Office for Nuclear Regulation

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LC4 & LC22 Licence Compliance Inspection

Executive summary

Purpose of intervention

The purpose of this intervention was to conduct Licence Condition (LC) compliance inspections at EDF Energy Nuclear Generation Limited’s Torness Power Station in line with the planned inspection programme contained in the Torness Integrated Intervention Strategy (IIS).

Interventions Carried Out by ONR

This intervention included compliance inspections against the following Licence Conditions (LCs):

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

The LC4 element of this intervention considered the adequacy of the arrangements at Torness Power Station to ensure compliance with LC 4 in terms of the measures used to control receipt, handling, storage, use and despatch for reprocessing or disposal of nuclear matter covering nuclear fuel and other radiological materials.

Our inspection found that the arrangements for compliance with LC4 provided an effective demonstration of the process and procedures used to ensure that nuclear matter at Torness Power Station is restricted and that appropriate measures are in place to track fuel and other materials throughout their use and storage at station. This was achieved through a combination of paper and computer-based records to effectively monitor nuclear fuel and the activities performed on fuel elements and assemblies in the form of a fuel cycle at Torness Power Station. We sampled a range of the processes, documentation and records used for nuclear matter from receipt through to despatch for reprocessing.

Additionally, we reviewed the arrangements for prevention and avoidance of hazards to nuclear fuel from criticality, dropped loads, flooding and seismic hazards at Torness Power Station. This found that the risks from these potential hazards were minimised through the use of measures, including criticality certificates, fire loading restrictions, revision of a seismic safety case and use of appropriate manual handling equipment to prevent dropped loads. The implementation of these measures was demonstrated to incorporate a number of aspects of relevant good practice.

We were satisfied that implementation of the arrangements for compliance with LC4 at Torness Power Station are to a good standard and judge that the outcome of the sample inspection undertaken satisfied relevant expectations in ONR guidance.

The LC22 inspection examined the arrangements in place at Torness Power Station in the context of Category 2 Engineering Change (EC) modifications that are scheduled to be implemented as part of a reactor periodic shutdown in 2015. This enabled a review to be carried out in terms of their safety significance and implications this may have on the provision of documentation to justify the safety of the proposed modifications, their implementation during the periodic shutdown and current status. We found that in excess of 90% of all outage-related modifications have reached an approved status in line with a target assigned at Torness Power Station. This enables focus to be given to other elements of each modification, such as development of work instructions, completed drawings, operating and maintenance instructions that links directly to other LCs, so that this can completed in a timely manner in advance of their implementation.

Our inspection reviewed the station’s EC performance and trends that continue to show an improvement, which reflects sustained improvements in terms of both all live and open ECs. This finding supports the closure of a longstanding ONR issue on EC backlog as this continues to be maintained at acceptable levels.

This inspection went onto consider the implementation of recent Category 3 ECs in support of modifications arising from the licensee’s Japanese Earthquake Response  project. This involved inspection of the process followed for implementation of Category 3 modifications, which covered issues such as the role of the author, verifier, specialist assessors and the responsible engineer.  A walkdown was subsequently undertaken of the implementation of a Category 3 EC associated with the installation of a Continuous Emergency Monitoring System where a series of control panels had been mounted onto sub-frames prior to their installation to provide resilience against seismic hazards.

We are satisfied that implementation of arrangements for compliance with LC22 at Torness Power Station are adequate and judge that the outcome of the sample inspection undertaken met with relevant expectations in ONR guidance.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

We are satisfied that the arrangements and their implementation at Torness Power Station for LC4 are good and judge that the outcome of the sample inspections undertaken met expectations detailed within relevant ONR guidance.  We have therefore rated the LC4 element of this intervention with an IIS rating of 2, good.

We are satisfied that the arrangements and their implementation at Torness Power Station for LC22 are adequate and judge that the outcome of the sample inspections undertaken met expectations detailed within relevant ONR guidance.  We have therefore rated the LC22 element of this intervention with an IIS rating of 3, adequate.

There are no findings from this inspection that could significantly undermine nuclear safety and no change to the planned ONR interventions and inspections at Torness Power Station are required.