Date(s) of inspection:
- March 2023
Aim of inspection
The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) require in Regulation 6 that operators “maintain a system of accountancy and control” and that the components of this system must be implemented “in a manner which is proportionate to and appropriate for the basic technical characteristics of the qualifying nuclear facility”. Regulations 7, 8 and 9 require that this system be described in an Accountancy and Control Plan (ACP) and that this is implemented as described.
ONR nuclear safeguards inspectors will conduct an ACP/accountancy focussed compliance inspection of the Sellafield Ltd Material Balance Area (MBA) QS26 – Central Laboratory on Wednesday 1st March 2023. The purpose of this inspection is to seek evidence in support of Sellafield Ltd’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR will form regulatory judgements and provide a single rating in line with ONR’s inspection rating guidance of Sellafield Ltd’s compliance against the following Regulations in NSR19:
- Regulation 6 (1-4): Accountancy and Control of Qualifying Nuclear Material. Including Schedule 2, in particular parts: 2, 4, 5, 6, 7, 8, 10.
- Regulation 7(1) and 7(4): Accountancy and Control Plan.
- Regulation 9: Operation of an Accountancy and Control Plan.
- Regulation 10: Operating Records.
- Regulation 11: Accounting Records.
- Regulation 12 (1-2): Accounting Reports.
- Regulation 14: Inventory Change Reports
- Regulation 15: Material balance report and physical inventory listing
- Regulation 20: Weight units and categories of qualifying nuclear materials
To form effective regulatory judgements on Sellafield Ltd’s compliance with the NSR19 regulations listed above, inspectors will consider the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within. There will be a particular focus on:
- FSE 7 – Nuclear Material Tracking
Subject(s) of inspection
- FSE 4 Reporting, Anomalies, and Investigations – rating: Green
- FSE 7 Nuclear Material Tracking – 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 Reg12 – Accounting reports – rating: Green
- NSR19 Reg14 – Inventory change report – rating: Green
- NSR19 Reg15 – Material balance report and physical inventory listing – rating: Green
- NSR19 Reg20 – Weight units and categories of qualifying nuclear materials – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
No significant shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected, I judge Sellafield Ltd has adequately implemented their arrangements for nuclear material accountancy and control of QNM in QS26. I judge the sampled operating and accounting records to be compliant with NSR19 Regulations 10 and 11 respectively. I also judge that these records were traceable to and underpin the sampled declarations within the accountancy reports submitted to ONR in line with NSR19 Regulations 12, 14, 15 and 20.
Based on the plant walkdown and discussions I held with the key staff on plant and within the safeguards team I judge that Sellafield Limited are implementing the arrangements described in their Accountancy and Control Plan (ACP) as required by NSR19 Regulation 9 and that implementation of these arrangements is supporting the accountancy and control of QNM within these MBAs as required in NSR19 Regulation 6.
During the inspection I gained assurance that the sampled portion of the ACP (FSE7 and FSE4) captures the nuclear material accountancy and control arrangements, as well as the arrangements for reporting, anomalies and investigations within the MBA as per NSR19 Regulation 7. Further I judge that Sellafield Ltd. broadly met ONR’s regulatory expectations for nuclear material tracking as per FSE7 and for reporting/incidents/investigations as per FSE4 in ONMACS.
During the inspection I sampled the accountancy line for a batch of QNM that was taken out of safeguards. Prior to the inspection I sampled the advanced notification for the batch and during the inspection collected adequate evidence that the transfer had been completed and documented appropriately. I judge this accountancy to be compliant and met my regulatory expectations.
I provided five pieces of regulatory advice relating to: Sellafield Ltd updating an operating instruction to include non-physical moves, the inclusion of planned quarterly inventory checks, updating the ACP to capture minor inaccuracies such as not all moves using an ITN, having all sample ID’s created by the nuclear material custodian, naming/labelling of the fume cupboards in the laboratories. I raised one regulatory issue to track several of these changes to completion. I also made four observations.
I was satisfied that the documentation reviewed, records sampled and evidence collected was adequate and I therefore judged Sellafield Ltd to be compliant against NSR19 Regulations 6, 7, 9, 10, 11, 12, 14, 15 and 20. Further, I judge Sellafield Ltd’s arrangements and their implementation to meet ONR’s regulatory expectations under FSE7 and FSE4. Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
Based on the sample inspected, I judge that Sellafield Ltd and NNL are adequately implementing their arrangements for accountancy and control of QNM in-line with regulatory expectations and are compliant with the following NSR19 requirements:
- Regulation 6 – Accountancy and control of qualifying nuclear material
- Regulation 7 – Accountancy and Control Plan
- Regulation 9 – Operation of Accountancy and Control Plan
- Regulation 10 – Operating Records
- Regulation 11 – Accounting Records
- Regulation 12 – Accounting Reports
- Regulation 14 – Intervention Change Reports
- Regulation 15 – Material balance report and physical inventory listing
- Regulation 20 – Weight units and categories of qualifying nuclear materials
Based on the sample inspected I also judge that Sellafield Ltd and NNL are adequately implementing their arrangements detailed in the ACP in-line with regulatory expectations for FSE 7 – Nuclear Material Tracking and FSE 4 – Reporting, Anomalies, and Investigations.
I did not identify any significant or minor shortfalls in compliance against NSR19 during this intervention.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
I raised one regulatory issue Regulatory Issue 1 (RI-11308) – Implementation of regulatory advice provided during QS26 ACP/accountancy inspection for NNL Central Labs to track the operator implementing the regulatory advice provided.