Office for Nuclear Regulation

Torness - LC6, LC11 and LC25 planned inspections

Executive summary

Purpose of Intervention

The purposes of this intervention at the Torness Power Station were: to observe a peer-assist emergency exercise (LC11), to attend the Station’s Site Emergency Arrangements Review Committee (EARC), and to undertake a compliance inspection of Licence Condition 6 (LC6) Documents, records, authorities and certificates, and LC25 Operational records.

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 I took the opportunity to join the EDF Independent Assessment Team to observe an exercise (Sahara) that simulated an offsite emergency. 

As part of the ONR inspection programme for Torness I carried out an inspection of LC6 and LC25. The inspection was informed by ONR technical inspection guidance on LC6 and 25 (NS-INSP-GD-006 and NS-TAST-GD-025), both of which are available on the ONR website. It comprised review of the Site’s document and drawings schedules, selection of a sample of documents and records important to nuclear safety to ascertain their preservation and accessibility, and discussion with key staff involved.

A number of routine Site Inspector interactions are also recorded in the report, including an emergency arrangements review meeting (EARC).

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

I observed that EDF’s Internal Assessment process for emergency arrangements, involving experienced staff from other Stations and HQ functions, provided good feedback for Torness, and the Station’s self-assessment after the exercise was also of good quality. Exercise Sahara demonstrated that the Station continues to make progress in improving emergency preparedness and response. I rate the exercise ‘Green’ for LC11 as the scenario was sufficiently challenging and the emergency response achieved its objectives, although there is further improvement needed in staff mustering arrangements.

For LC6 and 25 I found compliant practice at the Station, and an improvement plan to address issues of obsolescence and resilience which appears to be making sufficient progress to be complete within two years. As matters stand at the moment the task of keeping track with the wide range of documents of different location and format within the schedule is complex and relies on the local knowledge of a small number of staff, so I have requested an update on plans to ensure organisational resilience. On the basis of the sample I found that the Licensee was in general able to demonstrate compliance with LC6 and 25, I have therefore rated the inspection ‘Green – no formal action’ for both.

Conclusion of Intervention

For LC11 I took part in the development of the internal assessment team’s feedback to the Station and provided input through the EARC.

For LC6 and 25 I presented the inspection findings at the close of the inspection.  I requested an update on plans to ensure resilience of the knowledge required to maintain and locate the records required, and have raised a level 4 (lower priority) regulatory issue to allow follow-up.

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.