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Safety management across multiple sites – an example from the UK nuclear sector

29 May 2014

Graham Finn, Head of Health, Safety and Environment at EDF Energy’s Generation Division, explains the safety management systems in place within the group’s nuclear operational unit and suggests ways in which other process industries might benefit from the group’s experience.

Graham Finn, Head of HSE at EDF Energy's Generation Division
Graham Finn, Head of HSE at EDF Energy's Generation Division

Graham Finn has worked within the UK nuclear sector for 39 years, including a period as plant director of the Dungeness B nuclear power station, and is currently Head of Health, Safety and Environment at EDF Energy’s Generation Division, covering all the group’s UK nuclear, gas, coal and wind energy production facilities. This article is based on his presentation at the Hazardex 2014 Conference and a subsequent interview.

EDF Energy is the UK subsidiary of EDF SA, the French government-owned international energy group that now operates in 23 countries, with interests both in energy generation and sales. The heart of the group is still in France, where it runs 56 nuclear reactors at 19 locations, which supply 80% of the country’s electricity.

In the UK, EDF Energy Nuclear Generation Limited (NGL) operates eight nuclear power stations, seven UK-designed Advanced Gas-cooled Reactor (AGR) stations and one Pressurised Water Reactor (PWR).

Finn says EDF bought British Energy and its nuclear power stations five years’ ago for a number of reasons. “The main driver was that there were opportunities for synergies - some areas where we in the UK were perceived to be good, some areas where they were good - so we could take the best from both.”

British Energy also owned land where new nuclear power stations could be built, an important consideration given the recent enthusiasm for nuclear new-build shown by the UK Government. EDF Energy is currently preparing the ground for a new nuclear station at Hinkley Point in Somerset, and is in the early stages of developing the Sizewell site in Suffolk for another new plant. A final decision on whether to proceed with their construction should be taken later in 2014.

The seven existing AGRs are at Dungeness in Kent, the prototype, and three paired sites at Hinkley Point B and Hunterston (Ayrshire), Heysham 1 (Lancashire) and Hartlepool, (Co. Durham), and Heysham 2 and Torness (East Lothian). The single PWR station is at Sizewell.

“The UK nuclear fleet is currently performing well”, says Finn. “In 2012 we produced over 60 terawatt/hours (TWh) of low-carbon energy, about 40% of the domestic market in the UK. That is near to the maximum design capacity, pretty high in the international league table, and quite impressive considering some of those plants are 30 years’ old.”

This output improvement is linked to the introduction of management systems that have increased NGL’s performance across the board, not least in the field of safety, he says, and these systems can be applied to any plant or industry, no matter what the design or output.

Safety requirements

Compared with the other high hazard industries, there is nothing so potentially hazardous as a nuclear reactor, Finn says, and this requires an exceptional level of safety.

“In operation each reactor has a thermal power of up to 1,500MW, and when the control rods are lifted, you’re effectively pressing the accelerator on something as powerful as the Space Shuttle.

“The nuclear fission can be shut down in seconds, but the decay heat will be present for many days, weeks and years afterwards. The legacy that we leave behind in the nuclear industry stays around for many, many years. A nuclear power station will take hundreds of years to be turned into just another brownfield site.

“So nuclear, I would argue, is different. We need to communicate this to our staff all the time to ensure they understand the special nature of what is involved. Safety has to be the absolute priority in all nuclear operations.”

The World Association of Nuclear Operators

EDF Energy NGL’s primary safety management system is one developed by the World Association of Nuclear Operators (WANO), which unites every company and country in the world with an operating commercial nuclear power plant, aiming to achieve the highest possible standards of safety across the world nuclear fleet.

WANO and its US equivalent, the Institute of Nuclear Power Operators (INPO), exist purely to help members improve safety and reliability, and those members accept collective responsibility for nuclear safety on the basis that the industry is only as strong as its weakest member.

Dungeness B - Photo: EDF Energy
Dungeness B - Photo: EDF Energy

WANO's activities are concentrated in four main programmes: Peer Reviews, Operating Experience, Technical Support and Exchange, and Professional and Technical Development. Together these programmes provide a comprehensive package of resource and support to members.

“WANO is dedicated to helping operators strive for excellence,” says Finn. “This is a goal that you can never arrive at, but by providing comprehensive information on incidents, training, examples of good practice and more, the organisation ensures members’ standards continually improve.

“It carries out a peer review of every nuclear plant in the world every three years. They will never tell you you’re doing well – only the areas that need improvement. They will leave you with, typically, a list of anything between 10 and 20 areas for improvement. The journey towards excellence never finishes: the bar is moving up all the time and having carried out previous actions, there will always be more.

“When I was station director at Dungeness B we called it the ‘Your Baby Is Always Ugly’ syndrome!’ You think you’ve got the best nuclear power station in the world, you’re really proud of what you’ve achieved, and they come along and tell you where and how you should be doing better. It’s not a pleasant experience, but it helps you on that journey towards excellence.”

The Office for Nuclear Regulation

The other primary external relationship is with the UK nuclear sector regulator, the Office for Nuclear Regulation (ONR).

“If you want to run a nuclear power station, you have to apply for a Nuclear Site Licence from the ONR which covers everything from construction to operation and decommissioning – the whole life cycle,” says Finn.

“That site licence gives high level statements that you have to comply with, but not how to achieve that compliance. Statements might include: “You will have suitably trained and experienced staff”, “You will have procedures to operate your plant in a safe and compliant way” or “You will maintain your plant as expected”.

“We have to specify what we will do to meet those statements and they will check against what we say we will do. This is probably a bit different from most other high hazard industries. The ONR has a resident inspector at each nuclear station and at head office, so they are an integral part of the business. The inspectors have defined legal powers and are transferred to new sites every couple of years so they don’t go native.

“When we shut down for maintenance, we have to formally ask them for permission to start up again for the next three year period, which they will only grant when we provide a comprehensive list of everything we have ourselves inspected. If we want to modify part of a plant, they have to formally approve any change, which means that 9 times out of 10, we will replace like for like.

“If they don’t like what we’re doing, they can issue formal Directions. EDF Energy has never had a Direction - we have worked very closely with the ONR to achieve this.”

Finn says the ONR’s hands-off model of regulation is very effective in the UK context.

“In the UK, we work out our own programmes to fulfil certain stated goals, which is different from the approach used in the USA, where the regulator stipulates the exact kind of training and operational procedures to be carried out.

“I can’t claim any profound knowledge of the US system, but I’ve carried out WANO inspections over there and it’s interesting to see the differences.

“You might say the ONR has it easy compared with the more prescriptive model over the Atlantic. They make these high level statements, and it’s up to us to achieve full compliance - but I’ve worked with the current model for 39 years and think it works well.”

Self regulation

Apart from external regulation by the ONR and oversight by WANO, NGL is also self regulating. It has an independent internal safety and oversight department to which all proposals for changes to plant or operating conditions are referred for Independent Nuclear Safety Assessment. Each station also has a Nuclear Safety Committee which advises on safety matters and which is required to approve all significant changes to the safety case before they are submitted to the ONR. The membership of the Nuclear Safety Committee consists of the Station Director, senior safety officers of the company, and independent safety experts.

EDF Energy's main office at Barnwood, Glos.
EDF Energy's main office at Barnwood, Glos.

This onion model of oversight is a fundamental feature of the nuclear industry, according to Finn.

“At the centre of the onion is the power station where we expect continuous assessment. The next layer out is the fleet manager, who is responsible for functional oversight. Overseeing the fleet managers is NGL’s independent oversight team, and then external oversight – the ONR and WANO. So we expect the plant to pick up adverse trends first, then the fleet manager, then the independent oversight and finally the external oversight. We would expect the first two layers to identify and deal with most problems.”

NGL uses a process-based management system, which covers everything in the station from documentation, fire safety, industrial safety, security, maintenance, outages and work management. Everything you need to operate the plant is covered by a defined process.

Each process is accredited with Lloyds Register to ISO 9001 and ISO 14001, OHSAS 18000 and PAS 55, and has a Fleet Manager who is responsible for deploying it across the eight nuclear stations.

The processes themselves are not nuclear-specific, and the document management, the work management, training management can be used in any business, according to Finn.

Fleet Management

Key to the success of this model is the role of Fleet Manager (FM), who is the designated owner of a particular process within the management system, such as Industrial Safety or Environment, across the whole fleet of nuclear power stations. The FM heads a peer group of eight coordinators, who will each be responsible for the same process at one of the stations.

The fleet manager’s remit is to provide:

1.  Governance - by defining and setting standards across the fleet, establishing consistent fleet-wide arrangements and performance, and establishing and leading an effective peer group within the process

2.  Oversight - by monitoring and analysing performance, undertaking  reviews and initiating interventions to address emerging performance gaps

3.  Support - by providing advice and assistance

4.  Performance – by establishing continuous improvement plans to drive progressive improvements in performance

This gives the key acronym GOSP. All fleet managers apply the GOSP model to ensure consistency and facilitate effective cross-functional integration.

“The key roles are governance and oversight,” says Finn. “If the FM sees any problem with these, which would usually come from adverse KPI trends, he will provide support. If he cannot provide it himself, he can call in specialists from another UK station or an international team from WANO. His job is to ensure every station is performing as well as the best in the fleet.”

GOSP is used around the world in the nuclear industry, and the WANO website gives comprehensive information on how it should be applied.

“For his Governance arrangements, the Industrial Safety Fleet Manager has a number of standards, metrics, leading and lagging indicators, and is constantly monitoring these through self-assessments, benchmarking –both across the UK industry and the world, to ensure his process is being rolled out as specified in his standards – of which he has around 30.

“If he detects an adverse trend he will then put in corrective actions, put those through a control loop, and go back and ensure what he has done has corrected the adverse trend.”

It is a requirement for fleet managers and their associated peer groups to deliver continuous improvement within their designated process area. Continuous improvement is a key element, according to Finn, meaning the standard fleet managers have today is much higher than it was five years ago.

The safety system also applies to contractors.

“We have a number of long-term partners, such as Doosan Babcock in the UK, that are embedded in these processes. They have long term contracts supporting operations at our eight nuclear sites so it is a business imperative for them to comply fully.

“If you are a contractor on site for more than six months, you will go on the same training courses as EDF staff. Their supervisors and managers will also attend the same management courses as our managers. If you are on site for a day, you get a shorter version of that training.

“At Dungeness B, I employed 550 staff and 200 long-term contractors, and without those 200 being fully up to speed on our procedures, I could not have got the level of performance required.”

So what happens when something needs to be corrected?

The first stage is for the FM to engage with the problem and gain acceptance within the organisation that it is a business priority. The second stage is to determine the extent by carrying out root cause analysis. The third is to plan new management arrangements, the fourth to plan the implementation and the fifth to ensure oversight arrangements are in place.

Finn describes an actual example from his time at Dungeness B.

“We had a number of environmental events that pointed towards an adverse trend. That was a big deal for me. As site director, the sector’s other regulator, the Environment Agency (EA), would send me the warning letter after a notifiable event, and it was me who they would have taken to court if the negative situation continued.

“I relied on the Environment Fleet Manager to help get the situation back on track. He put together a five-year programme to improve our performance and the effects were very positive.”

Independent oversight

The next layer of the onion, independent oversight, is also crucial to the success of the system.

The Safety and Regulation Division within NGL provides independent oversight of safety-related processes and activities. Reporting to the Safety and Technical Director, it is entirely independent and separate from operational management.

The division has three departments:

*Nuclear Safety, which carries out nuclear safety assessments of engineering changes, and oversees the Nuclear Safety Committees

*Nuclear Inspection and Oversight, which provides station-based Site inspectors and organises  

planned reviews and interventions

*Central Quality Assurance, which undertakes quality assurance programmes and process deployment audits

Finn says the fact the individuals within this layer are on the payroll but have no line management responsibilities makes then truly independent. “What inspection method, what metrics they choose to look at is decided by them. There are three of these inspectors at each power station, quite apart from the plant manager and the ONR inspector, and they produce independent reports on performance that go straight to the board.”

Organisational learning and nuclear professionalism

Safety processes are only as good as the people implementing them, so another priority is organisational learning, which is delivered through the continuous improvement and operational support functions.

Risk determines investment
Risk determines investment

Three key elements of organisational learning are used within NGL:

*Self assessment and benchmarking is used to identify gaps between local performance and excellence in order that corrective action can be taken to close the gap

*Operating experience is used to learn from internal/external events and operating experience, to identify fundamental weaknesses and determine appropriate corrective actions that will minimise the likelihood of similar events

*The corrective action programme (CAP) process addresses the identification and resolution of undesirable conditions. The CAP process encompasses condition identification, condition documentation in a condition report (CR), investigation, corrective action determination, investigation report review and approval, action tracking, effectiveness review and trend analysis

“There’s no such thing as a new event in the nuclear industry”, says Finn. “You can look up where it happened before and what was done to sort it out.”

NGL has also introduced a Nuclear Professionalism (NP) programme to promote behaviours that support safe and reliable operation of the plant, and to establish principles for enhancing professionalism and respect for the unique technology that nuclear power represents.

Elements include:

*Nuclear safety culture

*Use of human performance error prevention tools

*Leadership and peer to peer coaching processes

*Setting to work processes and pre-job briefings

*Procedural use and adherence

*Human performance for knowledge workers

Some process industries are having difficulty recruiting sufficient numbers of well-trained engineers and technicians. Finn says this used to be a problem in the British Energy era, but since the acquisition by EDF, there is no shortage of good applicants.

“We are now part of a worldwide group and there are many opportunities for talented staff. Quite apart from the many new nuclear plants being built around the world and in the UK, here we also have the new gas power station at West Burton B, the newest gas plant on the grid, and extensive wind power interests.

“And away from generation, some engineers move into trading, or another of the many ancilliary functions performed within the group.”

Another important initiative has been the establishment of knowledge transfer programmes to ensure older engineers and specialists approaching retirement bring their younger counterparts up to speed on all the details of plant operations.

Plant and asset management

NGL uses a risk-based PAS 55-accredited system. The Fleet Manager is on the risk committee and is involved in investment management decisions.

The entire safety case, including risk assessments of plant based, internal and external hazards, is reviewed at intervals against current national and international standards which set industry best practices, for example from the International Atomic Energy Agency ( IAEA).

The review also encompasses operating experience gained within the group, the global nuclear industry (such as Fukushima) and through global high hazard industry events. The review process, which is referred to as a Periodic Safety Review, is carried out at intervals of approximately 10 years, and is one of the conditions of the Nuclear Site Licence. The review is submitted to ONR.

Sizewell B
Sizewell B

The age of NGL’s stations can also be a problem. The newest plant at Sizewell started operating 19 years ago, and the first AGRs have been operating for almost 30 years.

“There are very few issues at Sizewell B, says Finn. “That station benefited from the wealth of international experience with PWR technology, and is now one of the best-performing PWRs in the world. The final two AGRs, Heysham 2 and Torness, also benefited from the experience gained in the construction of the previous AGR stations, and also have few issues.

“With the other five AGR sites, at the 10 year safety reviews we go back to basics, and have had to invest to improve safety performance. At Heysham 1 and Hartlepool, for example, the standards for fire had moved on and we had to build a dividing wall to separate different sections.”

All the AGRs will get further life extensions. After a first round, the second round is currently being approved with a final decision taken on Dungeness B during 2014, which would extend its operational life to 2028.

“We spend an average of £300m a year updating and improving our power stations, and all of that spending is now risk-based,” says Finn. “The biggest risk is in the nuclear island, and that gets the most money.

“Based on the expected life extensions, all seven of our AGR stations should be operating in 2023 when the new nuclear power station at Hinkley Point C is due to be commissioned, if a final investment decision is taken in 2014.”

The results

In 2003, British Energy reported 82 violations to the ONR. A violation may be something as seemingly minor as operating plant at 400.1oC when the prescribed limit is 400oC, but it is still taken very seriously both by the company and the ONR.

As of early 2014, it has been over a year since NGL reported a single violation. This, says Finn, is top class performance in the world nuclear fleet.

Other metrics confirm how effective the Fleet Management process – the GOSP model – has been in improving safety:

*The number of automatic plant shutdowns – when plant shuts itself down because it is approaching its operational limits – has reduced by a third since FM was introduced.

*In 2005, UK nuclear stations passed over a significant number of environmental violation reports to the sector’s other regulator, the Environment Agency (EA). Here again it has been a year since NGL reported a single one. The EA now actually sends staff from other industrial sectors to NGL to learn best practice.

*NGL’s Lost Time Injury rate has improved to such an extent it is one of the leaders in world rankings.

*Staff radiation dosage – which would normally have increased as the plants get older – has in fact levelled off because of measures taken under the FM process. (Most NGL staff receive no radiation dose at all, and those that do, Finn says, receive a very small number of units, equivalent to the dose picked up on a transatlantic flight.)

“We always say safety and production go hand in hand”, says Finn, “and the FM process has provided real business benefits, not least the fact we have generated 60 TW per year over the last two years, the best performance delivered in a long time.

“I think the other process industries could learn much from our experience. One of the things the nuclear industry is good at is sharing information - there are no commercial or language barriers. In the past, events have happened at a foreign nuclear plant that I have information about within hours.

“Here in the UK, I sit on a number of cross-industry committees, for example on process safety with representatives from the petrochemical industry, and the same information sharing does not happen – which surprises me.”

“One of the biggest fears you have is complacency, and our system encourages you not to be complacent,” Finn concludes.

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