Executive summary
Date(s) of inspection:
February 2025
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 12 to 13 February 2025 at EDF Energy Nuclear Generation’s (NGL’s) Heysham A (HYA) Power Station.
Subject(s) of inspection
- CDM 15 - Rating: Green
- LC26 - Control and supervision of operations - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This inspection focused on 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 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 HYA management of contractors team, project teams, field supervisors, and relevant contractors.
An ONR team comprising specialist inspectors and the HYA site inspector carried out the inspection. The inspection was undertaken in person at HYA.
No significant matters were identified as requiring additional regulatory attention. The EDF NGL HYA team demonstrated compliance with the extant fleet LC 26 compliance arrangements and requirements of CDM 2015. 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), the definition of a construction project (and therefore the applicability of CDM 2015) and the role of the field supervisor versus that of the work supervisor.
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 broadly 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 observations regarding the implementation of the extant fleet field supervision arrangements, and I have accordingly updated an existing Level 4 Regulatory Issue (lowest level) which is currently owned by the relevant Fleet Process Owner (See - RI-12290) to address these observations. This Regulatory Issue is already tracked on the Regulatory Issue Database and will continue to be followed up as part of normal business. I provided regulatory advice in relation to the definition of a construction project and the applicability of CDM 2015, this was accepted by the station and I will accordingly follow this up with the industrial safety process owner to ensure it is considered at a fleet level.