Office for Nuclear Regulation

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LC24 Compliance inspection - Procedure use and adherence

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake a compliance inspection of Licence Condition 24 (LC24) – Operating Instructions, at the EDF Energy Nuclear Generation Torness Power Station.

The intervention was planned in accordance with ONR’s Torness Integrated Intervention Strategy (IIS) for 2018/19.

Interventions Carried Out by ONR

As nominated Site Inspector, together with specialist Human Factors inspectors from ONR and EDF’s Independent Nuclear Assurance, I carried out a compliance inspection of LC24.

The intervention, which comprised plant tours, interviews, meetings and review of documents, had a particular focus on the arrangements to ensure that written procedures were used and adhered to in practice.

The inspection was informed by ONR technical inspection guidance on LC24 (NS-INSP-GD-024) and assessment guidance on the design of procedures (NS-TAST-GD-060). Both of these are available on the ONR website.

A number of routine Site Inspector interactions are also recorded in the report.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable – no system based inspections were performed during this intervention.

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

We found generally good practice at the Station, and a considerable number of improvement initiatives underway. We identified some opportunities to further reduce errors in compliance with working procedures by the application of relevant good practice to the ergonomics of tasks. This included improving the way that procedures are written, and how well they developed in tandem with the layout and labelling of plant and process. This should be in addition to the existing emphasis on human performance practice.

On the basis of the sample we found that the Licensee was in general able to demonstrate compliance with LC24, I have therefore rated the inspection ‘Green – no formal action’.

Conclusion of Intervention

I presented the inspection findings to Torness power station management at the close of the inspection.  I made a number of observations and recommendations related to the findings above. Given the significant current efforts being made by the Station to improve I did not to make these formal requirements, but the Station undertook to respond within six months.

There were no findings from this inspection that significantly undermine nuclear safety or which would result in changes to the planned interventions and inspections of Torness Power Station.