The purpose of this intervention was to conduct an inspection of the arrangements in place at Torness power station for management of compliance with the Pressure Systems Safety Regulations (PSSR). The work was carried out as part of the planned intervention task sheet TS024 - “Through-Life Management of Flow Assisted Corrosion (FAC) and Pressure Systems Safety Regulation (PSSR) Compliance on AGR Sites”.
I carried out this inspection accompanied by an ONR Structural Integrity Inspector. The inspection took place on 24 and 25 January 2017 and involved discussions with staff from EDF Nuclear Generation’s (NGL) and Bureau Veritas (BV). BV are employed by NGL in the role of competent person, as defined within PSSR.
The objective of the inspection was to obtain information relating to NGL’s arrangements for managing compliance with PSSR, in order to identify any areas of relevant good practice, or shortfalls to our expectations. Particular emphasis was placed on the following:
For systems with nuclear safety significance, suitability of inspections completed for both PSSR and Licence Condition 28.
I concentrated my intervention on items I judged important to nuclear safety, focussed upon Structural Integrity.
To assist with PSSR compliance, NGL have produced an internal code of practice “Safety Management of Pressure Systems”, BEG/SPEC/SHE/COP/036 (COP/036). The document identifies Regulations within PSSR and assigns responsibilities for complying with them. I have also used this document to assess the adequacy of arrangements implemented at Torness.
The inspection reviewed the Written Schemes of Examination (WSE) and associated examination reports for selected systems, roles and responsibilities of key staff, process oversight and governance, I also sampled compliance arrangements against license conditions (LC) LC10 (training) to judge the adequacy of the arrangements in place.
Torness was able to demonstrate that their staff had an understanding of the roles and responsibilities in relation to PSSR, that WSE’s were in place for pressure systems at the station, and that systems had been created to ensure that the examination is carried out at the correct time. While there is evidence of good practice the System Engineers (SE’s) responsibilities in accordance with the code of practice were not always fully understood. However it is noted that actions are being taken by NGL to address this shortfall.
A robust process is in place for approval of new or updated WSE’s. Torness could demonstrate that SE’s had addressed the findings contained within a Competent Person’s examination report via use of the Asset Management System (AMS), however they acknowledged that at the time of our inspection the reports were not individually checked by the SE’s as required by COP/036. I encourage Torness to ensure the process for introduction of new and updated WSE’s is effectively managed, along with review of examination reports by SE’s.
The PSSR Advisor and Competent Person (CP) were able to demonstrate an effective process for management of PSSR examination postponements, dealing with the unavailability of components for inspection, the CP is made aware of repairs or modifications to pressure systems, and that Torness is able to adequately respond to imminent danger defects raised by the competent person. However ensuring that the CP made is aware of changes when the engineering change process is not used or if components are replaced on a like for like basis is not always as reliable.
Recent and forthcoming staff changes have the potential to challenge the effectiveness of the process of PSSR compliance. Torness should ensure appropriate support is provided during the changeover period.
There is evidence of non-imminent defects and recommendations contained within the CP examination report being recorded within AMS. However, there is a significant reliance upon the SE to address these findings rather than having a robust process in place. NGL should ensure that a suitable process is in place to address these defects and recommendations appropriately.
NGL should resolve the concern raised by the CP regarding the management of return to service inspections of equipment to ensure compliance with the PSSR regulations.
The plant walk down demonstrated that Torness is actively managing PSSR inspection requirements and condition of their pressure systems.
NGL and Torness Independent Nuclear Assurance function has considered PSSR requirements during their surveillance and the planned focused interventions in 2017 are welcomed.
PSSR training requirements are being adequately implemented although Torness need to ensure training is refreshed on an appropriate timescale.
During the inspection, several observations were made for improvement. Some PSSR shortfalls and non-compliance with COP/036 were identified and communicated to Torness. The good practice followed by staff minimised the potential effect of these shortfalls or non-compliances. Based upon these inspection findings we judge that a Green rating should be recorded against PSSR compliance.
A list of key findings from this intervention has been provided to Torness for their consideration and resolution. ONR should consider whether a revisit to Torness at a suitable future date is required given the future changes in personnel.