Dungeness B Licence condition 36 compliance Inspection focussed on Fatigue Management and Working Time Directive
- Site: Dungeness B
- IR number: 17-067
- Date: July 2017
- LC numbers: 36
Purpose of Intervention
This was a planned inspection at EDF Energy Nuclear Generation Ltd's (NGL's) Dungeness B power station. It was 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:
- Licence Condition (LC) 36 compliance inspection, focused on fatigue management.
- Meeting with Independent Nuclear Assurance (INA).
- Routine engagement with Technical Safety Support Manager and discussions held with the Emergency Planning team.
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 LC36, focusing on fatigue management, during which I found the following:
- The working time regulations 1998 (as amended) lay down the minimum legal requirements on how to organise working time. However, it is not sufficient to rely solely on these regulations to ensure the duty, so far as it is reasonably practicable, to protect the health, safety and welfare at work of all employees, is met. In support of these regulations relevant good practice provides guidance on how an employer can assess and manage the risks associated with shift work.
- I confirmed the licensee has been monitoring working time non-compliance and have mapped actual against planned hours from January 2015 to date, indicating key work activities such as refuelling and outages. The station has recently completed a working time deep dive audit. I am of the opinion this demonstrates management of working time by the station and leadership commitment in this area.
- I discussed fatigue management with a number of team leaders. I found they had a good understanding of signs of fatigue and what controls are available to manage worker fatigue.
- I sampled a number of completed working time risk assessments for both EDF NGL and its contract partners. I found that working time risk assessments were being raised in a timely manner. However, the quality of the risk assessments that have been completed by the licensee was poor and not in line with NGL's corporate arrangements as defined.
- The basis of decisions to extend working hours was discussed with the relevant team leaders and in the majority of cases an As Low As Reasonably Practicable decision was presented.
- No significant shortfalls were identified, but a minor failure to implement the licensee's compliance arrangements was identified. An ONR regulatory issue has been raised requesting to station to establish a systematic approach to prioritisation and risk management.
I undertook routine engagement with the station and the independent nuclear assurance team to discuss outage and station performance including recent events. I judge that the station is taking the appropriate action to management performance and investigate events. 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
In relation to LC36 compliance inspection - fatigue management, I judge no formal action is required. Although there is a good level of understanding regarding fatigue management across the station and evidence of management working time, I judge there is a minor failure to implement licensee's compliance arrangements relating to completion of working time risk assessments. I have raised a regulatory issue requesting the station to improve the quality of working time risk assessments.