Executive summary
Date(s) of inspection: August 2022
Aim of inspection
This Safeguards ACP, BTC and accountancy Inspection in conjunction with nuclear safety is one of a programme of planned inspections at EDF Nuclear Generation Ltd. (EDF) during 2022/2023, developed in accordance with the Safeguards Sub-Division Strategy. This intervention against The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) has four parts:
- A site visit in support of a basic technical characteristics (BTC) assessment
- An accountancy focussed compliance inspection
- An Accountancy and Control Plan (ACP) Inspection
- An inspection against LC 25 - Operational Records.
The LC25 was undertaken jointly by ONR's Safeguards and Nuclear Safety purposes to build confidence in the arrangements put in place to support demonstration of Fuel Free Verification (FFV) for reactor fuel channels.
The Hunterston B station permanently shut down and began end of generation defuelling earlier this year. This intervention is designed to give ONR confidence that the arrangements and procedures for accountancy and control at Hunterston B are adequate and suitably implemented as the station moves through this new lifecycle phase and towards FFV.
Subject(s) of inspection
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 8 Data Processing and Control - Rating: Green
- LC 25 - Operational records - Rating: Green
- NSR19 Reg03 - Declaration of basic technical characteristics - 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 Reg19 Additional reporting obligations arising from relevant international agreements and from obligations resulting - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The intervention comprised of discussions with EDF staff, reviews of operating and accounting records and inspection of implementation of arrangements and procedures for accountancy and control throughout defuelling of the station.
Site visit in support of BTC assessment
Based on the sample I selected, and the plant walk down which I conducted as part of this intervention I am satisfied that the BTC document accurately reflects the Hunterston B facility as required by regulation 3 of NSR19. The BTC assessment findings will be relayed to EDF as part of the assessment process.
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 10, 11, 12, 14, 15, 18 and 19.
Accountancy and Control Plan Inspection
I inspected arrangements linked to NMAC throughout end of generation defuelling and I am satisfied based on the sample which I selected that the arrangements and procedures for described by the Hunterston B ACP are appropriately implemented at the site. I also inspected several arrangements linked to fuel free verification activities and am satisfied that they are appropriately implemented at Hunterston B. Overall I judge that EDF are meeting the requirements of NSR19 regulation 9.
Joint Safeguards and Nuclear Safety inspection of FFV arrangements
I inspected arrangements put in place to demonstrate reactor fuel channels are free of irradiated fuel and was satisfied they were adequate. I am satisfied based on my sample that the arrangements are being appropriately implemented at the site. I noted the site is proactively making improvements to its arrangements based on learning from undertaking defuelling operations to date; this is positive. I provided regulatory advice for the site's consideration. Overall I judge that EDF is meeting the requirements of Nuclear Site Licence Condition 25 (Operational Records).
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 regulations 3, 6, 9, 10, 11, 12, 14, 15, 18 and 19, and Nuclear Site Licence Condition 25.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
Site Visit in Support of BTC Assessment
Judgements and associated recommendations related to the assessment of the BTC will be described in full within the assessment record ONR-SAF-AR-004 (2022/51207).
Overall based on the evidence I saw as part of this site visit I am satisfied that BTC is accurate and arrangements described by the BTC are appropriately implemented on site.
Accountancy focussed compliance inspection
Based on the arrangements, NuMAS records and source documentation presented to me for the batches sampled above I am satisfied that EDF Hunterston B are implementing adequate arrangements for the tracking and accounting of nuclear material at the Hunterston B power station, satisfying the requirements of FSE 8. I judge that EDF Hunterston are complying with regulations 6, 9, 11, 12, 14 and 18.
Accountancy and Control Plan Inspection
Overall, based on the sample that I inspected, I am satisfied that the operator has in place proportionate arrangements for the movement of fuel around the plant and that those arrangements are appropriately implemented at the station in line with FSE 7 and regulations 10 and 11.
Joint Safeguards and Nuclear Safety Inspection of FFV arrangements
I am satisfied the arrangements put in place to demonstrate reactor fuel channels are free of irradiated fuel are adequate. I am satisfied based on my sample that the arrangements are being appropriately implemented at the site. I noted the site is proactively making improvements to its arrangements based on learning from undertaking defuelling operations to date; this is positive. I provided regulatory advice for the site's consideration. Overall, I judge that EDF is meeting the requirements of Nuclear Site Licence Condition 25 (Operational Records).