The purpose of this intervention was to provide regulatory confidence in the arrangements for the management of contractors in relation to conventional health and safety work at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B power station (DNB). This work was carried out in line with the inspection programme contained in ONR’s Operational Facilities Division intervention plan 2020-21.
An ONR Enforcement Letter was issued to DNB on the 8th January 2020 following observation of a number of shortfalls in health and safety compliance matters through the previous months related to the control of contractors. The station director provided a response to that letter on the 30th January 2020. This inspection explored some of the actions detailed in that response as well as the suitability of the wider site arrangements for the control of contractors.
Due to the COVID 19 pandemic the inspection was carried out remotely over a six week period by holding a series of structured video conference discussions. Compliance with the key relevant legal requirements related to contractors was considered during the inspection. These are set out below;
The inspection identified three areas where DNB was judged to be below standard;
However, during the inspection ONR also noted positive areas. The station had a strong commitment to good conventional health and safety standards and culture. Contractors reported that they were encouraged to raise health and safety concerns and DNB were positive in their response to any matters identified. The role of the field supervisor was recognised by all as important in ensuring that health and safety standards were adequate and a field supervisor’s forum had been introduced to share learning and discussion. A regular programme of proactive leader time in the field observations is carried out with many of these observations focussed on the work of contractors. Reactive monitoring arrangements are in place for investigating accidents and incidents and operational experience from investigations is shared with contractors. The inspection also observed good adherence to COVID 19 control arrangements by both station staff and contractors.
The inspection was rated AMBER given the areas identified above were below standard. In light of these findings, three actions will be raised and added to a current ONR regulatory issue relating to ONR’s Enforcement Letter that was sent to the station on the 8th January 2020. The station’s response to this ONR enforcement letter has in part been delayed due to the COVID 19 pandemic. This has reinforced ONR’s view that the rating should remain amber until the station has made progress in addressing the regulatory actions.
There were no findings from the inspection that I consider would prevent restarting of the plant.