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System Based Inspection (SBI – 10 Emergency Equipment) and LC11 inspection

  • Site: Torness
  • IR number: 21-121
  • Date: November 2021
  • LC numbers: 11

Executive summary

Purpose of Intervention

This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Torness power station, undertaken as part of the planned intervention strategy for the Operating Facilities Division of the Office for Nuclear Regulation (ONR).

The work was carried out in-line with the planned inspection programme contained in the Torness Integrated Intervention Strategy for 2021-22.

Interventions Carried Out by ONR

We performed a System Based Inspection of the Emergency Equipment to examine if the licensee’s arrangements and their implementation enabled the system to fulfil its functional requirements in line with the safety case.

Through the examination of the emergency equipment, associated procedures, records and a confirmatory plant walk down, a compliance inspection was performed against the following Licence Conditions which are applicable provisions of the Energy Act 2013:

  • LC10: Training;
  • LC23: Operating Rules;
  • LC24: Operating Instructions;
  • LC28: Examination, Inspection, Maintenance and Testing;

LC 27 ‘Safety Mechanisms, Devices and Circuits’ was not considered applicable to this system based inspection as the equipment and facilities sampled were not considered to be safety mechanisms, circuits or devises as defined in the ONR Safety Assessment Principles. LC34 ‘Leakage and Escape of Radioactive Material and Radioactive Waste’ was also not considered applicable to this system based inspection as none of the equipment sampled contained radioactive material or radioactive waste.

We also performed a compliance inspection against LC 11 ‘Emergency Arrangements’.

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

Explanation of Judgement if Safety System Not Judged to be Adequate

The safety system was judged to be adequate, based on the sample inspected.

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

From the System Based Inspection on the emergency equipment, we concluded that:

  • LC 10 (Training) – We examined the training records of a number of personnel involved in the emergency scheme, including an Emergency Controller, an Assistant Access Controller and a Standby Emergency Response Team Member. We judged that the personnel undertaking these roles were suitably qualified and experienced. Therefore, we assigned a rating of Green (no formal action) for LC10 compliance.
  • LC 23 (Operating Rules) – We reviewed a number of technical specifications which specified limits and conditions of operation relating to emergency alarms and indications, emergency lighting and communication systems. We found these technical specifications to be straightforward and clear. In addition, the surveillance records and compliance check sheets demonstrated that the technical specifications were adhered to during operations. We therefore assigned a rating of Green (no formal action) for LC23.
  • LC 24 (Operating Instructions) – We examined a number of operating instructions relating to the operation of the back-up emergency feed system and the tie ins for the emergency decay store cooling. We judged these documents to be of an adequate standard and therefore assigned a rating of Green (no formal action) for LC24.
  • LC 28 (Examination, Inspection, Maintenance and Testing) – We sampled maintenance and testing records for a number of items of emergency equipment, including breathing apparatus and the back-up emergency feed system. We confirmed that regular maintenance and testing was being carried out and that maintenance instructions were clear and of sufficient quality. We identified a number of areas for improvement, but we judged these to be of minor safety significance and do not require follow up via regulatory issues. Overall, we judged from the records sampled and from the plant walkdown that the emergency facilities were being adequately maintained, and the required emergency equipment was maintained to an appropriate standard and available at the point of work. Therefore, we have given an IIS rating of Green (no formal action) for LC28.

The inspection targeted aspects of the stations LC11 arrangements associated with the emergency preparedness of facilities and response personnel pertinent to the scope of the SBI. We judged that NGL adequately demonstrated compliance with the requirements of LC 11 and therefore rated this inspection as Green (no formal action).

Conclusion of Intervention

After considering all the evidence witnessed during each of the sample inspections undertaken against LCs 10, 23, 24 and 28 we consider that the safety system meets the requirements of the safety case and is adequate.

Based on the sample taken against LC11, we were satisfied that there were no findings that could significantly undermine nuclear safety.  At present, no additional regulatory action is needed over and above the planned interventions at Torness Power Station as set out in the Integrated Intervention Strategy, which will continue as planned.