This was a planned inspection at EDF Energy Nuclear Generation Limited’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).
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
No system based inspection undertaken, hence not applicable.
The flask transport compliance inspection examined what actions have been taken and whether sufficient improvement has been made to address ONR’s enforcement actions following the flask processing event in May 2017.
During the plant walk down, significant improvements were observed. All actions to achieve compliance had been completed, with further enhancements planned.
A review of the revised documentation showed that the station’s management arrangements as required by Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations 2009 are suitable and sufficient. Completed compliance packs were sampled, checked and found to be comprehensive and complete in accordance with the revised documentation suite.
Training materials and delivery for flask operations were discussed, and the awareness of operators on the flask safety case and the Package Operations and Maintenance Manual (POMM) requirements has been addressed. We advised that refresher training would be beneficial in ensuring that a good level of knowledge on POMM and safety case requirements is maintained at the required standard.
During the LC6 inspection, a variety of records were sampled from the record schedule. The station successfully retrieved all records, however significant shortfalls against records management relevant good practice were observed specifically around record schedule completeness, indexing and recording practices.
The station recognises its current records management weaknesses, with an improvement plan in place to address known compliance shortfalls and enhance archiving arrangements. However, progress to date has been slow. We were informed that at present, the document centre has management commitment for the improvements and is sufficiently resourced.
Routine engagement was undertaken with the station and the independent nuclear assurance team to discuss operational performance including recent events. It was judged that the station is taking the appropriate action to management performance and the investigation of events. No significant nuclear safety concerns were raised during these discussions.
A meeting was held to conduct initial enquiries following an event involving corrosion of pipework supplying the Buffer Store Back Up Cooling Water. No further investigation has been judged to be warranted, due to no potential/actual harm, the station’s corrosion management intervention being already underway (addressing the compliance shortfall with LC28), and the dutyholder’s appropriate response to restoration and recovery of the pipework.
Discussions with the station leads were held, regarding progress against regulatory issues. The information received will be used to update ONR’s regulatory issues, no significant safety concerns were raised during these discussions and progress is being made.
Regarding Flask Transport compliance inspection, we judged that the station has taken appropriate action to address ONR’s findings through amendments to process documentation, equipment and training. Consequently, we have assigned an IIS rating of GREEN recommending closure of regulatory issue 5897.
The station’s capability to demonstrate compliance with the LC’s through effective records capture, management and retrieval was examined. Although the station was able to retrieve all of the documents requested, it was noted that significant shortfalls remain with regards to completeness of the record schedule. Furthermore, shortfalls were observed in general records management practices, such as record completion and missing information. Consequently, for LC6 compliance we have assigned an IIS rating of AMBER, and are seeking improvement through a regulatory issue.