Executive summary
Date(s) of inspection: July 2024
Aim of inspection
This was a planned inspection of EDF's Dungeness B Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR). This inspection targeted the sites arrangements for complying with the Construction (Design and Management) Regulations 2015 (CDM). It focused on the defined duties of the regulations and how these roles were being carried out. With specific focus on the “client”, “principal designer”, and “principal contractor”.
Relevant good practice such as L153 (Managing health and safety in construction), HSG 150 (Health and safety in construction), and NS-INSP-GD-074 (Regulating CDM 2015) was used to assess compliance.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection centred around how EDF Nuclear Generation Limited (EDF NGL) carry out their duties in line with the Construction (Design and Management) Regulations 2015 (CDM) at Dungeness B. Where construction work takes place on site EDF NGL are the ‘Client’ they also appoint themselves as the ‘Principal Designer’ and ‘Principal Contractor’. Under CDM these roles have specific duties.
Construction is a priority area for site health and safety inspectors given the rise in construction work across licensees. The inspection at Dungeness was planned following a cable cutting event that took place during construction work in August 2023. It is also a key priority for ONR as two fatal incidents on licensed sites have taken place during construction processes since November 2022. For clarity these did not occur at EDF power stations.
The inspection assessed whether EDF NGL were carrying out their duties in line with the legal requirements. Clear improvements were noted within the pre-construction information produced by EDF NGL in their role as Principal Designer. They were also able to demonstrate that they were meeting key milestones within their CDM improvement plan.
The inspection was spread over two days and both days consisted of an office based discussion and a site walk-down. We also requested to attend a setting to work meeting on day two of the inspection.
I have raised a level 4 regulatory issue (RI12141) as EDF NGL were unable to adequately demonstrate that they are carrying out the role of principal contractor effectively. The purpose of this issue is to track the progress they are making in relation to this issue.
Conclusion
The site were able to demonstrate improvements have been made in how they carry out the role of principal designer, allowing appropriate pre-construction information to be made available. Pre-construction information provided highlighted known risks as well as highlighting how health and safety risks could be designed out.
However I have raised a level four regulatory issue (RI-12141). This will require the site to revise their CDM Improvement plan. The site need to address how the pre-construction information will be communicated to the principal contractor. In acting as the Principal Contractor EDF NGL need to capture the risks identified within the pre-construction information in their construction phase plan. They also need to ensure that construction phase plans are reviewed and updated, because currently there is no evidence that it is being used as a live document to manage health and safety risks associated with construction.
Based on my sample a green rating is appropriate.