Office for Nuclear Regulation

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LC17 - Independent Nuclear Assurance Surveillance - Safety Culture

Executive summary

Purpose of Intervention

The purpose of this intervention was to conduct licence condition (LC) compliance inspections at EDF Energy Nuclear Generation Ltd’s (NGL) Dungeness B Power Station (DNB).  This intervention was undertaken as part of a series of planned interventions that are listed in the DNB Integrated Intervention Strategy 2018/2019. 

Interventions Carried Out by ONR

As nominated Site Inspector my aim was both to support and to assess a safety culture surveillance by EDF’s Independent Nuclear Assurance (INA) at Dungeness B Power Station. Together with the ONR inspector for another station I joined an EDF team led by INA to carry out the surveillance, which comprised interviews, focus groups and evaluation of meetings and selected documents. I rated the surveillance for compliance with Nuclear Site Licence Condition 17 (LC17) – Management Systems with respect to INA’s assurance arrangements.

Our evaluation of the surveillance was informed by ONR guidance on LC17 and internal challenge functions (NS-INSP-GD-017 and ND-TAST-GD-080) available on the ONR website, and IAEA guidance on safety culture published on its website.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not Applicable – no system based inspections were completed during this intervention.

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

The surveillance was the second in a series that INA will carry out across all EDF NGL stations. Altogether the team interviewed over 115 staff.

The surveillance team concluded that although Dungeness displays many of the characteristics of a good safety culture, there are aspects that should be addressed directly and robustly as part of the site improvement plan being developed at present. These conclusions will be assigned to the station by INA as an ‘Area for Improvement’ (AFI), which requires a response under EDF NGL’s management system. This was accepted constructively by station management at the close-out meeting.

I concluded that this was an effective exercise of EDF NGL’s assurance arrangements under LC17.

Conclusion of Intervention

I found that the surveillance represented good practice as part of EDF’s management system and arrangements under LC17 and rated it ‘Green no formal action’. 

At present, no additional regulatory action is needed over and above the planned interventions at DNB Power Station. The matters relating to safety culture that were self-identified by EDF through the surveillance will be tracked by INA; ONR will be informed of progress through normal interactions.