- Site: Sellafield
- IR number: 21-001 (SAF)
- Date: May 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards’ inspection and assessment plan 2021/22 for Sellafield, ONR Safeguards carries out a number of safeguards compliance inspections at the Sellafield site. One such intervention was performed to assess SL’s compliance within the Special Nuclear Material (SNM) Value Stream with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. For this intervention the Magnox Plutonium Nitrate Conversion Plant (MPNCP) was selected and the inspection planned as an accountancy focused compliance inspection.
Interventions Carried Out by ONR
I carried out an accountancy focused compliance inspection within the MPNCP. The inspection comprised of discussions with SL staff, reviews of operating and accounting records and other documentation, and a plant inspection.
The inspection targeted the completeness and correctness of the operating and accounting records (source documentation) which underpinned a sample of batches of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility. The inspection also targeted whether these source documents were traceable to the accountancy reports and whether arrangements for generation of source documentation and accountancy reports at MPNCP were adequately implemented.
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 (onr.org.uk).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
On the basis of the evidence sampled I am satisfied that SL has 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. I have undertaken discussions with the key SL staff on plant and within the SL Nuclear Material Accountancy and Safeguards team involved in accounting for and controlling nuclear material at the MPCNP, and have also gathered evidence that shows adequate implementation of suitable on-plant arrangements for accountancy and control of QNM.
My review of source documentation sampled the breadth of material flows at the MPNCP. I found the source documentation to be generally complete, correct, and traceable to the relevant accountancy declarations. However, I found four examples of transcription anomalies which had not been picked up by the quality assurance (QA) checks in SL’s arrangements. I do not consider the anomalies themselves as shortfalls as they will be easily corrected by SL, but consider it appropriate for SL to review the effectiveness of their QA arrangements for source documentation and accounting records and demonstrate to ONR that they are as effective as is reasonably practicable. I have raised a Regulatory Issue in relation to this.
I identified an area where SL were unfamiliar with the behaviour of the accounting system for generation of accountancy reports. The system had generated an incorrect field entry in a way that SL were not able to readily explain during the inspection. I therefore judged it appropriate for SL to investigate the glitch and demonstrate to ONR that they have an appropriate understanding of why the system operated in the way it did. I raised a second Regulatory Issue to track this.
I judged a shortfall against the implementation of SL’s own arrangements regarding the timeliness of recording internal accountancy transactions on the accountancy system. SL acknowledged this issue and were proactive in proposing suitable corrective actions at the closing meeting. On this basis I was content to track it as a Regulatory Issue.
Based on the inspection sample, I am satisfied that SL has demonstrated adequate accountancy and control for its QNM within the MPNCP. I am satisfied that SL is generating accounting and operating records that are generally complete and correct with only minor errors found during the inspection. I am satisfied that, with the exception of some internal transactions that did not impact on accountancy reports on this occasion, SL is implementing their arrangements for accountancy and control of QNM at the MPNCP.
I provided feedback to the site on the inspection findings at a close-out meeting with management representatives.
Conclusion of Intervention
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the inspection sample I judge SL is compliant with the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 9, 10, 11, 14, 20, and the reporting schemes set out in Parts 2-4 and noting ONR guidance on inspection ratings, I consider this inspection to merit a rating of green with two Level 4 Regulatory Issues raised and one area of good practise observed.