Office for Nuclear Regulation

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LC11 compliance inspection at Torness power station

Executive summary

Purpose of intervention

The purpose of this intervention was to undertake a Licence Condition 11 (LC 11) compliance inspection at EDF Energy Nuclear Generation Limited's (NGL's) Torness power station in accordance with the planned inspection programme contained in ONR's Integrated Intervention Strategy for Torness.

This intervention involved the inspection and evaluation of level 1 demonstration exercise 'Hector', which covered the on-site emergency response arrangements at the Torness nuclear licensed site. It was undertaken by four ONR inspectors, under the leadership ONR's operating reactors sub-programme head of assessment. The purpose was to seek assurance that NGL's emergency arrangements have the capability to deal effectively with security and nuclear safety emergencies with on-site or off-site consequences.

Interventions Carried out by ONR

This intervention included a compliance inspection against the following LC:

LC11 - Emergency Arrangements

This inspection used ONR guidance document, NS-INSP-GD-011 Revision 3, which requires inspectors undertaking a compliance inspection against LC11 to consider both the arrangements that are in place together with their associated implementation.

Explanation of Judgement if Safety System not judged to be Adequate

No safety system inspection was undertaken, hence this is not applicable.

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

We considered that this level 1 exercise provided sufficient challenge to test Torness' implementation of emergency arrangements. This permitted an effective examination of Torness' response in a wide range of areas and provided learning in a number of areas.

We welcomed the fact that a joint debrief meeting provided a comprehensive exchange of information on the outcome from the exercise, which made a valuable contribution to the identification of potential improvement opportunities in respect of the emergency arrangements and their implementation at the Torness power station.

Good practices and strong performances were identified in a number of areas, such as:

A number of areas for improvement, principally related to communications and the realism of the execution of the exercise, were also identified, which resulted in the station self-identifying that it should aim for higher levels of performance, and that it is able to achieve improvements in those areas identified.

Overall, ONR judged that Torness has adequately complied with the requirements of LC11, but with a number of shortfalls which cannot remain unattended until the next demonstration exercise. Torness should therefore collate all identified shortfalls into an action plan, with progress against each action actively tracked by the station and verified through Independent Nuclear Assurance (INA) surveillances. The action plan should also address and bring about significant improvements to the softer cultural and mindset aspects of emergency exercises, to ensure that a higher level of realism is observed during the unfolding of exercise scenarios. The Torness Nominated Site Inspector is, as necessary, to be advised of future shift exercises intended to test the implementation of the areas for improvement identified.

Overall, and on the basis that the demonstration exercise broadly met its stated objectives, that Torness complied with its legal duties and that no significant shortfalls were identified in the delivery of safety or security functions, ONR judged that this level 1 demonstration exercise should be assigned a rating of 'green', in line with ONR's inspection rating guide. Torness' progress against the recommended action plan will be tracked through an ONR issue.

Conclusion of Intervention

We consider that exercise 'Hector' provided sufficient challenge to test Torness' implementation of emergency arrangements, with good practices and strong performances identified such as conservative decision-making, the speed and effectiveness of mustering arrangements and the integration of the police and other emergency services. A number of areas for improvement, principally related to communications and the realism of exercises, were identified and will be collated into an action plan which will be progressed and tracked by the station, and independently verified by EDF's Independent Nuclear Assurance function.

In line with ONR's inspection rating guide, we have assigned an inspection rating of 'green' to this level 1 demonstration exercise 'Hector', with a station commitment to collate all identified areas for improvement into an action plan to be progressed in a timely manner.