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Compliance inspections of LC 9 (Instructions to persons on site), LC10 (Training) and routine engagements

  • Site: Dungeness B
  • IR number: 21-040
  • Date: June 2021
  • LC numbers: 9, 10

Executive summary

Purpose of Intervention

This was a planned compliance inspection of licence condition 11 (Emergency arrangements) at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B power station. It was undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).

The work was carried out in-line with the planned inspection programme contained in the Dungeness B Integrated Intervention Strategy (IIS) 2021-2022.

Interventions Carried Out by ONR

During this intervention, the following activities were undertaken:

  • LC9 and 10 compliance inspections
  • Observed the Station’s Level 1 Emergency exercise demonstration.
  • Undertook a meeting with the station’s Safety Representatives
  • Observed the station’s weekly site excellence tour
  • Plant visit (intelligence gathering)

During this inspection undertook intelligence gathering in the form of a follow up visit to the contract partners stores, I also held a monthly meeting with the station’s safety representatives, held discussions with senior managers, the station director and observed a site excellence tour of the turbine hall and the essential diesel generators .

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

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

The ONR site inspector observed

For the LC9 compliance inspection, I noted positive feedback from those individuals I interviewed who had either undertaken the unescorted site access training on line or had been provided instructions from the station who was escorting them during their station visit, From my sampled inspection of the station’s arrangements, I have rated this compliance inspection as Green.

During my LC9 compliance inspection, I elected to sample several workorder cards (WOC’s) that were active for painting work that was being undertaken. I noted that dates had been Tippexed out used in order to correct the WOC’s original issue date, I also identified within one WOC that the required Maintenance Instruction (MI) hold points had not been signed off and that work had continued to be progressed without the formal hold points having been completed. Considering the minor procedural use and adherence (PU&A) shortfalls, I have raised a regulatory issue to track the station’s progress in addressing the actions I have raised.

For the LC10 compliance inspection, I observed three training courses which were either delivered online via Skype or physically at the station. I also sample several station staff role profiles and their essential training requirements to meet the role requirements. Of those sampled I noted that one individual was still awaiting to complete role elements, consequently, the individual was being mentored whilst awaiting to complete their role profile training requirements. From my sampled inspection, I have rated this compliance inspection as Green.

During my station visit, I inspected the contract partners stores and the station’s arrangements for controlled access. My previous site inspection in April identified several areas which required urgent attention. The station’s controlled access to the facility is now limited to the removal of stored items which are being relocated to an alternative storage facility. The store is to be demolish within the next few months. I also held discussions with the station’s Safety Representatives, attended a site excellence tour and held an update meeting with the station director.

Conclusion of Intervention

In relation to LC9 and 10 compliance inspections I have rated them as Green.  In considering the minor PU&A shortfalls, I have elected to raise a regulatory issue to track the station’s progress in addressing the regulatory actions I have raised. No further regulatory intervention is required.