Date(s) of inspection:
- June 2023
Aim of inspection
ONR nuclear safeguards inspectors visited the Hunterston B site on 22 June 2023 for the purpose of conducting an inspection across the Nuclear Safety and Nuclear Safeguards Purposes.
The focus for of this inspection was nuclear material accountancy and control through end of generation defuelling and the fuel free verification arrangements for non-reactor areas of the facility.
ONR inspectors conducted two interventions for the material balance area QHNB (Hunterston B Power Station):
- An accountancy-focussed compliance inspection
- An inspection of arrangements for fuel free verification of non-reactor areas and other associated arrangements described by the site Accountancy and Control Plan (ACP)
These interventions adopted a sampling approach to seek evidence in support of 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.
To form effective regulatory judgements on EDF’s compliance with NSR19, ONR considered expectations as outlined in the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
The second part of the intervention was conducted by ONR inspectors from the Safeguards and Nuclear Safety purposes and focused on arrangements for fuel free verification in areas of the facility outside the reactors. This intervention adopted a sampling approach to seek evidence in support of compliance with Regulation 9 of NSR19 (Operation of an accountancy and control plan) and Nuclear Site License Condition 25 (Operational Records).
Subject(s) of inspection
- NSR19 Reg06 – Accountancy and control of qualifying nuclear material – 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 Reg14 – Inventory change report – 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 2023/24 for EDF, ONR Safeguards conducted a Safeguards compliance inspection at the EDF Hunterston B site. This intervention was performed to inspect against compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. For this intervention the Material Balance Area (MBA) known as QHNB was targeted.
This inspection included a safeguards accountancy focussed compliance inspection and an inspection of the arrangements for fuel free verification (FFV) of several new fuel areas at Hunterston B which was conducted in partnership with ONR’s Nuclear Safety purpose. The intervention comprised of discussions with personnel, viewing source data and other documents, and a plant walk down, in order to gather evidence that arrangements are appropriately implemented and to make judgements of compliance against NSR19.
No significant shortfalls in compliance against NSR19 were identified during this intervention.
Accountancy focused compliance inspection
I am satisfied that EDF presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted to ONR under Regulation 14 of NSR19. Based on the inspection sample, I am satisfied that EDF has demonstrated adequate accountancy and control and is generating accounting and operating records that are complete and correct in line with NSR19 regulations 6 10, 11, 12, 14, 15, 18 and 19.
Joint Safeguards and Nuclear Safety inspection of FFV arrangements
I inspected arrangements put in place to demonstrate that several new fuel areas are free of fuel items and was satisfied they were adequate. I am satisfied based on my sample that the arrangements are being appropriately implemented at the site. Overall, I judge that EDF is meeting the requirements of NSR19 regulation 9, and my expectations as described by the ONMACS and I rated this inspection Green.
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the sample inspected during the intervention I judge that EDF is compliant with the requirements of NSR19 regulations 6, 9, 10, 11, 12, 14, 15, 18, and 19.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
Accountancy focused compliance inspection
Based on the arrangements, NuMAS records and source documentation presented to me for the batches sampled, I am satisfied that EDF Hunterston B are implementing adequate arrangements for the tracking and accounting of nuclear material at the Hunterston B power station, satisfying the requirements of FSE 7 and 8. I judge that EDF Hunterston B are compliant with regulations 6, 10, 11, 12, 14, 15, 18 and 19.
Joint Safeguards and Nuclear Safety Inspection of FFV arrangements
I am satisfied the arrangements put in place to demonstrate the FFV of those new fuel areas which were inspected are appropriate, proportionate and were adequately implemented and I judge that EDF Hunterston B are compliant with NSR19 regulation 9.