Date(s) of inspection:
Aim of inspection
This inspection was part of a programme of planned ONR safeguards inspections at Springfields Fuels Ltd during 2022/23, developed in accordance with the Safeguards Sub-Division strategy.
This inspection was a Safeguards Systems-Based Inspection (SSBI) judging the adequacy of Systems, Structures and Components (SSCs) integral to Nuclear Material Accountancy Control and Safeguards (NMACS).
The purpose of this inspection was to gain regulatory assurance (on a sample basis) that relevant SSCs of the Springfields Fuels Ltd Oxide Fuel Complex (OFC) and finished fuel store Material Balance Area (MBA QBSP) NMACS system are fit for purpose and implemented in a proportionate and appropriate manner as required by the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), particularly regulations 6, 9, 10, 11 (2), 12 and 20.
Subject(s) of inspection
- FSE 3 Competence Management – Rating: GREEN
- FSE 5 Reliability, Resilience and Sustainability – Rating: GREEN
- FSE 6 Measurement Programme and Control – Rating: GREEN
- FSE 7 Nuclear Material Tracking – Rating: GREEN
- FSE 8 Data Processing and Control – Rating: GREEN
- 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 Reg20 – Weight units and categories of qualifying nuclear materials – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
This inspection comprised of discussions with Springfields Fuels Ltd personnel, sampling of documentation, implementation of arrangements and a plant walkdown.
I identified one minor shortfall in the information described in the Basic Technical Characteristics (BTC issue 11) for the Oxide Fuel Complex (OFC) and finished fuel store (MBA QBSP). This minor shortfall is associated with the description of the LWR pellet sampling weigh scale as the “method for measurement, sampling and analysis” even though this system is no longer used for that purpose. I have captured this minor shortfall within a regulatory issue to track completion of the corrective action.
I gave five pieces of regulatory advice related to the accuracy and completeness of the BTC for QBSP, implementation of routine checks and tests of backup files, IT systems recovery procedure and auditing contractors performing backups. Regulatory advice also included longer term succession planning and review of safeguards systems and components in the BTC to ensure Safeguards personnel are aware of engineering changes.
I made two observations during the inspection noting areas of good practice.
Based on the evidence sampled, I judge that Springfields Fuels Ltd is implementing adequate arrangements to manage the competence of staff using the SSCs inspected in line with FSE 3 – competence management, FSE 5 – reliability, resilience and sustainability, FSE 6 – measurement programme and control, FSE 7 – nuclear material tracking FSE 8 – data processing and control..
Overall, based on the evidence sampled at the time of the inspection, I am satisfied that Springfields Fuels Ltd has demonstrated that the SSCs sampled are fit for purpose and being implemented in a proportionate and appropriate manner as required by the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), particularly regulations 6, 9, 10, 11 (2), 12 and 20. The arrangements for the SSCs are being implemented as claimed within the Springfields Fuels Ltd’s Accountancy and Control Plan (ACP). I identified one minor shortfall that I will raise as a level 4 regulatory issue as I consider it to be a non-compliance with NSR19 regulation 3 and ONR’s regulatory expectations. The regulatory issue will be managed as part of routine activities to track Springfields Fuels Ltd’s return to compliance.
I therefore consider, noting ONR guidance on inspection ratings, an inspection rating of GREEN (no formal enforcement) is appropriate.