- Site: Hartlepool
- IR number: 21-042 (SAF)
- Date: March 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, ONR Safeguards carries out several 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 Hartlepool - Material Balance Area (MBA) QHPL. 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 regulatory expectations as described in the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS):
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Control
Interventions Carried Out by ONR
I carried out an accountancy focused compliance inspection at the Hartlepool site. The inspection comprised of discussions with EDF staff, review of operating and accounting records, arrangements and procedures for accountancy and control.
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. 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 Hartlepool were adequately implemented.
This intervention was performed in line with our 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 Hartlepool 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.
I reviewed, on a sampled basis, source documentation covering the material flows at the site, including the Hartlepool reactors, storage ponds and the Fresh Fuel Store. I found the source documentation to be complete, correct, and traceable to the relevant accountancy declarations.
I sampled several arrangements and procedures associated with the fuel route which are used in the accountancy and control of QNM at the site and found them to be appropriately implemented.
I provided one piece of regulatory advice during my inspection relating to competence management and resilience of staff with responsibilities for accountancy and control of nuclear material. I judge that the shortfall does not have a significant and urgent adverse effect on the accountancy and control of nuclear material at Hartlepool. I added the finding to an existing regulatory issue to be tracked through normal regulatory business.
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 Hartlepool site.
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, 18 and 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.