Executive summary
Date(s) of inspection:
October 2025
Aim of inspection
This was a planned inspection of EDF Nuclear Generation Limited's (NGL's) operational arrangements for Seasonal, Severe Weather and Marine Impact Preparations (“Seasonal Readiness”), and implementation of those arrangements, at Torness Nuclear Power Station (TOR). The purpose of this activity was to ensure that the licensee is adequately managing risks associated with seasonal hazards. Seasonal readiness arrangements include routine activities and other preparations (e.g., defects and asset maintenance) intended to mitigate risks associated with predictable summer and winter conditions.
Subject(s) of inspection
- LC 10 - Training - Rating: GREEN
- LC 17 - Management systems - Rating: Not Rated
- LC 24 - Operating instructions - Rating: AMBER
- LC 28 - Examination, inspection, maintenance and testing - Rating: GREEN
- Overall Inspection Rating - Rating: AMBER
Key findings, inspector's opinions and reasons for judgement made
Only those LCs for which sufficient evidence was gathered during the inspection activity have been rated.
LC10 Training - Green rating (No formal action) - This rating was considered appropriate based on our sample because EDF NGL staff were assigned training relevant to their roles and sufficient evidence was provided to demonstrate they had been adequately trained to deliver those roles. Regulatory advice was provided that general hazard awareness training may be beneficial for roles involved with seasonal readiness, as it is currently not a mandatory requirement. This advice will be followed-up through routine engagements with EDF NGL.
LC17 Management Systems - Not rated. Insufficient evidence was gathered during the inspection activity to rate this LC. EDF NGL's arrangements for controlling seasonal readiness works were assessed under LC28.
LC24 Operating Instructions - Amber rating (Seek improvement) - This rating was considered appropriate based on our sample of operating instructions for relevant seasonal hazards. We identified unclear and ambiguous instructions, and an adequate risk assessment was not available for hazards introduced by portable equipment that could be deployed in nuclear safety significant plant areas. A regulatory issue has been raised for EDF NGL to review its operating instructions for hazards and to address the identified gaps. Compliance with the corporate specification for seasonal readiness was not well evidenced for all required activities. This will be followed-up through engagements with relevant EDF NGL corporate teams to ensure adequate guidance and oversight is being provided to the stations.
LC28 Examination, Inspection, Maintenance and Testing - Green rating (No formal action) - This rating was considered appropriate based on our sample because EDF NGL provided sufficient evidence to demonstrate that routine seasonal readiness activities were being delivered and relevant plant defects are actively managed. Regulatory advice was provided that some seasonal readiness activities would benefit from being formalised including the routine inspection of civil structures and recording of decisions. This will be followed-up through engagements with relevant EDF NGL corporate teams. EDF NGL's prioritisation of civil structure defects that might be affected by predictable seasonal hazards was not adequately demonstrated during the inspection. Alongside other risks, the glazing system was identified by a report as ‘critical’ and ‘high risk’ but has not been addressed by the station. Damaged panes are remediated, but this does not mitigate risks from the overall system. Further inspections of cladding, louvres and glazing are planned by EDF NGL to inform condition and prioritisation of works, and a possible method of strengthening the glazing has been identified. A regulatory issue has been raised to ensure planned activities are delivered and a risk-informed strategy for managing the civil assets and appropriately prioritising defects is developed.
Conclusion
This inspection has been awarded an overall inspection rating of Amber (Seek improvement) based on our sample. The reasons for this are:
- Operating instructions relevant to hazards are ambiguous and some activities are not supported by appropriate procedures or risk assessments.
- It is not clear how civil asset defects are being managed and prioritised based on risks.
Regulatory issues have been raised for EDF NGL to address the identified gaps. Regulatory advice has been provided to EDF NGL in relation to other relevant matters. We will ensure this advice is acted upon through appropriate follow-up activities.