- Site: Dungeness B
- IR number: 20-015
- Date: June 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
The purpose of this intervention was to provide regulatory confidence in the arrangements for the management of contractors in relation to conventional health and safety work at EDF Energy Nuclear Generation Limited’s (NGL’s) Dungeness B power station (DNB). This work was carried out in line with the inspection programme contained in ONR’s Operational Facilities Division intervention plan 2020-21.
An ONR Enforcement Letter was issued to DNB on the 8th January 2020 following observation of a number of shortfalls in health and safety compliance matters through the previous months related to the control of contractors. The station director provided a response to that letter on the 30th January 2020. This inspection explored some of the actions detailed in that response as well as the suitability of the wider site arrangements for the control of contractors.
Interventions Carried Out by ONR
Due to the COVID 19 pandemic the inspection was carried out remotely over a six week period by holding a series of structured video conference discussions. Compliance with the key relevant legal requirements related to contractors was considered during the inspection. These are set out below;
- Health and Safety at Work Ect Act 1974, Section 3(1)
- The Management of Health and Safety at Work Regulations 1999, Regulation 3(2)
- The Management of Health and Safety at Work Regulations 1999, Regulation 5(1)
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspection identified three areas where DNB was judged to be below standard;
- Corporate fleet audits are the main proactive monitoring system in relation to industrial safety compliance. The inspection identified that DNB did not effectively address some of the concerns identified in the 2019 Control of Contractors audit. This matter was raised with the station during the inspection and a number of the original audit actions were reopened and some new actions were raised.
- The inspection identified breaches of the COSHH 2002 regulations within a contractor fabrication workshop. The station took immediate steps to address these matters.
- The inspection identified inconsistency with station oversight of the suitability of contractor risk assessment and method statement documentation for work planning when a significant risk permit was issued. Additionally, documentation for the use of a mobile elevated work platform had not been completed for one example. The station is currently investigating the root cause.
However, during the inspection ONR also noted positive areas. The station had a strong commitment to good conventional health and safety standards and culture. Contractors reported that they were encouraged to raise health and safety concerns and DNB were positive in their response to any matters identified. The role of the field supervisor was recognised by all as important in ensuring that health and safety standards were adequate and a field supervisor’s forum had been introduced to share learning and discussion. A regular programme of proactive leader time in the field observations is carried out with many of these observations focussed on the work of contractors. Reactive monitoring arrangements are in place for investigating accidents and incidents and operational experience from investigations is shared with contractors. The inspection also observed good adherence to COVID 19 control arrangements by both station staff and contractors.
Conclusion of Intervention
The inspection was rated AMBER given the areas identified above were below standard. In light of these findings, three actions will be raised and added to a current ONR regulatory issue relating to ONR’s Enforcement Letter that was sent to the station on the 8th January 2020. The station’s response to this ONR enforcement letter has in part been delayed due to the COVID 19 pandemic. This has reinforced ONR’s view that the rating should remain amber until the station has made progress in addressing the regulatory actions.
There were no findings from the inspection that I consider would prevent restarting of the plant.