Office for Nuclear Regulation

LC 6 and 10 Compliance inspection

Executive summary

Purpose of Intervention

This intervention was a planned LC6 (Documents, records, authorities and certificates) compliance inspection. In addition, a reactive unplanned LC 10 (Training) compliance inspection and intelligence gathering was also undertaken at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B power station.

Due to the Covid-19 pandemic a “remote” LC6 compliance inspection took place in between June and July 2020.
A planned station visit took place to undertake a physical inspection of the station’s LC6 arrangements and to undertake intelligence gathering.

Interventions Carried Out by ONR

This inspection was led by me (the DNB nominated site inspector) which consisted of the following:

During this inspection I also undertook intelligence gathering in the following areas:

Explanation of Judgement if Safety System Not Judged to be Adequate

No system based inspection undertaken, hence not applicable.

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

For the planned LC 6 compliance inspection of the station’s document store, it was positive to see the station’s efforts in rationalising its historic records and archiving them into clearly identifiable areas. The station provided evidence that satisfied me that it was complying with its arrangements in the areas sampled. In light of my observations I have rated this inspection as Green. This is a positive outcome given the historic challenges the station has had in this area, however there still remains a significant task for the station in continuing the work and meeting its objectives.

I undertook a reactive unplanned LC10 inspection of Simulator Training that was taking place during the time of my visit. I observed the instructors providing the training requirements and met with the training candidates to discuss the aspects of their training and the use of the dual Reactor 21 and 22 simulators. My overall rating of this LC10 inspection was that a GREEN rating was appropriate.

In relation to the areas I visited, it was evident that the housekeeping standards of the station had notably improved over the 6 months. The physical improvements of clear pedestrian walk ways, clearly identified surface water drains as well as newly installed plant were evident. The station’s management of the COVID-19 restrictions was encouraging around the station. It was clear that the control and management measures were well established especially on entering the station and in areas where there had been reported difficulties early on in the COVID 19 arrangements regarding social distancing. 

During the station walk down I visited the station’s existing secondary shutdown nitrogen facility which will be replaced with a new system in quarter 1 2021. This facility has suffered from reliability issues. It appears that the station’s efforts in addressing this have resulted in improved reliability of the system. However, during my inspection I observed broken indicator gauges, corroded valve wheels and pipe hangers and significant guano issues due to pigeons accessing the facility.  In light of these observations, I have raised a regulatory issue in order to track the station’s improvements in this area.

Conclusion of Intervention

In conclusion to my station visit, I have rated my planned LC6 and the unplanned LC10 compliance inspections as GREEN. This visit was overall positive given the significant progress the station has made over the past 6 months. 

However, noting the improved reliability of the existing nitrogen injection plant, further work is still required by the station to ensure that the material condition is addressed and maintained to meet the expected standards required from this front line plant. I have therefore raised a regulatory issue to track the stations improvements in this area.