Office for Nuclear Regulation

Licence condition compliance inspections – LC2 and LC16

Executive summary

Purpose of Intervention

The purpose of this intervention was to conduct licence condition (LC) compliance inspections at EDF Energy Nuclear Generation Ltd’s Dungeness B Power Station (DNB).  This intervention was undertaken as part of a series of planned interventions that are listed in the DNB Integrated Intervention Strategy 2018/2019. 

Interventions Carried Out by ONR

I, the nominated site inspector and supported by a civil nuclear security inspector, undertook inspections to evaluate compliance with the following nuclear site licence conditions (LCs), which are applicable provisions of the Energy Act 2013 for:

During my visit, I also undertook routine engagement meetings with the Licensee as part of information gathering and exchange. This included meetings with the  station director, station safety representatives, emergency planning engineer and the DNB internal safety inspector. I also attended attending the licensee’s operational focus meeting and the statutory outage review board meeting.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not Applicable – no system based inspections were completed during this intervention.

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

Licence Condition 2 - The inspection primarily focussed on the licensee’s arrangements for compliance with LC 2(1) and LC 2(4), covering prevention of unauthorised entry onto site, and marking of the properly maintained licensed site boundary.  A sample of the implementation of the licensee’s arrangements was carried out which included visual inspection of a sample of the site boundary and boundary signage and a review of the associated documentation.  I considered that the site fence and signage marking the site boundary meets legal requirements but noted that some signage was confusing in specific areas. The boundary fence was observed to be complete in all areas but was in need of maintenance in several areas. These observations were accepted by the licensee who committed to deal with these minor issues. In light of this, I have raised a regulatory issue to track the licensee’s progress.  Overall, I am satisfied that the licensee  was compliant with legal requirements and judge that the following inspection rating is appropriate: Green

Licence Condition 16 - On the basis of sample inspection undertaken during the LC2 (above), I confirmed that the site plan adequately identified the boundaries of the nuclear licenced site and the major nuclear safety significant buildings (or plant). I did note that the building schedule was not linked to the update of the site plan and that prioritisation of drawing updates was not clear. The licensee has committed to address these minor administrative shortfalls, which will be monitored via an entry on the ONR issues database. Overall, I am satisfied that the licensee is compliant with its legal duties required under LC16 and I judge that the following inspection rating is appropriate against LC16: Green.

During my inspection of the site boundary, I noted a number of areas where the standards of housekeeping were below the expectations of the station; I also noted the poor condition of redundant boreholes that are at the periphery of the site boundary. In addition, I observed potentially unsafe storage practice of gas bottles that supply the chemistry laboratory. In light of these observations I have elected to raise a regulatory issue on the ONR issues database to monitor the station’s progress in resolving these issues.

Conclusion of Intervention

From the evidence gathered during these inspections, there are no findings from this inspection that could significantly undermine nuclear safety.  At present, no additional regulatory action is needed over and above the planned interventions at DNB Power Station.