Office for Nuclear Regulation

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Remote compliance inspection of LC7 and LC6

Executive summary

Purpose of Intervention

The purpose of this inspection was to evaluate EDF Energy Nuclear Generation Limited’s (NGL) LC7 compliance arrangements for ‘the notification, recording, investigation and reporting of “Incidents on the site” and LC6 arrangements for “Documents, record, authorities and certificates” at Dungeness B (DNB) nuclear power station.

Interventions Carried Out by ONR

The inspection was led by the DNB Site Inspector and was observed by a Nuclear Safety Authority (ASN) inspector seconded to ONR.  The inspection consisted of eleven 40-minute interviews with members of the senior leadership team (SLT), the Corrective Action Programme (CAP) team and data archivists.

For the LC 7 compliance arrangements, the inspection gathered data on the effectiveness of the CAP/Organisational Learning process (the principal mechanism through which NGL complies with the requirements of Licence Condition (LC7) and examined the degree of SLT individuals’ engagement with the CAP process. The inspection also involved the observing of the station’s routine Corrective Action Review Board (CARB) meeting.

For the LC6 compliance arrangements, the inspection gathered information on the station’s progress in the rationalisation of the station’s data store which currently has a regulatory issue associated with it.

The above inspections were undertaken as a remote inspection’s through audio and video conferencing as a result of the COVID-19 pandemic. 

Explanation of Judgement if Safety System Not Judged to be Adequate

No system based inspection was undertaken hence, this is not applicable for this intervention.

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

The LC7 compliance inspection centred on remote interviews with the station’s SLT.  It was evident that there was consistency across those interviewed with regard to their level of commitment and enthusiasm for the organisational learning process.  It was evident from my discussions that many of the SLT had prepared well and provided good examples of where the process has clearly been successful or where it was  believed the process has not been and the potential reasons for this.  My observations of the station’s CARB meeting were that it was a robust process with strong challenges to the  items presented for CARB endorsement.

To capitalise on the above observations, the station should seek to harness and promote the ideas and actions of its SLT members with a view of instilling this behaviour in all leaders to follow and further promote.  In my opinion, the level of engagement and drive of the SLT is key to enabling people to perform in their role and ultimately improve the station’s performance.

I have therefore rated the LC7 compliance inspection as GREEN, no significant regulatory shortfalls during this remote inspection.
The LC6 compliance inspection of the station’s arrangements in its rationalisation of the station’s data store which currently has a regulatory issue associated with it.  My discussions with the team centred upon their view of the station’s current position and difficulties they have had in the rationalisation process.  I was provided with examples of what has been achieved so far and the station’s forward plan for this year.

Given the current circumstances regarding COVID 19, I stated that a physical examination of the data store and the sampling of records would be of benefit in further demonstrating the stations compliance arrangements.  Once the current COVID 19 arrangements permit, a physical inspection of the data store would be undertaken.  With this in mind, I have considered this inspection as a part 1 which will be followed by a part 2 inspection of the station’s data store.

In light of the above observations and discussions, my ongoing engagement with the station on the documentation team I have rated this compliance inspection as GREEN, no further regulatory intervention is currently required.

Conclusion of Intervention

Based on the sample inspected, I rate both the LC 7 and LC6 inspections as GREEN - no formal action.

However, once the COVID 19 situation improves I will undertake a further follow-up of the stations LC6 arrangements with a visit to the station’s data store to undertake a sampled inspection of those areas that are currently being improved upon by the documentation centre team.

No additional regulatory interventions are needed over and above those already planned at DNB Power Station.