Sizewell B - Licence Condition 7 inspection
- Site: Sizewell B
- IR number: 17-087
- Date: August 2017
- LC numbers: 7
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) Sizewell B power station, in line with the planned inspection programme of the Operating Facilities Operating Reactors sub-programme intervention plan for 2017/18.
Interventions Carried Out by ONR
During this intervention, we undertook a themed inspection on Organisational Learning, during which we measured compliance against the following Licence Condition:
- LC 7 - Incidents on the site
Also during this intervention I:
- Undertook a review of the system based inspection programme in advance of planning for the next 5 year cycle of inspections (2018-2023);
- Undertook a monthly review meeting with the station’s independent nuclear assurance evaluators;
- Met with a selection of Safety Representatives to discuss matters of health and safety in accordance with the requirements of Section 28(8) of the Health & Safety at Work (etc.) Act 1974.
Explanation of Judgement if Safety System Not Judged to be Adequate
No system inspection was undertaken during this intervention.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
This inspection was the third in a series of themed inspections intended to evaluate the effectiveness of NGL’s organisational learning across the operational reactor fleet.. This intervention evaluates how well each station learns lessons from internal and external sources in order to continuously improve leadership, organisational capability, safety decision making and safety performance
During the inspection, the following themes were examined:
- Investigation and action close-out,
- Communication of operating experience (OPEX),
- Benchmarking and self-assessment.
A number of positive areas were noted that will be reviewed following completion of ONR’s Fleet-wide Organisational Learning themed interventions when they may be identified as good practices:
- Following the 2015 OSART mission (IAEA’s operational safety assessment team), the station now requires that proposed root causes in significant adverse condition investigations (SACIs) are approved by the corrective action review board prior to submission of the SACI to ensure early scrutiny and minimise abortive work. This approach goes beyond the requirements set out in the company arrangements;
- The use of cognitive trending across various departments has greater visibility and alignment to company arrangements;
- It was evident through our discussions that Benchmarking is happening, with excellent local initiatives and international relationships with Penly and Callaway (and wider French fleet);
- We observed practice adopted from Penly (French PWR site) - targeted ‘must-know’ OPEX for forthcoming outage. We see this as good practice, an excellent example of benchmarking being put into practice with real value.
- The development of ‘Snatch Packs’ which will include relevant Operating Experience (OPEX) briefs under various headings was being developed in some departments. A particularly good example was the Maintenance Group Head, where OPEX was provided broken down into task activities for ease of use.
There were several areas in which we noted required further work but did not merit raising a regulatory issue:
- There is a need for the station to improve quality and consistency with which trend analysis is undertaken across departments and to realise the benefits from trending in the longer term having noted there is no obvious station management level oversight of these trend review boards. It was not always clear however if departmental information gleaned from such sources was presented for the wider station benefit.
- The level of engagement with international PWR (pressurised water reactor) benchmarking was variable and seemed to depend upon to some extent on individual French contacts. The station would benefit from a more holistic strategy for benchmarking to support organisational learning;
- Use of the Organisational Learning Portal appears to be inconsistent and not necessarily in line with the company arrangements Usage appears to be based on individual preference and is not routinely used by all individuals that we spoke to.
One regulatory issue has been raised at Level 4 through which to monitor improvements in timeliness and quality of investigations and action-close out. Timeliness of investigation and CAP action close-out and Quality of CAP actions continues to be a challenge at Sizewell B (outwith the timescales set out within company LC 7 compliance arrangements).
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 summary, we found that the station has made considerable efforts to respond to the 2015 OSART findings, specifically the need for more consistent and visible consideration for extent of condition in investigations. A number of good practices were found that will be disseminated by the ONR Corporate Inspector as part of the fleet wide theme inspection (listed below). One Level 4 regulatory issue has been raised through which the station’s progress towards improving quality and timeliness of investigations and action close-out. Suggested areas for improvement relating to benchmarking, use of the organisational learning portal and consistency in trending have also been made which will not be subject to specific regulatory follow-up.
I consider that, based on the evidence acquired during this intervention, that an inspection rating of Green is appropriate for LC 7 (Incidents on the site).