Executive summary
Date(s) of inspection: February 2024
Aim of inspection
The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) require in Regulation 6 that operators “maintain a system of accountancy and control” and that the components of this system must be implemented “in a manner which is proportionate to and appropriate for the basic technical characteristics of the qualifying nuclear facility”.
ONR nuclear safeguards inspectors conducted a Safeguards Systems Based Inspection (SSBI) at EDF Nuclear Generation Ltd. (EDF) which covered the use of PANTHER across the EDF fleet.
PANTHER is one of several systems identified at EDF which plays a critical role in nuclear material accountancy control and safeguards (NMACS); In particular PANTHER is the system which calculates changes in the composition of Qualifying Nuclear Material (QNM) as a result of fuel being irradiated in a reactor. This inspection aimed to evaluate whether the system is fit for this purpose and is implemented in an appropriate and proportionate manner as required by NSR19. In particular, this inspection aimed to obtain assurance that:
- The use of PANTHER is both appropriate and proportionate to the basic technical characteristics for each of the EDF facilities
- That PANTHER is fit for purpose and meets functional requirements for NMACS
- That PANTHER is appropriately implemented according to EDF’s own arrangements
- That PANTHER fulfils ONR’s regulatory expectations as listed below and described by the ONR Nuclear Material Accountancy, Control, and Safeguards Assessment Principles (ONMACS)
Subject(s) of inspection
- FSE 3 Competence Management - Rating: Green
- FSE 5 Reliability, Resilience and Sustainability - Rating: Green
- FSE 6 Measurement Programme and Control - Rating: Green
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 8 Data Processing and Control - Rating: Green
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: Green
- NSR19 Reg09 - Operation of an accountancy and control plan - Rating: Green
- NSR19 Reg10 - Operating records - Rating: Green
- NSR19 Reg11 - Accounting records - Rating: Green
- Overall Inspection Rating - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2023/24 for EDF, ONR Safeguards conducted a safeguards system based inspection of the EDF PANTHER and associated systems with support from specialist inspectors from the ONR Nuclear Safety purpose. This was the first inspection of this system and this inspection aims to provide assurance that PANTHER meets the requirements of a safeguards system as required by Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) and the expectations as described by the ONR guidance on Nuclear Material accountancy, control and safeguards (ONMACS).
The intervention comprised discussions with personnel, sampling source data and other documents in order to gather evidence that arrangements are appropriately implemented and to make judgements of compliance against NSR19.
I gave one piece of regulatory advice to EDF related to the consistency of templates for competence management arrangements for PANTHER across the fleet. I also identified one minor shortfall in the consistency of completion of those mentor guides and as such am raising a L4 regulatory issue to track a review of arrangements for completion of those guides. No significant shortfalls in compliance against NSR19 were identified during this intervention.
Overall, based on the sample inspected during the intervention I judge that EDF is compliant with the requirements of NSR19 regulations 6, 9, 10, 11, and 12 and are meeting my expectations under FSEs 3, 5, 6, 7 and 8 of the ONMACS.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate against each of those expectations listed above
Conclusion
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the sample inspected during the intervention I judge that EDF is compliant with the requirements of NSR19 regulations 6, 9, 10, and 11, and are meeting my expectations under FSEs 3, 5, 6, 7 and 8 of the ONMACS.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of green (no formal action) is appropriate against each of those expectations listed above.