- Site: Springfields
- IR number: 20-130
- Date: March 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This Intervention Record (IR) details the planned nuclear safeguards accountancy focussed compliance inspection at Springfields Fuels Limited (SFL). This inspection focussed on the Material Balance Area (MBA) QBSP, as defined in the Basic Technical Characteristics (BTC) for the Qualifying Nuclear Facility (QNF), which primarily consists of the Oxide Fuel Complex.
The purpose of this inspection was to seek evidence in support of ONR forming regulatory judgements of SFL’s compliance against the following Regulations in NSR19:
- Regulation 6 – Accountancy and control of qualifying nuclear material.
- Regulation 10 – Operating records
- Regulation 11 – Accounting records
- Regulation 12 – Accounting reports
This intervention was undertaken remotely due to the ongoing COVID-19 pandemic.
Interventions Carried Out by ONR
I conducted a remote nuclear safeguards accountancy focussed compliance inspection at SFL from 29 March to 31 March inclusive. This inspection focussed on SFL’s accountancy arrangements and their implementation for the MBA QBSP. There was no on-site attendance by ONR inspectors.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No significant or minor shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected during this intervention I judge SFL demonstrated their implementation of their arrangements to be in-line with my regulatory expectations, compliant with NSR19 and also demonstrated numerous good practices. I am satisfied that SFL are compliant with NSR19 Regulations 6, 10, 11 and 12.
I made a number of observations relating to good practice as well as identifying several areas for improvement. These were fed back to the operator at the conclusion of the inspection:
- OBSERVATION 1 – GOOD PRACTICE. The SFL implemented physical facility checks and assessments provide SFL with additional assurance regarding the facility implementation of accountancy arrangements, and thus the accuracy of the SFL nuclear material accounts.
- OBSERVATION 2 – GOOD PRACTICE. SFL undertake numerous quality assurance and audit checks of nuclear material accounting data and records, including thorough review of the ICR lines generated in NUMIS as part of the regulatory report submitted to ONR on a monthly basis.
- OBSERVATION 3 – GOOD PRACTICE. SFL utilise their existing Corrective Action Process (CAP) used for safety/security to identify areas for improvement, track these to completion and to capture Learning From Experience (LFE) for nuclear material accounting.
- OBSERVATION 4 – AREA FOR IMPROVEMENT. Some arrangements documents sampled require updating (such as SSI609 and LI108 relating to Uranium accountancy guidelines and operation of a pool account), however I judged the updates to be minor as they were administrative only and did not impact the compliance with NSR19 or the accountancy of qualifying nuclear material at SFL.
- OBSERVATION 5 – AREA FOR IMPROVEMENT. Some of the supporting documents sampled would benefit from being formalised and having appropriate document management implemented (such as the in-development job guides and accountancy guides). I judge that this is not a minor shortfall since these informal documents support the formal arrangements documents that enable compliance, however I judge that having formally owned, tracked and maintained documents is recognised as good practice.
- OBSERVATION 6 – AREA FOR IMPROVEMENT. While SFL were able to demonstrate appropriate competence management, I noted that in one instance an informal refresher training course was provided to a SQEP member of staff. While SFL felt this did not merit being captured formally, as it was above and beyond their competence management arrangements, I judge that formal capture of attendance of refresher training above and beyond the competence management arrangements should be captured and claimed as good practice.
Conclusion of Intervention
Based on the sample I inspected during the intervention, I am satisfied that SFL are implementing their arrangements for accountancy and control of QNM in-line with my regulatory expectations and are compliant with NSR19 Regulations 6, 10, 11 and 12. I judge that the sampled accountancy reports previously submitted to ONR, the sampled accounting records, and associated operating records for both, were correct and complete. I did not identify any significant or minor shortfalls, but did make some observations of good practice and areas for improvement relating to good practice.
Upon consideration of the ONR guidance on inspection ratings I judge that a rating of GREEN (no formal action) is appropriate.