Executive summary
Date(s) of inspection: October 2024
Aim of inspection
ONR has been undertaking a series of LC28 themed inspections. The aim of these inspections is to carry out a broad sample to determine the adequacy of LC28 compliance arrangements across the EDF NGL sites.
Subject(s) of inspection
- LC10 - Training - Rating: GREEN
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating: Green
- LC28 - Examination, inspection, maintenance and testing - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
We held a series of discussions with station engineering personnel covering a variety of engineering topics. Prior to the inspection we provided station with a scope and agenda for the inspection which formed the basis of the discussions. Station provided, and presented a comprehensive suite of documentation during the inspection and questions were clarified during the course of the discussions. Additional evidence was requested during the inspection for clarification purposes.
A number of topics were covered under the management system related to engineering and maintenance including:-
- Governance and performance indicators
- System Health and system walkdowns
- Preventative Maintenance Delivery and Optimisation
- Equipment Reliability Reviews (ERRs) and Lifetime Asset Management Plans (LAMPS)
- Work Prioritisation
- 3rd Party Recommendations
- Safety Case, Safety Case Health Reviews & Maintenance Schedule
- Ageing & Obsolescence
- Technical Governance
- Corrosion
- Training and SQEP
Based on my sample, the ERRs are being delivered to schedule and 3rd party recommendations are dealt with adequately. One observation was raised on how lower category LOLER defects are being tracked and sentenced which I will follow up through a level 4 regulatory issue. The corrosion programme is being managed and station has taken action to improve corrosion technical governance. The preventative maintenance programme is being managed effectively. Advice and observations were offered in a number of areas to influence the station to make further improvements.
From a training and SQEP perspective, it is recognised that there has been a change in demographics within the engineering department and "experience" levels have reduced, but station engineering management are being proactive to identify vulnerabilities to the team retention, which was welcomed. It was apparent that staff in the department understand their roles and responsibilities and take an active role in managing their training and development. The management of system engineer training and staff development was discussed and sampled, which is considered to be systematic and well considered. However it was noted that this management is delivered through local practices implemented by line managers rather than following an agreed approach across station teams. Some observations relating to the adequacy of the management and oversight of staff experience and competence development were identified which will be provided to the NGL Corporate Services Training team during routine regulatory engagements.
Conclusion
Overall there was evidence to suggest that engineering oversight at Torness is being effectively governed. The engineering function at Torness adequately fulfils its function of trending and reviewing system health. I was content that the engineering lead team understood its role and responsibilities and has the necessary governance arrangements in place to help them deliver this. One minor regulatory issue has been raised in relation to the governance and oversight for sentencing category B and C defects raised in LOLER inspection reports. A small number of observations and advice was provided which have been communicated to station and if acted upon will assist in further strengthening the engineering function. As no significant issues were raised I have rated the intervention as GREEN against LC28 (Maintenance, Examination, Inspection and Testing); LC10 (Training) and LC12 (Duly Authorised and other suitably qualified and experienced persons).