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Dungeness B - Inspection ID: 52005

Date(s) of inspection:

  • November 2022

Aim of inspection

The aim of the inspection is to undertake a planned fire system based inspection to determine the adequacy of implementation of the Licensee’s claims associated with the fire detection, suppression and protection system to ensure fire (conventional and nuclear) risks are reduced as low as reasonably practicable. The inspection focussed on the Fuel Route areas given the station is shut down and will be focussing on defueling operations moving forward.

Subject(s) of inspection

  • LC10 - Training - Rating - Green
  • LC23 - Operating rules - Rating - Green
  • LC24 - Operating instructions - Rating - Green
  • LC27 - Safety mechanisms, devices and circuits - Rating - Green
  • LC28 - Examination, inspection, maintenance and testing - Rating - Green

Key findings, inspector's opinions and reasons for judgement made

In accordance with Office for Nuclear Regulation (ONR) and Operating Facilities Division (OFD) strategy a planned and combined System Based Inspection (SBI) and Life Fire Safety inspection was carried out at Dungeness B (DNB) in November 2022.

This inspection considered the nuclear fire safety risks associated with the Fuel Route and conventional fire safety risk associated with the Fuel Route and other areas.

ONR inspected EDF NGL’s compliance with arrangements made under the following Licence Conditions (LCs) and for the purpose of regulatory transparency the relevant guidance can be found below:

  • LC10 TRAINING NS-INSP-GD-010 Revision 3
  • LC 23 OPERATING RULES NS-INSP-GD-023 Revision 5
  • LC24 OPERATING INSTRUCTIONS NS-INSP-GD-024 Revision 5
  • LC 27 SAFETY MECHANISMS, DEVICES AND CIRCUITS NS-INSP-GD-027 Revision 6
  • LC 28 EXAMINATION, INSPECTION, MAINTENANCE AND TESTING NS-INSP-GD-028 Issue 8.1
ONR inspected EDF NGL’s compliance with arrangements made under the Regulatory Reform (Fire Safety) Order 2005 to form a judgement on their adequacy from the perspective of controlling risks from fire hazards:
  • Fire Safety Order 2005 – I sampled fire risk assessments for the fuel route and other areas on site. Based on the discussions, explanations and the evidence sampled during the inspection, I considered the arrangements made under the Regulatory Reform (Fire Safety) Order 2005 were adequate. Overall, I judge that EDF NGL is adequately implementing its arrangements from the perspective of life fire safety and award a Green rating.
  • LC10 – I sampled training records for several roles relevant to fire hazards and compared these with the role profile requirements. Based on my sample, EDF NGL operators have either received the required fire training or in the process of completing their training (due to being new to role). Overall, I judge that EDF NGL is adequately implementing its training arrangements from the perspective of fire and award a Green rating.
  • LC23 – I sampled the technical specifications (Tech. Specs.) relating to fire (active and passive elements of the fire system). I was able to trace operational limits and conditions to relevant safety cases, and into more detailed surveillance and local instructions. I judge that EDF NGL is adequately implementing its arrangements with respect to operating rules relevant to fire, and award a Green rating
  • LC24 – I sampled several safety instructions and maintenance for the fire system. I am satisfied that the instructions clearly communicate the required actions that operators need to undertake in the safe execution of work. I judge EDF NGL is adequately implementing its arrangements with respect to instructions relevant to flooding and associated protection measures and award a Green rating.
  • LC27 – I sampled several elements of the fire detection and suppression system and saw evidence that the safety devices are available and routinely maintained. I judge EDF NGL is adequately implementing its arrangements with respect to safety devices, mechanisms and circuits relevant to fire, and award a Green rating.
  • LC28 – I sampled several areas of the fire system (including fire alarm, fire suppression and emergency lighting) to ensure EDF NGL were adequately implementing their maintenance activities. I judge that EDF NGL is adequately implementing its arrangements with respect to maintenance relevant to fire, and award a Green rating
Overall, I found that EDF NGL’s existing arrangements made under the inspected LCs are adequate for controlling risks related to fire hazards. On this basis I award EDF NGL a GREEN rating.

Conclusion

Overall, I found that EDF NGL’s existing arrangements made under the inspected LCs are adequate from the perspective of controlling fire hazards relevant to the Fuel Route and on this basis I award a Green rating. Overall, I found that EDF NGL’s existing arrangements made under the inspected provisions relevant to the Regulatory Reform (Fire Safety) Order 2005 are adequate from the perspective of Life Fire Safety management and on this basis I award a Green