Executive summary
Date(s) of inspection: October 2023
Aim of inspection
ONR nuclear safeguards inspectors visited the EDF Nuclear Operations Heysham 1 site on 23 October 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
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
- 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
- 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 Heysham 1 site. The last safeguards intervention at Heysham 1 was in January 2022 and this inspection aimed to provide assurance that Heysham 1 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 QHEY was targeted.
This inspection included a safeguards accountancy-focussed compliance inspection and an inspection of the arrangements for personnel competence management and resilience against ONR’s expectations as described by the ONMACS. The intervention comprised discussions with personnel, viewing source data and other documents 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. I am also satisfied based on my sample that EDF are meeting ONR’s regulatory expectations as detailed in ONMACS Fundamental Safeguards Expectations (FSEs) 7 and 8.
Inspection of the arrangements for competence management and resilience
I inspected arrangements put in place for safeguards specific roles and the 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.
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 safeguards specific 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 FSEs 1 and 3.
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 and are meeting my expectations under FSE 1, FSE 3, FSE 7, and FSE 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.I also judge that I have seen sufficient and appropriate evidence to recommend the de-escalation of the regulatory issue relating to personnel competence and resilience,from level three to level four.