Executive summary
Date(s) of inspection: September 2023
Aim of inspection
ONR nuclear safeguards inspectors visited the EDF Nuclear Operations Hartlepool site on 19 September 2023 for the purpose of conducting a nuclear safeguards compliance inspection. The inspection had two purposes:
- An accountancy-focussed compliance inspection
- An inspection of personnel competence and resilience related to an existing fleet wide level three regulatory issue (RI-9025)
This intervention adopted a sampling approach to seek evidence in support of compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19). ONR formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance.
To form effective regulatory judgements on EDF’s compliance with NSR19, ONR considered expectations as outlined in the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: Green
- FSE 3 Competence Management - Rating: Green
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: Green
- NSR19 Reg10 - Operating records - Rating: Green
- NSR19 Reg11 - Accounting records - Rating: Green
- NSR19 Reg12 - Accounting reports - Rating: Green
- NSR19 Reg14 - Inventory change report - Rating: Green
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: Green
- NSR19 Reg18 - Reporting of nuclear transformations - Rating: Green
- NSR19 Reg19 Additional reporting obligations arising from relevant international agreements and from obligations resulting - 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 compliance inspection at the EDF Hartlepool site. The last safeguards intervention at Hartlepool was in March 2021 and this inspection aims to provide assurance that Hartlepool continues to account for and control their nuclear material as required by Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) and as expected by the ONR guidance on Nuclear Material accountancy, control and safeguards (ONMACS). For this intervention the Material Balance Area (MBA) known as QHPL was targeted.
This inspection included a safeguards accountancy focussed compliance inspection and an inspection of the arrangements for competence management and resilience against our expectations as described by the ONMACS. The intervention comprised of discussions with personnel, viewing source data and other documents, and a plant walk down, in order to gather evidence that arrangements are appropriately implemented and to make judgements of compliance against NSR19.
No significant shortfalls in compliance against NSR19 were identified during this intervention. Accountancy focussed compliance inspection. I am 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. Based on the inspection sample, I am satisfied that EDF has demonstrated adequate accountancy and control and is generating accounting and operating records that are complete and correct in line with NSR19 regulations 6 10, 11, 12, 14, 15, 18 and 19.
Inspection of the arrangements for competence management and resilience I inspected arrangements put in place for safeguards specific roles and resilience of those roles compared to the EDF organisational baseline. I sought evidence that those roles were appropriately filled and met the agreed actions of a level three regulatory issue (RI-9025). I am satisfied based on my sample that the competence management arrangements are being appropriately implemented at the site and that there is sufficient resilience in those roles which I sampled when compared to the EDF organisational baseline. Overall, I judge that EDF is meeting the requirements of NSR19 regulation 9, and my expectations as described by the ONMACS and I rated this inspection Green.
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, 11, 12, 14, 15, 18, and 19. Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate Accountancy focussed compliance inspection Based on the arrangements, NuMAS records and source documentation presented to me for the batches sampled, I am satisfied that EDF Hartlepool are implementing adequate arrangements for the tracking and accounting of nuclear material at the Hartlepool power station, satisfying the requirements of FSE 7 and 8. I judge that EDF Hartlepool are compliant with regulations 6, 10, 11, 12, 14, 15, 18 and 19. Inspection of the arrangements for competence management and resilience. Based on my sample, I am satisfied that EDF at Hartlepool are implementing their arrangements described by the ACP, and hence meeting the requirements of NSR19 regulation 9. They are also meeting my expectations for competence management and resilience as described by the ONMACS.I also judge that I have seen sufficient and appropriate evidence to recommend the de-escalation of RI-9025 from level three to level four.