Office for Nuclear Regulation

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Compliance Inspection of LC17

Executive summary

Purpose of intervention

This was a planned inspection of the Management Systems (MS’s) and Quality Assurance (QA) arrangements being applied for the 2015 R22 018 statutory outage at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B (DNB) nuclear licensed site.

Interventions Carried Out by ONR

I carried out a planned compliance inspection against Licence Condition (LC17) ‘Management Systems’ & Quality Assurance Arrangements This focussed on a review of the adequacy of the outage arrangements with a focus on the oversight activities of station Quality Assurance and the Independent Nuclear Assessment (INA) groups. This intervention also included; supply chain activities, procedural use and adherence and licensee oversight of suppliers.   

Explanation of Judgement if Safety System Not Judged to be Adequate

Based on this intervention I judged the outage management systems to be adequate.

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

I found that DNB’s compliance with LC17 Management Systems for the areas inspected is adequate (IIS Rating 3) and consistent with relevant procedures.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

I discussed the approach to quality surveillances for the outage and concluded that the programme is risk and intelligence driven and adequately resourced. Contract Partners also have their own surveillance schedules that are discussed at the Quality Forum meetings. Overall, I judged that surveillance planning and resourcing is adequate.

I noted that pre outage readiness audits and concurrence is undertaken on the DNB station outage scope of work and a sample of their contractors. Findings found were being tracked to completion on the NGL action tracking system. I was satisfied that this is consistent with the outage quality arrangements. I discussed the INA ‘concurrence plan’ and the “rapid trending review” for the outage and noted that the activities are compatible with ONR’s outage quality management system review. Overall, I was satisfied that the concurrence process was being followed.

I noted that there is a standard approach to conducting quality audits and surveillances that promotes consistency. Issues arising from surveillances are captured to inform management thus enabling improvement actions and focus on future audits and formal surveillances. I observed a surveillance undertaken by the Turbine Support Group (TSG) and was satisfied that this was consistent with arrangements. Overall, I was satisfied that there was an adequate approach to audit and surveillances.

I observed the weekly Quality Forum (QF) and noted good attendance and participation from attendees with good use of samples and pictures of poor quality. Station management attend the quality forum on occasion.

I sampled supply chain activities which follow normal business processes for; procurement, contract management and item stores requirements. I am satisfied that that processes are being followed with comprehensive supplier SQEP (suitably qualified experienced persons) files being maintained for direct contract suppliers and their sub-contractors. 

I witnessed Procedural Use and Adherence (PU&A) in action at the work face and found a mixed picture on work control documents. I was informed that PU&A improvements are part way down a journey to being implemented fully and that the 13 week programme and outage work had been targeted. I consider that more focus is required by management to accelerate application of PU&A improvements to enable contract suppliers to understand NGL’s requirements and in ensuring work control documents identify usage codes.

I have raised five actions which are recorded in this report for DNB to provide clarity and action to resolve. Adequate responses have been received which will be followed up in subsequent visits or by correspondence.

Conclusion of Intervention

I was satisfied from the activities I examined that the LC17 Management Systems and the internal independent oversight arrangements along with their implementation for the DNB statutory outage are adequate and consistent with the relevant procedures. For the areas inspected, DNB’s compliance with LC17 Management Systems for the outage is judged to be adequate (IIS Rating 3). I have not raised any actions that need to be completed prior to the reactor R22 start-up permissioning point.