- Site: Harwell
- IR number: 21-024 (SAF)
- Date: September 2021
- LC numbers: N/A
Executive summary
This inspection was one of programme of planned inspections at Magnox Ltd during 2021/22, developed in accordance with the Safeguards Sub-Division strategy. This inspection was a Physical Inventory Take Evaluation (PITe) inspection of Magnox’s arrangements against the Nuclear Safeguards Regulations 2019 (NSR19).
Purpose of Intervention
The purpose of this Physical Inventory Taking (PIT) Evaluation was to provide ONR with regulatory assurance that Magnox’s Nuclear Materials & Accountancy Control, Safeguards (NMACS) system at Harwell (QHR1), required under Regulation 6(1) of NSR19, is maintained such that the operator can demonstrate the system and its implementation meets relevant good practice and the requirements specified in the following;
- Regulation 6(1) - Accountancy and control of qualifying nuclear material,
- Regulation 9 - Operation of an accountancy and control plan,
- Regulation 10(1)(e) - Operating records,
- Regulation 11 - Accounting records and where relevant,
- Schedule 2 of NSR19 in relation to a PIT.
The inspection was carried out as part of ONR’s Safeguards’ inspection and assessment plan 2021/22 for Sellafield.
Interventions Carried Out by ONR
As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
- ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS),
- SG-INSP-GD-001 Rev 3 - Safeguards Technical Inspection Guide (TIG).
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
The inspection targeted:
- The adequacy and implementation of Magnox’s arrangements for a PIT at QHR1
- The adequacy of the implementation of data processing arrangements associated with the PIT at QHR1
- The competence of key Magnox personnel involved in the PIT at QHR1
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I sampled the QHR1 PIT arrangements and their implementation at the waste complex and the drum store. Based on my review of these documents and sampling on site, I consider that the arrangements are available but noted that one of the sampled arrangements was not being appropriately maintained as expected in ONR-SG-INSP-001. I also judged a minor shortfall against Regulation 6(3) and Component 14 of Schedule 2 of NSR19 with regards to the arrangements not defining the plant status to be achieved prior to a PIT. I have raised a Level 4 Regulatory Issue for Magnox to address these shortfalls by updating their written arrangements.
I conducted a walkdown of three facilities at QHR1 and sampled the implementation of an interim PIT within these areas as per the written arrangements. Based on evidence sampled during the walkdown, I consider that the PIT was adequately implemented in line with their arrangements. I also sampled the data processing arrangements for a PIT at QHR1, and how they are implemented on plant and within the central Safeguards Team. I considered that they are adequately implemented and generate appropriately validated outcomes. I therefore judged that the data processing arrangements for a PIT were adequate. I held discussions with key personnel involved in the PIT and sampled their training records. During these discussions the personnel appeared knowledgeable for their roles in the PIT and were fully up to date with the relevant PIT competencies on the training management system. I therefore judged that the personnel key to carrying out a PIT at QHR1 are suitably qualified and experienced for this role.
During the inspection I made four Observations where I considered that Magnox was demonstrating relevant good practice for a PIT and a fifth that I considered represented an improvement opportunity to Magnox. I also provided Magnox with two pieces of Regulatory Advice which I recommended Magnox action prior to the next PIT in 2022.
I provided feedback to Magnox on the Regulatory Issues, Regulatory Advice and Observations, at a close-out meeting at the end of the inspection which they accepted.
Conclusion of Intervention
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the evidence sampled, in my opinion Magnox is complying with the requirements of Regulations 6(1), 9, 10(1)(e), 11, and relevant paragraphs of Schedule 2 in NSR19 with regards to a PIT. Noting ONR guidance on inspection ratings, I consider this inspection to merit a rating of GREEN with a Level 4 Regulatory Issue.