- Site: Torness
- IR number: 21-005 (SAF)
- Date: May 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This Intervention Record (IR) details the safeguards systems-based inspection conducted at EDF NGL Torness (QTSA). The purpose of this inspection was for the ONR to determine the adequacy of implementation of EDFs arrangements and procedures for accountancy and control with respect to the NuMAS electronic accountancy and control system.
This planned intervention took place 11 – 13 May 2021 and was undertaken in accordance with the Safeguards subdivision operational schedule for 2021/2022.
Interventions carried out by ONR
I examined evidence of the implementation of arrangements and procedures for the operation of NuMAS against four Fundamental Safeguards Expectations (FSEs) as described in the ONMACS. These FSEs (listed below) were selected in view of their importance to NMAC&S and in providing a structured approach to determining whether the dutyholder’s arrangements have been implemented adequately through the system being inspected.
- FSE 3 – Competence Management
- FSE 5 – Reliability, Resilience and Sustainability
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Control
This SSBI did not examine FSE 6 – Measurement Programme and Control, as no measurement takes place at EDF sites.
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found at Safeguards Inspection Guidance (onr.org.uk)).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection, no matters were identified requiring immediate regulatory attention.
FSE 3 (Competence Management) – Based on evidence sampled during the inspection, EDF did not demonstrate that adequate competency management arrangements such as role profiles, are implemented for their NMAC staff at Torness. This is a shortfall against NSR19 Regulation 9 (Operation of their ACP) as the ACP states that all NMAC staff have Role profiles and does not meet the expectations set out in MACE 3.1 and 3.2 of the ONMACS. EDF have provided me with an outline plan to develop role profiles for those staff with NMAC responsibilities, however I am not fully satisfied that this plan alone adequately addresses the underlying issues with the competence management of NMAC staff at Torness. I will raise a level 3 regulatory issue to seek improvements which may entail training needs analysis and development of role profiles at Torness. The same regulatory issue will also track a resiliance study as outlined by a shortfall against FSE5.
Based on the above, I am assigning a rating of Amber for FSE 3.
FSE 5 (Reliability, Resilience and Sustainability) - Based on the evidence I sampled, I judge that EDF NGL have proportionate and appropriate arrangements in place to support the reliability, resilience, and sustainability of the NuMAS software and its underlying database. I have seen evidence of the adequate implementation of these arrangements and procedures with only minor shortfalls. There is evidence that EDF are lacking personnel resiliance in NuMAS users and I propose including an EDF resiliance study in the L4 regulatory issue which will be raised under FSE3. This is a minor shortfall and I therefore assigned a rating of Green for FSE 5.
FSE 6 (Measurement Programme and Control) – EDF do not conduct any measurement activities at their sites, therefore this expectation is not applicable to EDF SSBIs.
FSE 7 (Nuclear Material Tracking) – Based on the evidence sampled, EDF were able to demonstrate an ability to identify, quantify, and characterise material throughout the site. I reviewed evidence of several items throughout the fuel route including an item of non-fuel fissile material. I judge that, on the evidence sampled, EDF adequately implemented their arrangements under FSE 7 and therefore, I assigned a rating of Green for FSE 7.
FSE 8 (Data Processing and Control) – EDF demonstrated an ability to; effectively manage reports and associated NMAC&S data, produce reports in a timely manner and in the correct format, and reconcile reports against source data. I identified a shortfall relating to the capability of NuMAS in accurate reporting of category changes on irradiated fuel shipped from all EDF sites. I will raise a level 4 regulatory issue for EDF NGL corporate to address this shortfall. Overall, I judged that, on the evidence sampled, the dutyholder had adequately implemented their arrangements under FSE 8. Therefore, I assigned a rating of Green for FSE 8.
Conclusion of Intervention
Based on the evidence sampled during this inspection, I judge that there was sufficient evidence that the dutyholder has broadly complied with all legal duties and adequately implemented those ACP claims for FSE’s 5, 7 and 8 that relate to the sampled SSCs. For FSE 3, I judged an Amber rating to be proportionate to ensure that operator addressed the identified shortfalls in a timely manner.