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LC 28 (EMIT) Examination, inspection, maintenance and testing compliance inspection

  • Site: Dungeness B
  • IR number: 20-136
  • Date: March 2021
  • LC numbers: 28

Executive summary

Purpose of Intervention

This intervention was a planned LC28 (EMIT) Examination, inspection, maintenance and testing compliance inspection at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B power station. In addition, the follow-up of reported incidents, Intelligence gathering was also undertaken during the station visit.

Interventions Carried Out by ONR

This inspection was led by the DNB nominated site inspector and was observed by an ASN regulator as part of their secondment activities. The station visit consisted of the following:

  • An inspection of the station’s arrangements with regards to LC28 (EMIT) which focused on the station’s Water Spray Fire system (WSFS)
  • COVID 19 arrangements inspection and interviews
  • ONR issues review
  • Level 1 emergency Exercise demonstration discussion
  • Station plant Manager meeting

During this inspection I also undertook intelligence gathering in the form of a routine plant visit to the existing nitrogen injection system and the Dump water tank 22, I also held discussions with the Engie conventional safety representative and  a held a monthly  meeting with the station’s safety representatives. I also observed a site excellence tour of the Main Cooling Water Pump House and Drum Screen area.

Explanation of Judgement if Safety System Not Judged to be Adequate

No system-based inspection was undertaken during this visit.  

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

This compliance inspection was undertaken in 4 parts, this consisted of three skype remote inspection meetings followed by onsite inspection.

The areas covered in this inspection were:

  • PMS & maintenance arrangements for the WSFS
  • A demonstration that EIMT has been completed within the stated timescales.
  • A demonstrate that EIMT has been carried out in accordance with licensee maintenance instructions.
  • Examination of a sample of reported defects and follow up actions 
  • Example of the Suitably Qualified and Experienced Persons (SQEPs) who undertake maintenance work on the system (Channel Fire)
  • A sampled walkdown of WSFS system
  • Discussions with relevant station staff.

From my planned inspection of LC28, the station provided sufficient evidence to demonstrate that it was complying with its arrangements in the above areas sampled. I did identify some very minor shortfalls which the station address during my visit. Considering my overall observations, I have rated this inspection as Green.

During my station visit, I inspected the station’s COVID 19 arrangements I identified several areas within a messroom area where the  COVID 19 arrangements could be further improved, in my opinion there has been a lapse in standards and expectations.  However, I am content that the station will address the observations I have made.

I followed up on a reported incident regarding a safety case anomaly, the station is to address the shortfall identified, I have therefore raised a regulatory issue to follow the station’s progress in addressing this gap.

I observed the station’s site excellence tour of the main cooling water pumphouse, I raised several observations regarding housekeeping standards and the number of defect tags associated with corrosion. The station acknowledged that the housekeeping standards were not consistent with its expectation and will address all the observations made as part of its site excellence tour arrangements.

Conclusion of Intervention

For the LC28 compliance inspection I have rated this as green, I have raised a single regulatory issue concerning a safety case shortfall, my inspection of the  COVID 19 arrangements of a contract partner at the station  did not identify  any significant issues but a drop in standards was noted which the station will address. My inspection did not identify any other significant issues that warranted any further follow-up.