- Site: Sellafield
- IR number: 21-007 (SAF)
- Date: June 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 Ltd., ONR Safeguards carries out a number of safeguards compliance inspections at the Sellafield site. One such intervention was performed to assess SL’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. This intervention was planned as an accountancy focused compliance inspection.
The purpose of this inspection was to confirm compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) at the Fuel Handling Plant; Decanners Facility (QS23) at Sellafield Ltd. The inspection was undertaken as part of the 2021/22 intervention plan.
The purpose of an accountancy focused inspection is to provide confidence to ONR that the operator has adequate arrangements and procedures implemented in relation to nuclear material accountancy and control systems.
Interventions Carried Out by ONR
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.
I carried out the planned Accountancy Focused Compliance Inspection at the Fuel Handling Plant; Decanners Facility (QS23) to gain regulatory confidence that the accountancy declarations were correct and complete. I used a sampling approach to assess compliance with the following regulations of NSR19:
- Regulation 6: Accountancy and Control of Qualifying Nuclear Material.
- Regulation 9: Operation of an Accountancy & Control Plan.
- Regulation 10: Operating Records.
- Regulation 11: Accounting Records.
- Regulation 12: Accounting Reports.
- Regulation 14: Inventory Change Reports.
- Regulation 20: Weight Units and Categories of Qualifying Nuclear Material.
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 held discussions with the key SL staff on plant and within the SL Nuclear Material Accountancy and Safeguards (NMAS) team involved in accounting for and controlling of nuclear material at the Material Balance Area (MBA) QS23, gathered evidence that shows adequate implementation of suitable arrangements for accountancy and control of Qualifying Nuclear Material (QNM).
My review of source documentation sampled covered all the none-waste material flows at QS23. I found the source documentation to be complete, correct, and traceable to the relevant accountancy declarations.
I identified one minor shortfall against NSR19, Regulation 14(1) in the incorrect use of the ‘Measurement Basis’ code for some of the sampled population. I will, therefore, raise this as a Regulatory Issue to investigate potential solutions for further discussion.
I noted that references to Euratom & Euratom regulations existed in the ‘Production of ICRs/MBRs/PILs using SRG’ local instruction: LI/SSD/2.12/0320. I also noted that there was an instruction to ignore a warning message in a local instruction; LI/SSD/2.12/0329. I provided regulatory advice that SL reconsider the wording when the two documents are reviewed.
I did not observe any security or safety concerns. SL Covid arrangements within QS23 and the NMAS office were clearly communicated and it was evident there was effective application on site.
I provided feedback to SL 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 evidence sampled during the inspection, I am satisfied that SL demonstrated compliance with the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 6, 9, 10, 11, 12, 14 & 20 with a minor shortfall against regulation 14(1). Noting ONR guidance on inspection ratings, I consider this inspection to merit a rating of GREEN with one Regulatory Issue raised to track completion, two pieces of regulatory advice and one observation.