Executive summary
Date(s) of inspection: September 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 the EDF corporate centre. 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. To form effective regulatory judgements on EDF’s compliance with NSR19, ONR also considered the following expectations as outlined in the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS):
- FSE1 - Leadership and Management for NMACS
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Controlli>
- FSE10 - Quality Assurance and Control for NMACS
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: Green
- FSE 10 Quality Assurance and Control for NMACS - Rating: Green
- FSE 7 Nuclear Material Tracking - Rating: Not rated
- FSE 8 Data Processing and Control - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
No significant shortfalls in compliance against NSR19 were identified during this intervention.
I inspected arrangements for Governance and Leadership, Assurance Processes and Quality Assurance and Control for NMACS. I am satisfied based on the sample which I selected in these areas that the arrangements and procedures for described by the EDF corporate ACP are appropriately implemented. I also inspected activities linked to Nuclear Material Tracking and Data Processing and Control, however, the corporate support function for Safeguards does not directly maintain nuclear material tracking or conduct data processing and control activities for the stations in the areas which I inspected against. Instead, they provide a support and advice role with regular checking of reports following submission to ONR; No written arrangements were available for this role and I gave EDF regulatory advice that they should consider capturing those arrangements formally. Overall, based on the sample that I inspected I was unable to make a judgement regarding the implementation of arrangements against FSE7 or FSE8 as there were no written arrangements in the areas that I inspected. Arrangements for nuclear material tracking and data processing and control are managed and implemented at each site, however the role which the corporate function provides gives me assurance that reports submitted by EDF will continue to meet the requirements of NSR19 under regulations 11, 12, 14, 15 18 and 19.
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
FSE1 and FSE10
Overall, based on the sample that I inspected, I am satisfied that the operator is appropriately implementing arrangements for Governance and Leadership (MACE 1.1) Assurance Processes (MACE 1.5) and Quality Assurance and Control for NMACS (FSE10) as described by the EDF corporate ACP. They are therefore meeting the requirements of NSR19 Regulation 9.
FSE 7 and FSE 8
The corporate support function for Safeguards activities does not directly maintain nuclear material tracking or conduct data processing and control activities for the stations in the areas which I inspected against. Instead, they provide a support and advice role with regular checking of reports following submission to ONR. Overall, based on the sample that I inspected I was unable to make a judgement regarding the implementation of arrangements against FSE7 or FSE8 as there were no written arrangements in the areas that I inspected. Arrangements for nuclear material tracking and data processing and control are managed and implemented at each site, however the role which the corporate function provides gives me assurance that reports submitted by EDF will continue to meet the requirements of NSR19 under regulations 11, 12, 14, 15 18 and 19. This could be further strengthened by capturing those checks done at the corporate function into formal arrangements and this is reflected in the regulatory advice which I gave as detailed below.