Executive summary
Date(s) of inspection: October 2024
Aim of inspection
ONR Nuclear Safeguards Inspectors visited the EDF Dungeness B station on 29 and 30 October 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 NSR19 regulations 6, 7, 9, 10, 11, 12, 15, 18 and 19. To form effective regulatory judgements on EDF's compliance with the NSR19 regulations listed, 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 Reg12 - Accounting reports - 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
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 the NSR19 Regulations 6, 7, 9, 10, 11, 12, 15, 18 and 19, and the ONR Nuclear Material Accountancy, Control, and Safeguards Assessment Principles (ONMACS) Fundamental Safeguards Expectations (FSEs) 3, 6, 7 and 8.
The inspection targeted the operator’s arrangements and their implementation for qualifying nuclear material (QNM) accountancy and control, defueling and fuel free verification, computer modelling for the generation of accountancy data, and competence management.
Based on the evidence sampled, plant walkdown and discussions I held with the key staff, I judge that EDF Dungeness B are implementing the arrangements described in their Accountancy and Control Plan (ACP) as required by NSR19 Regulations 7 and 9, and that the implementation of these arrangements is supporting the accountancy, tracking and control of QNM at Dungeness B, as required in NSR19 Regulations 6, 10, 11, 12, 15, 18 and 19, and FSEs 6, 7 and 8.
I provided Regulatory Advice in relation to FSE 7 for the addition of a step in the quality plan used for the dispatch of fuel transport flasks to enable sign off and traceability of the input of flask dispatch information into NuMAS. This regulatory advice will be followed up as part of routine regulation.
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. 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 FSE 3.
I was satisfied that the arrangements reviewed, records sampled, and evidence collected was adequate and I, therefore, judged EDF to be compliant against the NSR19 regulations and ONRs FSEs outlined above.
Conclusion
Based on the sample inspected, I judge that EDF Dungeness B are implementing their arrangements for accountancy and control of QNM, defueling and fuel free verification 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.