Office for Nuclear Regulation

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Licence Conditions Compliance Inspections against LC19 and 21 in support of Permissioning of the Dry Fuel Store Project

Executive summary

Purpose of intervention

This intervention was on Sizewell B Dry Fuel Store project compliance with Site arrangements and to gather evidence to aid decision-making when Site requested Consent to commence active commissioning on the project.

Interventions Carried Out by ONR

Site Licence Condition (LC) compliance inspections against LC19: Construction or Installation of New Plant and LC21: Commissioning.

Explanation of Judgement if Safety System Not Judged to be Adequate

Inspection of arrangements for LC 19 and 21 were judged adequate.

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

The ONR inspector team were of the view that the Licensee at times struggled to clearly articulate how responsibilities of the Project Safety Review Group (PSRG) and Testing and Commissioning Panel (T&CP) had been discharged. A significant weighting in the inspection rating awarded was based upon the knowledge and experience of individuals who were members of the PSRG and T&CP.

The ONR inspector team noted that EDF Energy Nuclear Generation Ltd (NGL) provided no evidence of any formal training for Chair and members of the PSRG or T&CP. This type of awareness training is considered important to ensure individuals understand their duties and responsibilities together with being familiar with arrangements produced in the construction of new facilities and their processes and subsequent commissioning. Training is also considered supportive to demonstrate that individuals are Suitably Qualified and Experienced Persons for the role they are carrying out. This is to be discussed with the ONR NGL Corporate Site Inspector for inclusion in future intervention on training arrangements.

Conclusion of Intervention

The Sizewell B Dry Fuel Store project was considered compliant with Site LC 19 and 21 arrangements. Some areas of good practice were identified in the development and implementation of commissioning activities. However, this was not found to be standard across the different work-streams of the Dry Fuel Store project. This finding was brought to the attention of the PSRG Chair during the de-briefing at the end of this inspection. The Chair indicated that he was aware of this issue and considered that this difference reflected the maturity of the different work-streams and that standards had been set which he was sure would be met as the project developed.


It is recommended that further compliance inspections against LC 19 and 21 be carried out on the Dry Fuel Store project. This is to confirm standards set by the PSRG and T&CP are delivered together with ensuring work to underpin active commissioning is delivered to the stated high standards in a controlled and organised manner.