Office for Nuclear Regulation

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Dungeness B - Observation of Level 1 shift exercise demonstration and routine engagements

Executive summary

Purpose of Intervention

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).

Interventions Carried out by ONR

During this intervention, the following key activities were undertaken:

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

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 observed the Level 1 shift exercise demonstration, the scenario (Pathfinder) was a nuclear emergency that was initiated by a seismic event which required the use of deployable backup equipment (DBUE). My observation of this exercise was undertaken as a precursor to the stations partial re-demonstration level 1 exercise that is due to take place on the 3 December 2019.  This inspection examined the training element of the stations LC11 (6) arrangements for emergency planning at the station. I observed a much improved performance with respect to the DBUE with a more cohesive team response and use of improved instruction sheets   However, there were some areas that the station is fully aware of where further improvements can be made. The station is confident that all the necessary arrangements will be in place for   its partial re-demonstration to ONR in December. Overall, the station’s arrangements for LC11 (6) meet legal requirements, I have therefore rated this inspection as ‘Green’, no further regulatory intervention is required.

I undertook a reactive compliance inspection for LC12 where I observed the feedback provided by a re-authorisation panel to a shift manager who was taking part in the shift exercise I observed. The feedback was constructive and open, significant feedback from the shift manager and from the re-authorisation panel was observed in terms of performance and decision making rational. From my observations of this re-authorisation process, I was content that the re-authorisation process was challenging and robust. In light my observations of this process  I have therefore rated this as Green no further regulatory intervention is required

I continued with my follow-up of the shortfalls that I observed during my previous inspection regarding the licensee’s and contract partners DSEAR arrangements. I found significant improvements in all the areas concerned.

During my station visit I observed a site excellence tour of the turbine hall which was supported by station staff and contract partner’s personnel.  During the observations of the turbine hall basement I raised a number of concerns regarding individuals not wearing air respirators for the various work activities that were being undertaken when the associated risk assessment identified this requirement. The station addressed this immediately; I was therefore content for the station to follow-up the circumstances surrounding this shortfall of work practices and to report its findings back to me.

However, I am aware that the above observations I have made and that of my previous inspection, that these observations are symptomatic of wider behavioural and control and supervision issues associated with the station. I will therefore refer to ONR’s enforcement management model to determine what potential regulatory action may be indicated, this is reported within a separate enforcement decision record.

Conclusion of Intervention

In relation to LC11 (6), I judge that an inspection rating of Green (no further regulatory action required).

In relation to LC12 reactive I judge that an inspection rating of Green (no further regulatory action required).

In relation to the information gather during routine engagements primarily to work /task observation observed on this visit and previous station visits I will refer to ONR’s enforcement management model to determine what potential regulatory action is indicated; this will be reported within a separate enforcement decision record.