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Licence Condition 32 compliance inspection and Annual Review of Safety

  • Site: Dungeness B
  • IR number: 21-109
  • Date: November 2021
  • LC numbers: 32

Executive summary

Purpose of Intervention

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

Interventions Carried Out by ONR

A team from ONR attended the Dungeness B Annual Review of Safety, Security and Environment (ARoSSE).

I carried out a compliance inspection of Licence Condition 32 (Accumulation of radioactive waste), focused on the status of radioactive waste management at Dungeness B following the successful closure of Regulatory Issue 5113 in November 2019.

In addition I had a number of routine interactions with station management.

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

The ARoSSE comprised presentations on progress in a number of areas by the station to ONR and Environment Agency (EA) inspectors. I was satisfied that this was a fair reflection and represented a good standard of self-awareness and organisational learning.

From the compliance inspection I consider the station’s arrangements for compliance with Licence Condition 32 to be adequate. I sampled the implementation of arrangements for minimising accumulations of radioactive waste generated on the site and for recording the waste so accumulated. Overall, I found that the radioactive waste is being managed in accordance with regulatory expectations and the station is delivering against its radioactive waste management plan. The station recognises the importance of maintaining its current performance and the environmental safety group is planning to reinvigorate engagement with operational teams to reinforce good radioactive waste management behaviours and practice.

There remain areas where the arrangements could be strengthened to support and cultivate a waste led culture, which will help to maintain compliance with Licence Condition 32. This is particularly important now that the station has stopped generating.

I encouraged the station to improve the interfaces between its asset registers, lifetime asset management plans and radioactive waste inventory. This should provide enhanced understanding of when assets will become redundant and enable appropriate planning for their management when they are declared waste.

Conclusion of Intervention

From the evidence sampled, I concluded that implementation of EDF’s arrangements for minimising the accumulation of radioactive waste on the station, and for recording the waste so accumulated, to be adequate.