Executive summary
Date(s) of inspection:
February 2026
Aim of inspection
ONR nuclear safeguards inspectors conducted a physical inventory take (PIT) evaluation inspection of the QTSA material balance area (MBA). As an action against RI-12397, QTSA have recently revised the PIT arrangements. The purpose of this inspection was to seek evidence that the PIT arrangements are appropriate for the qualifying nuclear facility and are adequately implemented in support of EDF Torness's compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
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
- FSE 9 Material Balance - 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 Reg14 - Inventory change report - Rating: GREEN
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
In accordance with the ONR Safeguards inspection and assessment plan 2025/26 for EDF, this inspection was performed to inspect EDF’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
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, 14 and 15, and the ONR Nuclear Material Accountancy, Control, and Safeguards Assessment Principles (ONMACS) Fundamental Safeguards Expectations (FSEs) 3, 7, 8 and 9.
The inspection targeted the operator’s arrangements and their implementation for the annual physical inventory taking (PIT) of qualifying nuclear material (QNM), production and traceability of the associated nuclear material accountancy (NMA) reports, and competence management. Evidence was also sought that the Accountancy and Control Plan (ACP) contains adequate descriptions of the PIT arrangements and associated procedures.
Based on the evidence sampled, observation of PIT activities conducted and discussions I held with key staff, I judge that EDF Torness are implementing the PIT and associated nuclear material accountancy and competence management arrangements described in their ACP as required by NSR19 Regulations 7 and 9, and that these arrangements adequately meet the requirements of NSR19 Regulations 6, 10, 11, 14 and 15, and FSEs 3, 7, 8 and 9.
Multiple minor shortfalls against NSR19 Regulations 6 and 9 and FSE 9 were identified due to inadequacies in the methodology used to determine the sample size for the PIT of the spent fuel pond and diverging implementation of the defined arrangements:
- An inappropriate population was used to calculate the sample size for the PIT of the spent fuel pond.
- A random sample was not implemented as stated in the arrangements.
- No justification was provided that the spent fuel pond sampling as defined in the arrangements and implemented during the PIT represents a statistically-meaningful sampling plan.
- The sample size determined for the spent fuel pond was not implemented as defined in the arrangements.
As a result, I have raised a Level 4 Regulatory Issue (RI-12956) for EDF to revise the PIT arrangements to address these shortfalls.
I provided six pieces of regulatory advice regarding minor procedural and record amendments, use of seals and incident reporting requirements. I raised five observations regarding procedures lacking detail and clarity, the recording of QNM unique IDs on radioactive source inventory records, out of date references to EURATOM and minor inconsistencies between NMA reporting procedures. I identified five positive observations related to good practice observed during the PIT of the spent fuel pond and reconciliation of the PIT results.
A significant shortfall against NSR19 Regulation 8 was identified. Multiple similar shortfalls against NSR19 Regulation 8 and associated Regulation 3 have been identified across the EDF Fleet. As a result, I have raised a Level 3 Regulatory Issue (RI-12945) which seeks to achieve sustained compliance with NSR19 Regulations 3 and 8 across the EDF Fleet arrangements for the management of station Basic Technical Characteristics (BTC) and ACP documentation. This finding was extraneous to the objectives of this inspection and therefore is being addressed separately via these enforcement activities applicable to the wider EDF Fleet. Consequently, this finding has not influenced the rating of this inspection.
Conclusion
Based on the sample inspected, I judge that the EDF Torness PIT and associated nuclear material accountancy and competence management arrangements are appropriate for the qualifying nuclear facility, and that these arrangements are being adequately implemented to meet the requirements of NSR19 Regulations 6, 7, 9, 10, 11, 14 and 15, and the expectations of FSEs 3, 7, 8 and 9.
A significant shortfall against NSR19 Regulation 8 was identified. Multiple similar shortfalls against NSR19 Regulation 8 and associated Regulation 3 have been identified across the EDF Fleet. As a result, I have raised a Level 3 Regulatory Issue (RI-12945) which seeks to achieve sustained compliance with NSR19 Regulations 3 and 8 across the EDF Fleet arrangements for the management of station BTCs and ACPs.
My findings against the sample inspected have identified multiple minor shortfalls against NSR19 Regulations 6 and 9 and associated regulatory expectation FSE 9 due to inadequacies in the methodology used to determine the sample size for the PIT of the spent fuel pond and the implementation of the defined arrangements. As a result, I have raised a Level 4 Regulatory Issue (RI-12956) for EDF to revise the PIT arrangements to address these shortfalls.
Regulatory advice provided during this inspection will be followed up as part of routine regulation.
Upon consideration of the ONR guidance on inspection ratings and application of the EMM, I judge that a rating of GREEN (no formal action) is appropriate.