Executive summary
Date(s) of inspection:
- October 2022
Aim of inspection
This intervention was 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 was an Accountancy and Control Plan (ACP) Compliance Inspection at Dungeness B, Material Balance Area (MBA) QDUB. The purpose of an ACP inspection is to ensure that the operator has established a robust accountancy and control system and that its implementation complies with the requirements specified in the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) regulation 9 - Operation of an accountancy and control plan.
Subject(s) of inspection
- FSE 3 Competence Management - Rating: Green
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 8 Data Processing and Control - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
I inspected arrangements for competence management at Dungeness B. EDF were unable to provide evidence that role requirements associated with suitably qualified and experienced personnel (SQEP) included the necessary references to of site-specific procedures. In response to this minor shortfall, I have added a new action to an existing regulatory issue to track resolution of this minor shortfall. I am satisfied based on the sample which I selected that the remaining competence management arrangements and procedures described by the ACP are appropriately implemented at Dungeness B.
I inspected arrangements for nuclear material tracking and data processing and control at Dungeness B. Based on the sample that I inspected I am satisfied that those arrangements described in the ACP are appropriately implemented at the site.
Overall, based on the sample that I inspected I am satisfied that EDF Dungeness B are meeting the requirements of NSR19 regulation 9 and are meeting ONR expectations FSE3, FSE7 and FSE8 as described by the ONMACS
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the sample inspected during the intervention I judge that EDF is appropriately implementing their arrangements for those areas inspected and is compliant with the requirements of Regulation 9 – Operation of an ACP.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
I inspected arrangements for nuclear material tracking and data processing and control at Dungeness B. Based on the sample that I inspected I am satisfied that those arrangements described in the ACP are appropriately implemented at the site.
Overall, based on the sample that I inspected I am satisfied that EDF Dungeness B are meeting the requirements of NSR19 regulation 9 and are meeting ONR expectations FSE3, FSE7 and FSE8 as described by the ONMACS
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the sample inspected during the intervention I judge that EDF is appropriately implementing their arrangements for those areas inspected and is compliant with the requirements of Regulation 9 – Operation of an ACP.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
Conclusion
Overall, I did not identify any significant shortfalls against NSR19, or our expectations as described by the ONMACS.
FSE3
FSE3
Based on the arrangements which I sampled as part of this intervention, I am satisfied that Dungeness B has appropriately implemented its arrangements for competence management of safeguards personnel using both PANTHER and NuMAS.
While I am satisfied that the operator can demonstrate competence of safeguards personnel, there is lack of written explanation of the competency requirements for safeguards personnel at Dungeness B. Level 3 regulatory issue 9025 led to new role and training profiles for safeguards personnel across the fleet, however I judge that station specific arrangements or explanation for competence requirements are still missing, and this is likely to apply to the entire fleet, not just Dungeness B. I have therefore added a new action to RI-9025 for EDF to propose a solution to this lack of “golden thread” between the RTPs and individual competence of safeguards personnel.
Overall, I am satisfied that Dungeness B meet my expectations as described by FSE3 and are meeting the requirements of regulation 9 – Implementation of the ACP.
FSE7 and FSE8
Based on the arrangements, NuMAS records and source documentation presented to me I am satisfied that EDF Dungeness B are implementing adequate arrangements for nuclear material tracking and data processing and control, satisfying my expectations as described by FSE7 and FSE8. I judge that EDF Dungeness B is complying with regulations 9.
While I am satisfied that the operator can demonstrate competence of safeguards personnel, there is lack of written explanation of the competency requirements for safeguards personnel at Dungeness B. Level 3 regulatory issue 9025 led to new role and training profiles for safeguards personnel across the fleet, however I judge that station specific arrangements or explanation for competence requirements are still missing, and this is likely to apply to the entire fleet, not just Dungeness B. I have therefore added a new action to RI-9025 for EDF to propose a solution to this lack of “golden thread” between the RTPs and individual competence of safeguards personnel.
Overall, I am satisfied that Dungeness B meet my expectations as described by FSE3 and are meeting the requirements of regulation 9 – Implementation of the ACP.
FSE7 and FSE8
Based on the arrangements, NuMAS records and source documentation presented to me I am satisfied that EDF Dungeness B are implementing adequate arrangements for nuclear material tracking and data processing and control, satisfying my expectations as described by FSE7 and FSE8. I judge that EDF Dungeness B is complying with regulations 9.