Dungeness B - Inspection Week - Theme 1
- Site: Dungeness B
- IR number: 17-038
- Date: June 2017
- LC numbers: 12, 23, 24, 25, 26, 27, 28
Purpose of Intervention
This was a planned inspection at EDF Energy Nuclear Generation Ltd’s (NGL’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).
The work was carried out in-line with the planned inspection programme contained in the Dungeness B Integrated Intervention Strategy (IIS).
Interventions Carried Out by ONR
During this intervention, the following key activities were undertaken:
- Themed inspection examining control and supervision of operations and maintenance.
- Quarterly update on regulatory issues.
- Meeting with Independent Nuclear Assurance (INA).
- Routine engagement with senior leadership team, including plant walk-down of Fuel Route process and facilities.
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
We evaluated compliance against the following site licence conditions during our themed intervention:
- Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons) - We sampled training records of individuals performing the duties which may affect safety and judged that demonstrated staff were suitably qualified and experienced. We sampled the training records of duly authorised persons controlling and supervising operations and found their training records supporting the appointments to be up to date. The station presented information on succession planning, which focused on future retirements. The station recognises the need to extend this succession planning to address future vulnerabilities. We therefore assigned a rating of Green (no formal action) for LC12 compliance.
- Licence Condition 23 (Operating rules) - We sampled control room tracking logs, operating instructions and observed plant release. Based upon the evidence, the station demonstrated that operations were controlled and carried out in compliance with safety case limits and conditions. We therefore assigned a rating of Green (no formal action) for LC23 compliance.
- Licence Condition 24 (Operating instructions) - The work activities observed during the inspection were conducted in accordance with written instructions. We identified potential improvements to some of the operating instructions being used. NGL agreed to consider these points. ONR will monitor NGL’s progress via an existing regulatory issue seeking improvements in standards of procedural quality use and adherence at the Station. We have assigned a rating of Green (no formal action) for LC24 compliance.
- Licence Condition 25 (Operational records) - The sampled safety document records and safety case limits and conditions compliance records examined were found to be adequate. We therefore assigned a rating of Green (no formal action) for LC25 compliance.
- Licence Condition 26 (Control and supervision of operations) - We observed a number of work activities including the pre-job briefs and setting to work activities. In all cases the level of control and supervision was commensurate with the safety significance of the task. We also observed plant release through the DAP. We therefore assigned a rating of Green (no formal action) for LC26 compliance.
- Licence Condition 27 (Safety mechanisms, devices and circuits) - We sampled the availability of safety mechanisms, devices and circuits providing emergency electrical generation. We confirmed that the impact of a fault which had occurred on essential diesel generator 22 had been assessed in accordance with NGL’s own arrangements. We confirmed that sufficient electrical generational capacity remained available since the fault occurred meeting the requirements of the nuclear safety case. We therefore assigned a rating of Green (no formal action) for LC27 compliance.
- Licence Condition28 (Examination, inspection, maintenance and testing) - We sampled arrangements for planning and management of emergent maintenance activities. We found improved engineering and operations engagement at the daily work review meetings to ensure optimal prioritisation of emergent maintenance activities. We sampled a number of maintenance activities and concluded they were conducted by suitably qualified and experienced persons in accordance with written schemes and were subject to control and supervision commensurate with the nuclear safety significance of the task. We therefore assigned a rating of Green (no formal action) for LC28 compliance.
- MHSW Reg 5 (Health and safety arrangements) - We examined various elements of the work management and control of work processes. There was sufficient evidence that control arrangements were being considered during the work planning process. However, we did find that assumptions made during the work management planning process, on the availability of SQEP capability to undertake examination, inspection maintenance and testing, are often inaccurate. Hence, a level 4 regulatory issue has been raised on maintenance SQEP availability. We therefore assigned a rating of Green (no formal action).
I requested progress updates on a number of regulatory issues and engaged with the senior management team on forthcoming improvement initiatives and operational focus. No significant nuclear safety concerns were raised during these discussions.
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
The themed inspection examined compliance against LC12, LC23, LC24, LC25, LC26, LC27, LC28 and MHSW Reg 5. Overall, based on the evidence sampled, inspectors judged that legal requirements were met. We observed a number of work activities including the pre-job briefs and setting to work activities. In all cases the level of control and supervision was commensurate with the safety significance of the task. One minor compliance shortfall was identified relating to adequacy of assumptions made during the work planning process associated with availability of SQEP capability to deliver maintenance activities according to schedule. A level 4 regulatory issue was raised in order to monitor the agreed remedial action.