Office for Nuclear Regulation

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EDF Energy, Nuclear Generation Ltd (NGL), Corporate Inspection of LC5 (including elements of LC25) Arrangements

Executive summary

Purpose of intervention

This was a planned inspection of the EDF Nuclear Generation Limited (NGL) corporate arrangements for the Management of nuclear matter, including AGR fuel and waste.

Interventions Carried Out by ONR

We carried out a planned compliance inspection against Licence Condition 5 (LC5) 'Consignment of Nuclear Matter' and the relevant aspects of Licence Condition 25 'Operational Records'. The inspection focussed on the adequacy of the corporate management arrangements for Advanced Gas Cooled Reactor (AGR) Fuel and the transport of nuclear matter and waste and Carriage of Dangerous Goods (CDG).

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

We discovered that overall LC5 compliance is spread across three management system processes, namely Management of Nuclear Fuel, Environment and Radiological Protection, together with their associated procedures. We noted that the Licence Condition compliance statements for LC5 and 25 did not include all the primary implementation procedures and the licensee undertook to amend the statements accordingly.

The corporate team has recently been reorganised and the documentation is being progressively revised based on the Governance, Oversight, Support and Perform (GOSP) Model. The Management of Nuclear Fuel Process has three interrelated legs, Management of AGR Fuel, Management of PWR Fuel and CDG. We focussed on the corporate arrangements associated with the Management of AGR Fuel and CDG arrangements and were content that the revised arrangements are adequate for the reorganised corporate team and that the arrangements are being introduced in a controlled and systematic manner.

We examined the corporate arrangements for the Nuclear Material Accounting System (NUMAS). NUMAS is a well-established system for which the corporate team are the custodians and the stations are the 'users'. The Corporate Team were able to demonstrate the basic features of the system and identify the information, reports and analysis the stations can extract from it when they have populated it with data. The system software is due to be updated and a project proposal is currently being progressed through the 'gated' project process.

Conclusion of Intervention

From the arrangements sampled, the LC5 and LC25 (2) Corporate Management arrangements for nuclear matter, including AGR fuel and waste have been rated Green, meaning that ONR has raised no issues.

Recommendations

No formal recommendations were raised although a number of comments were given to the licensee in the spirit of continuous improvement.