Executive summary
Date(s) of inspection:
- December 2023
Aim of inspection
Licence condition compliance inspections are an essential element of ONR’s intervention strategy for operating reactor fleet. The aim of this inspection is to test EDF Nuclear Generation Ltd (NGL’s) compliance with Licence Condition 36 (Organisational Capability) at Dungeness B (DNB) nuclear power station
Subject(s) of inspection
- LC36 – Organisational capability – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
Overall the station was able to demonstrate adequate management of organisational capability against the requirements of Licence Condition 36.
We noted that the station has a clear view of organisational capability demands and vulnerabilities over the next 12 months. However there is a less clear a view of how the station will ensure that it retains the capability it needs throughout the period of defueling (up to 5 years or more), noting the extended training times for some posts. The need to develop a Resourcing Strategy is an open action from an investigation in 2023 into a series of events at the station. The station also noted that it will address longer term capability planning in a new People Strategy. This issue is subject to ongoing follow-up by the ONR Dungeness B Site Inspector.
The two departments sampled – Operations and Engineering – were able to demonstrate how they identify and address organisational vulnerabilities, using bespoke tools. We noted that the station does not use the fleet Organisational Capability Risk Assessment Tool, which would ensure a consistent approach aligned to good practice. This relates to an existing fleet-wide shortfall in the adequacy of NGL’s vulnerability assessments, and an associated improvement plan, which ONR is tracking through Level 3 regulatory issue RI-10695 and maintaining oversight at corporate level. As a result of this inspection, we will review the R/A/G status of this regulatory issue and determine whether any additional actions are needed.
We noted that the Operations Department appears to be planning to reduce the number of staff in the Chemistry team by one Chemistry Engineer and one Chemistry Technician, as indicated in overarching Management of Change (MOC) proposal for defueling (DNB/MOC/202). However there does not appear to be a corresponding MOC proposal to implement this change. We have therefore raised a regulatory issue at Level 4 for the station to clarify the changes proposed and provide the appropriate MOC documentation.
We noted that the Technical Safety and Support Department plans to reduce the number of Quality Assurance Engineers from two to one later in 2024, as set out in MOC proposal DNB/MOC/217. However, in my opinion, this document does not provide an adequate justification for the change recognising the continuing workload of this team and shortfalls in the station’s current performance in this area. We have therefore raised a regulatory issue at Level 4 for the station to provide an adequate justification for this change should it wish to proceed with implementation.
Conclusion
Overall we were satisfied that there are no significant shortfalls in the station’s management of organisational capability against the requirements of Licence Condition 36. We have therefore rated the inspection ‘Green’ (no formal action required). In coming to this conclusion, we noted shortfalls in the station’s longer term capability planning, which is the subject of ongoing follow-up by the ONR DNB Site Inspector, and shortfalls in the justification of reductions in the Chemistry and QA resource at the station, which we will follow-up via Level 4 regulatory issues.