Executive summary
Date(s) of inspection: July 2024
Aim of inspection
ONR nuclear safeguards inspectors visited the EDF Torness station on 16 July 2024 in order to conduct a nuclear safeguards compliance inspection. The purpose of this inspection was to seek evidence in support of EDF's 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 of EDF's compliance against the following Regulations in NSR19 6, 7, 9, 10, 11, 12, 15, 18, and 19. To form effective regulatory judgements on EDF's compliance with the NSR19 regulations listed above, inspectors considered the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) and the expectations within. This inspection focussed particularly on FSEs 3, 6, 7, and 8
Subject(s) of inspection
- FSE 3 Competence Management - 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 Reg07 - Accountancy and control plan - 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 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
Key findings, inspector's opinions and reasons for judgement made
Purpose of intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2024/25 for EDF, this inspection was performed to inspect EDF’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy.
This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 7, 9, 10, 11, 12, 15, 18, and 19 and FSEs 3, 6, 7, and 8.
Interventions carried out by ONR
The inspection targeted the operator’s arrangements for nuclear material accountancy and control and their implementation, arrangements to utilise computer modelling for the generation of accountancy data, and arrangements for competence management.
Key findings, inspector's opinions and reasons for judgements made
Based on the sample I inspected, I judge that EDF has adequately implemented their accountancy and control arrangements at Torness. I judge that the records were appropriate, traceable to, and adequately underpin the inventory change reports submitted to ONR in line with NSR19 Regulation 14. I provided EDF with regulatory advice relating to corrective actions following previous errors recording qualifying nuclear material in the wrong units; I advised that EDF confirm recording actions to prevent recurrence within their procedures.
Based on the plant walkdown and discussions I held with the key staff I judge that EDF are implementing the arrangements described in their Accountancy and Control Plan (ACP) as required by NSR19 Regulation 9 and that implementation of these arrangements is supporting the accountancy and control of qualifying nuclear material at Torness, as required in NSR19 Regulation 6.
I sampled the implementation of competence management arrangements for safeguards personnel and for the nuclear safety group personnel involved in the generation of data for safeguards purposes. I provided regulatory advice that staff who have been exempted from the use of mentor guides on the basis of “grandfather rights” have written exemption forms or complete a mentor guide based on their competence. Based on the sample I selected, I judge that EDF are implementing their arrangements for competence management and are meeting ONR expectations as described by FSE3 of the ONMACS.
I was satisfied that the documentation reviewed, records sampled, and evidence collected was adequate and I, therefore, judged EDF to be compliant against NSR19 and ONRs expectation as outlined in the ONMACS.
Conclusion of intervention
Based on the sample inspected during the intervention, I judge that EDF at Torness are implementing their arrangements for accountancy and control of QNM in QS20 in line with regulatory expectations and are compliant with NSR19 Regulations 6, 7, 9, 10, 11, 12, 15, 18, and 19 and FSEs 3, 6, 7, and 8.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
Conclusion
Based on the sample inspected, I judge that EDF Torness are implementing their arrangements for accountancy and control of QNM in-line with regulatory expectations and are compliant with NSR19 requirements. Regulatory advice provided during this inspection will be followed up as part of routine regulation.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.