- Site: Hinkley Point B
- IR number: 21-023 (SAF)
- Date: November 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This inspection was one of programme of planned inspections at EDF Nuclear Generation Ltd. (EDF NGL) reactor sites during 2021/22, developed in accordance with the Safeguards Sub-Division strategy. This inspection was a system-based inspection judging the adequacy of systems structures and components (SSCs) integral to Nuclear Material Accountancy and Control (NMAC).
Purpose of Intervention
The purpose of the intervention was to gain assurance (on a sample basis) that the Nuclear Material Accountancy System (NuMAS) at Hinkley Point B (QHLB) is fit for purpose and is implemented in a proportionate and appropriate manner, as required by regulation 6 of the Nuclear Safeguards (EU Exit) Regulations 2019. In particular, the inspection aimed to obtain assurance that:
- NuMAS is proportionate to and appropriate for the Basic Technical Characteristics (BTC) of Hinkley Point B;
- NuMAS is implemented adequately, and delivers its functions as claimed within Hinkley Point B’s Accountancy and Control Plan (ACP) and their arrangements; and
- NuMAS fulfils (where relevant) ONR’s regulatory expectations regarding the regulations and expectations targeted (outlined below and detailed further in the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS).
Interventions Carried Out by ONR
The inspection examined the NuMAS system at Hinkley Point B against the following Fundamental Safeguards Expectations as detailed in the ONMACS document:
- FSE 3 – Competence Management
- FSE 5 – Reliability, Resilience and Sustainability
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Control
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspection comprised of demonstrations by Hinkley Point B staff of the inputs into and outputs of the NuMAS system, the examination of source documents underpinning NuMAS data, the discussion of NuMAS role profiles and the examination of associated training records, and a discussion of the resilience of NuMAS and its users.
On the basis of the evidence sampled, I found that Hinkley Point B is implementing adequate arrangements to manage the competence of staff using the NuMAS system. I provided regulatory advice on how Hinkley Point B could improve these arrangements by including certain suitably qualified and experienced personnel in the oversight body for these arrangements.
I found that Hinkley Point B is implementing adequate arrangements to maintain the reliability, resilience, and sustainability of the NuMAS system. I advised Hinkley Point B that it is good practice to build resilience in human resources, and they could improve the breadth of organisational competence for entering information into NuMAS.
I found that Hinkley Point B is implementing adequate arrangements to track nuclear material in the form of fuel and in the form of depleted uranium shields. I found that the absence of systematic or recorded checks in these arrangements creates a risk that incorrect data may be entered into NuMAS. I consider this a minor shortfall against the requirements of regulation 6(3) as explained in FSE 7. I also found that Hinkley Point B is not implementing adequate arrangements to track nuclear material in the form of neutron flux measuring assemblies; the locations and identities of which are not adequately set out in their system of accountancy and control. This is a minor shortfall against regulation 6(2) of NSR19. I have raised level 4 regulatory issues to track the remediation of these shortfalls.
I found that Hinkley Point B is implementing adequate data processing arrangements to produce accounting reports as required by regulation 12 of NSR19. I found a minor shortfall in these data processing arrangements against regulation 14(1). I have raised a Level 4 Regulatory Issue to track its remediation.
I found arguments within Hinkley Point B’s ACP that did not accurately reflect the arrangements and procedures being implemented on site. These are a minor shortfall against regulation 9(1) of NSR19. I provided regulatory advice regarding the inaccuracies identified during the inspection. I also provided regulatory advice regarding the regulatory requirements for updates to BTC and ACP submissions in the event of a change in operational status of Hinkley Point B.
I observed Hinkley Point B proactively identifying discrepancies in their records and issues with their arrangements, and examples of good procedural adherence by operational technicians.
Conclusion of Intervention
The inspection demonstrated that the NuMAS system at Hinkley Point B is fit for purpose and is implemented in a proportionate and appropriate manner. The inspection recognised the good practiced demonstrated by Hinkley Point B’s proactive identification of shortfalls in NuMAS and provided Hinkley Point B with regulatory advice on improvements that could be made to arrangements supporting NuMAS. While the inspection identified three shortfalls, I consider these minor and I rate the inspection green (No formal enforcement).