Date(s) of inspection:
- July 2023
Aim of inspection
The aim of this inspection is to;
- To provide regulatory confidence in the implementation of the LC22 Offload Depressurised Refuelling (ODR) arrangements and sample the future plans following the decision that station will not be returning to Low Power Refuelling (LPR).
- To sample the adequacy of Training (LC10) and DAP SQEP (LC12) of operations personnel pre and post ODR implementation.
- To establish the adequacy of stations Organisational Capability (LC36) pre and post ODR implementation, to include future plans following the decision that station will not be returning to Low Power Refuelling (LPR).
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC22 – Modification or experiment on existing plant – Rating: Green
- LC36 – Organisational capability – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
This themed inspection at Torness power station focused on the arrangements (and the implementation of those arrangements) that have been established for Off Load Depressurised Re-fuelling (ODR) operations. It was announced in June 2022 that ODR will be the chosen method of re-fuelling the reactors at Torness until the end of generation. The aim of this inspection was to provide ONR with regulatory confidence in the implementation of the arrangements established for ODR operations and compliance with licence conditions 10 Training, 12 DAP and SQEP, 22 Modification or Experiment on existing plant and 36 Organisational Capability.
From the sample inspected, EDF Energy NGL adequately demonstrated the implementation of the arrangements established for ODR or licence conditions 10, 12 and 22, included in the inspection sample was the training and SQEP requirements identified and undertaken for operations personnel, a sample of the engineering change documentation associated with safety case updates, equipment modifications and the methodology for associated instruction changes was undertaken. Station demonstrated that these aspects were adequately implemented through the sample undertaken.
From an LC36 organisational capability perspective, I noted that the station has made various organisational changes over the past two years associated with introduction of ODR, including new roles, secondments between departments, and changes to work allocation. However I found significant shortfalls in the adequacy of the documentation to justify the safety of these changes. Specifically, the station did not apply its LC36 management of organisational change (MOC) arrangements at the time the changes were made. Furthermore the MOC document it has produced subsequently, in my judgement, does not apply the correct criteria to the categorisation of the change or define the scope of the change adequately. I consider it important that the station can demonstrate adequate control of the ODR-related organisational changes given the ramifications across the station, both direct and indirect, for roles, responsibilities and workloads. I have therefore raised a regulatory issue for the licensee to review and revise its MOC documentation for these changes.
On the basis of the evidence sampled, ONR were provided with regulatory confidence in the implementation of the arrangements for ODR operations and were able to adequately demonstrate compliance with licence condition 10, 12 and 22 aspects of the inspection at Torness. Noting ONR guidance on inspection ratings, it is our opinion that an inspection rating of Green – Adequate rating for licence conditions 10, 12 and 22.
For licence condition 36, the inspection findings highlighted a significant shortfall in the station’s application of its MOC arrangements. ONR judge this to be significant because of the ramifications of ODR – direct and indirect – across the station in terms of roles, responsibilities and workload of staff. Noting ONR guidance on inspection ratings, it is our opinion that an inspection rating of Amber – Below standard for licence condition 36. A level 3 regulatory issue will be raised to track the improvements necessary to address this shortfall.