Executive summary
- Date(s) of inspection: October 2024
Aim of inspection
The purpose of this inspection was to examine EDF NGL's arrangements for control and supervision of work activities to ensure safety, specifically NGL’s field supervision arrangements and the role of the field supervisor. The inspection was undertaken against Licence Condition (LC) 26 and The Construction (Design and Management) Regulations 2015 and took place on 08 to 09 October 2024 at EDF Energy Nuclear Generation’s (NGL’s) Dungeness B (DNB) Power Station.
Subject(s) of inspection
- CDM 15 - Rating: Green
- LC26 - Control and supervision of operations - Rating: Green
- MHSWR - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
This inspection targeted the application of the licensee’s LC 26 and CDM 2015 arrangements for the management of contractors, targeting specifically the arrangements as applied to field supervision (including the role of the field supervisor). We sampled evidence of the adequacy of these arrangements and evidence of the adequacy of their implementation.
The inspection comprised a review of relevant documentation supplied by EDF NGL in advance of, and during, the inspection plus group discussions with members of the DNB management of contractors team, project teams, field supervisors, and relevant contractors.
An ONR team comprising specialist inspectors and the DNB site inspector carried out the inspection. The inspection was undertaken in person at DNB.
No significant matters were identified as requiring additional regulatory attention. The EDF NGL Dungeness B team demonstrated compliance with the extant fleet LC 26 compliance arrangements and requirements of CDM 2015 (for project delivery function). I identified a number of areas to follow up with the fleet field supervision process owner and the fleet industrial safety process owner. These areas related to the approach to the review of contractor Risk Assessment Method Statements (RAMS) and the need for greater alignment between the field supervision arrangements and other linked arrangements such as industrial safety, CDM 2015 and intelligent customer.
Conclusion
Based on my sampling undertaken during this intervention, I consider that the licensee has adequately demonstrated it has implemented the fleet LC 26 arrangements and its project delivery arrangements are compliant with CDM 2015. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection ratings of GREEN for LC 26 and GREEN for CDM 2015 are merited here. However, during the inspection I identified a number of shortfalls in the extant fleet field supervision arrangements relating to the links with other supporting NGL arrangements, and I have accordingly raised a Level 4 Regulatory Issue (lowest level) on the relevant Fleet Process Owner (See - RI-12290) to address these shortfalls. This Regulatory Issue is now tracked on the Regulatory Issue Database and will be followed up as part of normal business.