- Site: Heysham 1
- IR number: 21-034 (SAF)
- Date: February 2022
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2021/22 for EDF Nuclear Generation Ltd. (EDF), ONR carries out safeguards compliance inspections across the EDF fleet. One such intervention was performed to assess compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy at Heysham 1 - Material Balance Area (MBA) QHEY.
I carried out an accountancy focused compliance inspection at the Heysham 1 site. The purpose of this accountancy focused inspection is to provide confidence to ONR that the operator is making adequate operating records and accounting records, which are traceable to the accounting reports, and are underpinned by suitable accountancy arrangements.
This inspection sought evidence of arrangements and their implementation to make judgements of compliance against the following regulations in NSR19:
- Regulation 9 – Operation of an accountancy and control plan
- Regulation 10 – Operating records
- Regulation 11 – Accounting records
- Regulation 12 – Accounting reports
- Regulation 14 – Inventory change report
- Regulation 15 - Material balance report and physical inventory listing
- Regulation 18 – Reporting of nuclear transformations
- Regulation 19 - Additional reporting obligations arising from relevant international agreements and from obligations resulting from international trade.
To form effective regulatory judgements on EDF’s compliance with NSR19, I also considered the following expectations as described by the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS):
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Control
- FSE9 – Material Balance
Interventions Carried Out by ONR
The inspection comprised of discussions with EDF staff, reviews of operating and accounting records, arrangements and procedures for accountancy and control, and a plant walkdown.
The inspection targeted the completeness and correctness of the operating and accounting records (source documentation) which underpinned a sample of batches of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility ranging from February to November 2021. The inspection also targeted whether these source documents were traceable to the accountancy reports and whether arrangements for generation of source documentation and accountancy reports at Heysham 1 were adequately implemented.
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on our website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I undertook discussions with the key EDF staff involved in accounting for and controlling nuclear material at the Heysham 1 site and gathered evidence that shows adequate implementation of suitable arrangements for accountancy and control of QNM. I was satisfied that EDF presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted to ONR under Regulation 14 of NSR19.
The scope of this inspection also included a PITe, however due to the simplistic nature of a PIT at EDF sites and the timing of the inspection, I was unable to obtain evidence of implementation of PIT arrangements as no physical evidence was available. I was however able to run through the Heysham 1 arrangements for conducting a PIT with The Operator and I judge that those arrangements accessible and well understood by The Operator and proportionate to the basic technical characteristics of the site.
I provided two pieces of regulatory advice during my inspection related to competence management and resilience. I judge that neither shortfall has a significant and urgent adverse effect on the accountancy and control of nuclear material at Heysham 1. I added the findings to an existing regulatory issue to be tracked through normal regulatory business.
I made two minor safety observations during the inspection, I raised these with The Operator during the inspection/hot feedback and subsequently provided feedback to the Nominated Nuclear Safety Inspector for follow-up as appropriate.
Overall, based on the inspection sample, I am satisfied that EDF has demonstrated adequate accountancy and control, is generating accounting and operating records that are complete and correct and is implementing its arrangements for accountancy and control for its QNM at the Heysham 1 site that meet relevant good practice.
I provided feedback to the site on the inspection findings at a close-out meeting.
Conclusion of Intervention
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the inspection sample I judge EDF is compliant with the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 9, 10, 11, 12, 14, 15 & 19, and noting ONR guidance on inspection ratings, I consider this inspection to merit a rating of GREEN. I did not find any significant shortfalls and do not plan to raise any regulatory issues based on this inspection.