- Site: Dungeness B
- IR number: 21-048
- Date: July 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This was a planned intervention to provide regulatory confidence in the management of conventional health and safety (CHS) hazards associated with two high risk areas: work at height and control of substances hazardous to health (COSHH) at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B (DNB) power station.
The intervention was carried out in-line with the planned inspection programme contained in the ONR DNB Integrated Intervention Strategy (IIS) 2021-2022.
Interventions Carried Out by ONR
This intervention was carried out by two ONR Nuclear Internal Hazards and Site Safety specialist inspectors and the ONR recovery site inspector on 7 and 8 July. An agenda was prepared for the intervention and shared with NGL before the intervention.
During the site visit, ONR inspectors strictly adhered with control measures outlined within ONR-GEN-GD-022 (Visit to licensee and other duty-holder premises and other relevant locations during the COVID-19 pandemic) and the local COVID-secure control measures at DNB.
The intervention comprised:
- discussions with NGL DNB staff, contractors, and a Trade Union safety representative;
- site walk-down accompanied by NGL DNB staff and contractors;
- sampling of documents and records; and
- further email correspondence after the site visit with NGL DNB seeking clarification on documents and records.
Regulatory advice and judgement were based on determining compliance with sections 2 and 3 of the Health and Safety at Work etc. Act 1974 and the relevant statutory provisions made under the Act including Work at Height Regulations 2005, Management of Health and Safety at Work Regulations 1999, Control of Substances Hazardous to Health Regulations 2002. I also consulted the relevant good practice such as the Approved Code of Practice and guidance L5 for COSHH and HSG53 a practical guide for respiratory protective equipment at work.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
In addition to the planned CHS intervention, the ONR recovery site inspector carried out engagements related to performance improvement plans at the station from 6 to 8 July.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Whilst on site, ONR inspectors observed and followed the COVID-19 workplace control measures that NGL had put in place including testing arrangements before attending site, use of facemasks, hand-sanitising and cleaning regimes in buildings, social distancing. The arrangements put in place at DNB were considered to be adequate.
The inspectors noted an area of good practice, which was that DNB had developed and was using a roof register that contained sufficient information for work on each of the roofs (more than 200 in total) to be planned safely.
Whilst NGL’s arrangements in managing work at height and COSHH met ONR’s regulatory expectations, there were minor shortfalls identified against COHH requirements in relation to a painting task that required improvements.
Conclusion of Intervention
Based on the samples observed and examined, ONR inspectors were satisfied that NGL demonstrated adequate management of hazards and risks associated with work at height and COSHH against relevant good practice. As a result, an intervention rating of Green (no formal action) was allocated for each of those topics. A Level 4 Regulatory Issue has been raised to track NGL’s progress in addressing the minor shortfalls against COSHH requirements. ONR will follow this up as part of routine engagements with NGL.