Office for Nuclear Regulation

Compliance Inspections and Attendance at Site Stakeholder Group

Executive summary

Purpose of intervention

This report covers an inspection of Magnox Ltd’s Dungeness A nuclear licensed site on 20-21 April 2015. This inspection was undertaken as part of a programme of planned interventions as outlined in the IIS plan for 2015/16.

The inspection looked at the site’s emergency arrangements, and suitably qualified and experienced persons (SQEP) arrangements.

Interventions Carried Out by ONR

During this intervention, I carried out Licence Condition (LC) compliance inspections to verify compliance with the following Licence Conditions:

My inspections were carried out against the requirements of LC11 and LC12 and ONR’s published inspection guidance associated with these Licence Conditions.  The inspection comprised office-based examination of procedures and records and interviews with staff.

Whilst on site I held meetings with the licensee to discuss follow up the status of actions and investigations from recent events. I also met with the site safety representatives.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable – This was not a Safety Systems Inspection.

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

I inspected compliance to Licence Condition 11 – Emergency Arrangements. I judged the arrangements and implementation of the current Emergency Plan to be adequate. I examined the duty roles identified in the emergency plan and was satisfied that each had an identified responder available on the current shift. I inspected the list of equipment available for emergency response and these were shown to be adequately controlled and maintained.

I met with site Safety Representatives. We discussed current issues and plans on site and feedback from the safety rep interactions with staff and management.

I inspected compliance with Licence Condition 12 – Suitably Qualified and Experienced Persons. The licensee demonstrated adequate arrangements for ensuring that personnel with roles in the emergency plan are adequately trained, however it was less clear how the experience of responders is assured, since participation in exercises is not routinely recorded. Due to the frequency of exercises currently underway to implement the revised emergency arrangements the potential for significant gaps is unlikely, so I am satisfied this does not impact on nuclear or radiological safety. The licensee agreed actions for recording exercises to ensure gaps do not emerge once the training returns to normal levels.

I attended the Dungeness Site Stakeholder Group meeting; no matters related to safety or security regulation were raised.

Conclusion of Intervention

From the evidence gathered during this intervention I judged the licensee’s compliance with LC11 to be adequate. I judged the licensees compliance with LC12 to be below standard due to the availability of records to demonstrate experience in emergency roles. The licensee has agreed improvements for recording participation in emergency exercises which will address this minor shortfall. These actions will be followed up by the ONR Site Inspector as part of routine regulatory interactions with the licensee.