- Site: Sellafield
- IR number: 21-106
- Date: October 2021
- LC numbers: 6, 10, 11, 14, 20
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety, and against the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), targeted at those facilities with significant importance to nuclear safeguards. One such inspection was performed to assess the Special Nuclear Materials (SNM) Value Stream’s compliance with Sellafield Limited’s corporate arrangements for Licence Condition (LC) 6 (Documents, records, authorities and certificates) in addition to SNM’s compliance with Sellafield Limited’s arrangements made for compliance with requirements of NSR19 for nuclear material accountancy. The inspection focussed on Special Nuclear Material stored in the North part of the value stream (SNM(N)) (specifically QS04 and QS28 material balance areas).
Interventions Carried Out by ONR
All day on 13 October, and on the morning of the 14 October we carried out compliance inspections of the SNM facilities. The inspection comprised discussions with SL staff, review of plant records and other documentation, and a plant inspection.
The LC 6 part of the Inspection was led by the relevant Nuclear Safety Site Inspector with support from a Quality Assurance Specialist inspector. A member of SL’s Nuclear Intelligence and Independent Oversight (NI&IO) team also participated in the inspection.
LC 6 requires the licensee to make adequate records to demonstrate compliance with any conditions attached to the licence, and to make and implement adequate arrangements to ensure that such records made are preserved for 30 years or such other periods as ONR may approve.
The inspection against the Nuclear Safeguards (EU-Exit) Regulations 2019 (NSR19) was led by an ONR Safeguards Inspector, and targeted Regulations 9, 10, 11, 14 & 20. These regulations cover the implementation of arrangements included in Sellafield’s Accountancy and Control Plan (9), the making and retaining of adequate Operating and Accounting Records (10 and 11), and the submission of accountancy reports to ONR Safeguards (14 and 20).
As part of the preparation for the delivery of this intervention, the ONR Nuclear Safety Inspectors used the current version of ONR technical inspection guidance documentation NS-INSP-GD-06 Documents, records, authorities and certificates for guidance. The Safeguards Inspector used guidance from the current version of SG-INSP-GD-001, the “Safeguards Technical Inspection Guide”. In addition, reference was made to relevant good practice in ONMACS (ONR Guidance for Nuclear Material Accountancy, Control and Safeguards), particularly Fundamental Safeguards Expectations (FSEs) 7, and 8, and SG-TAST-GD-002, the “ONR Nuclear Material Accountancy Guide”.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Nuclear Safety
We inspected records related to the production, packaging, movement and repackaging of Special Nuclear Material (SNM). For the sample we found that SNM(N) were making adequate records to demonstrate compliance with conditions attached to the nuclear site licence. SNM(N) were able to retrieve a range of records for activities undertaken in the last two years. These included supporting historical information for the material in packages.
SNM(N) are in the process of Implementing the current corporate arrangements for making and managing records. In the meantime, SNM(N) have a policy of storing most records locally. Whilst the stored records inspected appeared to be in reasonable physical condition, we advised SNM(N) to consider if there were any reasonably practical improvements that could be made to comply with the expectations in the corporate arrangements for local storage.
In line with the corporate arrangements, SNM(N) is planning to start digitising and archiving (off-site) the majority of records. SNM(N) have arranged contractor specialist support and are looking to start the process early in the new year. SNM(N) had intended to commence the process much earlier but were delayed due to COVID 19 restrictions. Due to the nature of the records SNM(N) consider in-situ scanning is optimal. The Local Records Officer provided evidence of SNM’s preparations. These included the drafting of a revised record retention schedule, and supporting local instruction. We provided advice on aspects SNM(N) should consider when completing the revision of the retention schedule. This included considering what credit is taken for the Sellafield Limited Nuclear Material Accountancy and Safeguards Team record retention.
Safeguards
From the Safeguards perspective, no matters requiring immediate regulatory attention were identified during this inspection.
I sampled a selection of operating and accounting records for can movements and repacks reported on the QS04 and QS28 Inventory Change Reports (ICR) within the last 6 months. Sellafield was able to retrieve all records requested in a timely manner and the records were sufficiently detailed to fully substantiate accountancy reports submitted.
I sampled the record storage arrangements for the records reviewed in this inspection and confirmed that, based on this sample, corporate arrangements for record creation and storage are being followed, and the required SQEP personnel are in position. I provided Regulatory Advice to Sellafield, recommending inclusion of these arrangements in their Accountancy and Control Plan, and to ensure they have considered all relevant requirements for storage of safeguards records.
I carried out a plant walkdown of SNM North and sampled a number of items on the local database system. Barring a minor typographical error which Sellafield was able to rectify quickly, all sampled records aligned with each other and were traceable to the accountancy reports submitted under Regulations 14 and 20 of NSR19. I held discussions with the Nuclear Material Custodian for this area who provided evidence for the management and processing of operating and accounting records in alignment with Sellafield’s written arrangements for this. I considered that the record verification checks carried out aligned with section 8.1 of ONMACS. I therefore consider that Sellafield is adequately controlling and accounting for Qualifying Nuclear Material at QS04 and QS28 and implementing adequate arrangements for generating traceable operating and accounting records that substantiate the accountancy reports provided to ONR.
Conclusion of Intervention
At this stage SNM(N) have not fully implemented the Sellafield Corporate arrangements for LC 6. This is understood to be primary due to the restrictions of COVID-19. Currently, the majority of relevant records are stored locally. I have advised, SNM(N) to consider if there were any reasonably practical improvements that could be made to comply with the expectations in the corporate arrangements for such storage. However, as an interim solution, I judge that SNM(N)’s current approach adequately satisfies the requirements of LC 6. Consequently, I have assigned an inspection rating of Green (no formal action) for compliance against this LC. One level four (i.e., lowest level) regulatory issue has been raised in order to gain oversight of SNM(N) plans for fully implementing the SL Corporate requirements for LC 6.
On the basis of the evidence sampled for Safeguards at the time of the inspection and noting the guidance in Appendix 9 of ONR-INSP-GD-064, I consider that Sellafield Ltd is compliant with Regulations 9, 10, 11, 14, and 20 of NSR19 within the areas targeted at SNM(N). I therefore judge the inspection to merit a rating of GREEN with respect to compliance against The Nuclear Safeguards (EU-Exit) Regulations 2019.