Executive summary
Date(s) of inspection:
Aim of inspection
The aim of this inspection was to undertake a planned fire SBI at Torness (TOR) to determine the adequacy of implementation of the Licensee’s claims associated with the fire detection, suppression and protection system to ensure fire (conventional and nuclear) risks are reduced as low as reasonably practicable. This was achieved by determining how the TOR fire safety cases and risk assessments are implemented to ensure safety functional requirements are delivered.
Subject(s) of inspection
- Fire (Scotland) Act 2005 - Rating: AMBER
- LC 10 - Training - Rating: GREEN
- LC 23 - Operating rules - Rating: GREEN
- LC 24 - Operating instructions - Rating: GREEN
- LC 27 - Safety mechanisms, devices and circuits - Rating: GREEN
- LC 28 - Examination, inspection, maintenance and testing - Rating: AMBER
- Overall Inspection Rating - Rating: AMBER
Key findings, inspector's opinions and reasons for judgement made
Fire hazards, if not controlled, can present risks to safety (nuclear and conventional) including common cause failure of safety systems. It is therefore important that the risks from fire are suitably controlled. This fire system-based inspection at TOR considered both Nuclear Fire Safety (Internal Hazards (IH)) and Conventional Life Fire Safety (LFS) and was undertaken by the Nominated Site Inspector and a specialist inspectors from LFS and IH to determine whether fire risks at site are suitably controlled. The inspection focussed on areas of plant in the Reactor Building and Admin Building with the greatest nuclear and conventional fire risks.
The LFS inspection assessed the implementation of arrangements for managing life fire risks by reviewing compliance against the requirements of the Fire (Scotland) Act 2005 (FSA) and Fire Safety (Scotland) Regulations 2006 (FSSR). The IH element of the inspection assessed compliance against the requirement of Licence Conditions LC10 Training, LC23 Operating Rules & LC24 – Operating Instructions, LC27 Safety devices, mechanisms and circuits & LC28 Examination, inspection, maintenance and testing.
LC10 Training - I sampled the training records for a number of operators that fulfil roles associated with the fire system. I judge that EDF NGL is adequately implementing its training arrangements and staff are either trained or in the process of undertaking the training currently identified as necessary to carry out the fire related aspects of their role. I therefore award a Green rating. However, a minor issue (L4) has been raised relating to the training needs of the civil engineering system engineer to ensure they are suitably qualified to undertake their role appropriately.
LC23 Operating Rules & LC24 – Operating Instructions - I sampled the fire safety case and associated Technical Specifications and determined that the principal limits and conditions were identified and clearly enacted into station procedures and operator surveillances. A review of surveillance records and compliance check sheets demonstrated that the technical specifications were adhered to during operations. On this basis I award a Green rating for both LC23 and LC24.
LC27 Safety devices, mechanisms and circuits & LC28 Examination, inspection, maintenance and testing - During the plant walkdown various elements of the fire detection and suppression system were viewed and appeared to be in good working order in line with the requirements of LC27. Based on my sample I judged that EDF NGL is adequately implementing its arrangements with respect to safety devices, mechanisms and circuits relevant to fire. I sampled the EIMT records on several key components of the Fire Protection System. This included the fire dampers, doors, barriers and smoke vents. I judged that EDF NGL is inadequately implementing its arrangements with respect to EIM&T and award a Amber rating. As such a L3 regulatory issue has been raised to ensure the gaps in maintenance are addressed appropriately.
Section 53 Duties of employers to employees/ Section 54 Duties in relation to relevant premises/ Regulation 3 Duty to review.- Fire Risk Assessment.- I judge that EDF NGL is inadequately implementing its arrangements with respect to review of Fire Risk Assessments based on the requirements of Regulation 3 of the FSSR and award an Amber rating. As such a L3 Regulatory Issue has been raised to ensure the gaps in review of Fire Risk Assessments are addressed appropriately.
Regulation 10 Fire safety arrangements- I judge that EDF NGL is inadequately implementing its arrangements with respect to the management of LFS as required by Regulation 10 of the FSSR and award an Amber rating. As such a L3 Regulatory Issue has been raised to ensure the gaps in the management of Fire Safety Arrangements are addressed appropriately.
Regulation 16 Maintenance- I judge that EDF NGL is inadequately implementing its arrangements with respect to the management of Maintenance as required by Regulation 16 of the FSSR and award an Amber rating. A L3 Regulatory Issue has been raised under the LC28 section of this report to address this deficiency.
Regulation 20 Training- I judge that EDF NGL is adequately implementing its training arrangements and staff are either trained or in the process of undertaking the training currently identified as necessary to carry out the fire related aspects of their role. I therefore award a Green rating. A L4 issue has been raised under the LC10 section of this report to ensure a review is undertaken to determine whether any other fire specific training is necessary to ensure the Civil SE is suitably qualified to undertake their role appropriately.
Section 53 Duties of employers to employees.- I judge that EDF NGL is inadequately implementing its arrangements with respect to the management of compartmentation, as required by Section 53 of the FSA and award an Amber rating. As such a L3 Regulatory Issue has been raised to ensure that the gaps in the management of the Duty to Take General Fire Precautions (compartmentation) are addressed appropriately.
Regulation 13 Means of Escape- I judge that EDF NGL is inadequately implementing its arrangements with respect to the management of Emergency Routes and Exits, as required by Regulation 13 of the FSSR and award an Amber rating. As such a L3 Regulatory Issue has been raised to ensure that the gaps in the management of Emergency Routes and Exits are addressed appropriately.
Conclusion
I have sampled EDF NGL’s arrangements relevant to TOR that are claimed to protect against nuclear fire hazards or are provided for life fire safety. Although I have identified a number of shortfalls, I do not consider that there is a direct impact on nuclear safety as the shortfalls related to a non-nuclear building. I have however raised ONR Regulatory Issues to ensure the shortfalls are addressed in a timely manner.
Overall, I found that EDF NGL’s existing arrangements made under the inspected LCs and the requirements of the FSA/ FSSR were being inadequately implemented. On this basis I award EDF NGL an Amber rating.