- Site: Sellafield
- IR number: 21-004 (SAF)
- Date: May 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This intervention inspected the implementation of the Sellafield Ltd (SL) arrangements for a Physical Inventory Take (PIT) at the QS30 Material Balance Area (MBA) in SL’s Thermal Oxide Reprocessing Plant (THORP). The purpose of this intervention was to gain regulatory assurance that SL is adequately implementing its arrangements to deliver an appropriate PIT at QS30.
The intervention was one of a programme of planned inspections at SL during 2021/22, developed in accordance with the Safeguards Sub-Division strategy and is detailed in the SL Annual Safeguards Implementation Plan.
Interventions Carried Out by ONR
During this intervention I sampled SL’s arrangements for undertaking the QS30 PIT, obtained evidence for their implementation, and held discussions with the key SL staff involved.
The intervention was undertaken against Regulations 6, 9, 10, 11 and Schedule 2 of The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
This intervention was performed in line with ONR's guidance, as described in the relevant technical inspection guides, which can be found on ONR’s website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
SL’s QS30 PIT arrangements are captured in a single arrangements document that clearly identifies staff responsibilities for PIT and describes the methods to be used.
The operating and accounting records sampled provided evidence that the inventory is complete and correct. I followed and sampled the process through from the planning phase, to the on-plant PIT undertaking through to the generation of the LII.
I judged that the sampled arrangements and their implementation were sufficient to provide a complete and correct PIT and hence List of Inventory Items (LII). Based on this sample, I judge SL to be compliant with Regulations 6, 10, 11 and Schedule 2.
I judged that SL did not fully implement some aspects of their listed PIT arrangements, although on this occasion I judged it did not negatively impact the PIT and gave regulatory advice to this effect. I determined these were two minor shortfalls against Regulation 9(1). SL agreed to update their arrangements at the next scheduled review to accurately reflect the activities undertaken as part of the PIT and to more accurately capture the replacement of EURATOM by ONR as the Safeguards regulator. This will be tracked through ONR’s regulatory issues process.
I gave regulatory advice in areas relating to areas for improvement for SL to consider regarding the already planned updating of the ACP, learning from experience from PIT to PIT, addressing of minor shortfalls when consolidating QS30 into the other MBAs, and NMAS team support to facility staff writing PIT procedures documents.
I made four observations recognising good practice by SL regarding adequate resilience should the NMC be unavailable for the PIT, comprehensive audit and quality checks of the PIT, a comprehensive and traceable LII, and use of clearly defined roles with associated responsibilities.
Conclusion of Intervention
No matters requiring immediate regulatory attention were identified during this inspection.
In my opinion SL has adequate arrangements in place for the QS30 PIT which were implemented appropriately. In my opinion, based on the sample taken, this has resulted in a complete and correct PIT and therefore LII.
Overall, based on the sampled QS30 PIT, I judged SL to be compliant with Regulations 6, 9, 10, 11 and Schedule 2 of The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19)
Based on the evidence sampled and noting the ONR’s inspection rating guidance I judge that an inspection rating of green with no formal action is merited here.