Office for Nuclear Regulation

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Dungeness B - LC28 Planned Compliance Inspection

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake Licence Condition (LC) compliance inspections at EDF Energy Nuclear Generation Ltd's (NGL's) Dungeness B power station, in line with the planned inspection programme contained in the Dungeness B Integrated Intervention (IIS) plan for 2016/17.

Interventions Carried Out by ONR

This intervention included a compliance inspection against Licence Condition 28 - Examination, Inspection, Maintenance and Testing, focussed around delivery of safety engineering improvements resulting from system health and equipment reliability reviews.

I also undertook a number of engagements with the licensee representatives, which covered the following topics:

Explanation of Judgement if Safety System Not Judged to be Adequate

No system based inspection undertaken hence, not applicable.

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

I undertook a planned intervention against LC 28, during which I:

Examined the station's ability to utilise system health and equipment reliability information to inform engineering improvements, focusing on the management and oversight of the 'small schemes' portfolio of work.

Found that the investment areas are being informed by the system engineering. The investment areas are being prioritised but this is limited to the strength of the case being brought forward by the engineering group heads. Based upon the evidence, I am of the opinion there is no systematic approach to prioritising equipment reliability investment and the decisions not to invest on items below the line are not captured sufficiently.

Sampled the equipment reliability reviews and found it difficult to find linkage between the reviews and the investment areas listed in the small schemes.

No significant shortfalls were identified; a number of observations were made and communicated to the licensee. A regulatory issue has been raised requesting to station to establish a systematic approach to prioritisation and risk management.

I held a meeting with the outage coordinator and outage group head to obtain an update on the outage scope and preparations. In summary, the outage team recognise improvement in outage arrangements is required, in particular governance and oversight of outage performance and improved integration of outage activities within normal business.

I obtained information on a recent event relating to a flask consignment. The station is investigating and engaging with Sellafield Limited to gather the facts. ONR is considering what follow-up is warranted and will monitor the progress of the investigation.

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

Conclusion of Intervention

In relation to LC28, I judged that an inspection rating of Green (no formal action) is warranted on the basis that the investment areas are being informed by the system engineering. The investment areas are being prioritised but the prioritisation process is lacking a systematic approach. A systematic approach would improve the visibility of decision making and consideration of emergent work through change control. It would also enable the station to demonstrate due priority is given to nuclear safety with respect to equipment reliability investment. A level 4 regulatory issue has been raised to address this minor shortfall.

There are no findings from this inspection that could significantly undermine nuclear safety.