been developed. During the walk-down of the facilities, I observed visible improvements to the Decontamination Centre.  However, improvements to other waste storage areas are still required.  The station needs to maintain the focus on delivering the action plan and demonstrate that the changes implemented are sustainable. 

Based on the evidence sampled I judge that good progress to address the shortfalls has been made since my previous inspection in July 2018.  However, further improvements to the radioactive waste storage and processing areas are still required to meet relevant good practise.  The planned programme of disposals needs to continue to remove the backlog of radioactive waste and the station needs to demonstrate that the changes implemented are sustainable and embedded within routine operations.  I will continue to monitor the station’s progress to deliver the radioactive waste management plan and achieve sustained compliance via the extant regulatory issues remaining.  I judge that an AMBER rating is appropriate.

Conclusion of Intervention

From the evidence gathered during this inspection, it was judged that there were no matters that have the potential to impact significantly on nuclear safety.  A follow-up inspection will be carried out to ascertain the progress made in addressing the remaining extant regulatory issues and to provide evidence that the improvements made to date are sustainable.