- Site: URENCO UK Ltd
- IR number: 21-003 (SAF)
- Date: February 2022
- LC numbers: N/A
Executive summary
This inspection was one of the programme of planned inspections at URENCO Capenhurst during 2021/22, developed in accordance with the Safeguards Sub-Division strategy. The inspection was a compliance inspection of operator arrangements against Nuclear Safeguards Regulations (EU Exit) 2019 (NSR19).
Purpose of Intervention
This physical inventory take (PIT) evaluation (PITe) and Accountancy and Control Plan (ACP) inspection was held at URENCO Chem Plants (UCP) Tails Management Facility (TMF) to provide assurance on the adequacy of the implementation of the nuclear material accountancy and safeguards (NMACS) arrangement as detailed in the UCP ACP in particular for the PIT carried out for the qualifying nuclear material (QNM) within the facility. The objective of the inspection was to inform ONR’s judgement on URENCO’s compliance with NSR19 in particular Regulations 6(3), 9, 10(1), 15 and Schedule 2.
The purpose of a PITe inspection is to provide assurance to ONR of the adequacy and implementation of the arrangements made by the operator for conducting a PIT in order to gain assurance of the accuracy of the operator’s physical inventory.
The purposed of an ACP inspection is to assure ONR that the arrangements and procedures described in the ACP that form the system of NMACS are being implemented effectively at the facility.
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 (onr.org.uk).
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 inspection targeted:
- The suitability of the arrangements and procedures for undertaking a PIT in TMF including that they allow the plant to be in an appropriate state to ensure the best possible results are obtained.
- The adequate implementation of arrangements and procedures for NMACS in particular for the performance of a PIT and consideration that arrangements are being implemented as claimed in the ACP
- The staff key to maintaining NMACS and undertaking a PIT are suitably qualified and experienced
- The implementation of appropriate data processing methods
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I reviewed the arrangements for undertaking a PIT at TMF and discussed them with personnel responsible for the PIT. I carried out a plant walkdown at TMF to observe the PIT as it was being undertaken and the implementation of the arrangements. I consider that the arrangements broadly define the steps to carry out a PIT and that the plant was in an appropriate state to carry out the PIT and adequate inventory checks were being performed. I identified minor shortfalls against NSR19 in the arrangements and their implementation which I have captured in a Level 4 Regulatory Issue to track completion of the corrective action.
I sampled competence management records and the assessment process for the persons carrying out the PIT to gain regulatory confidence that they are suitably qualified and experienced personnel (SQEP) for nuclear material accountancy control and safeguards (NMACS) responsibilities. I identified significant shortfalls in the formal records against relevant good practice as detailed in Fundamental Safeguards Expectation (FSE3) in the ONMACS. FSE 3 states that the operator should implement and maintain a process of assessment that all personnel whose actions have the potential to impact upon nuclear material accountancy control and safeguards meet defined competency expectations. Through discussions with the personnel I was able to determine that they had an appropriate level of NMACS awareness and were competent to undertake a PIT however this was not reinforced by claimed documentary evidence. I have raised a Level 3 Regulatory Issue to seek the necessary improvements of the corrective actions.
I reviewed the UCP ACP sections describing the inventory tracking and the physical inventory take and, during the inspection, I identified that the ACP did not identify nor describe the NMACS arrangements that are implemented at the facility which I consider to be a minor shortfall with ONRs regulatory expectations on the scope and function of the ACP. I have raised a Level 4 Regulatory Issue to track the corrective action.
Conclusion of Intervention
Overall, on the basis of the evidence sampled at the time of the inspection, I am satisfied that URENCO has demonstrated that it is appropriately implementing arrangements for undertaking a PIT at UNS QBCX in line with Regulations 6(3), 9(1), 10(1), 15 and Schedule 2 of NSR19, however I judge that there is a significant shortfall in the process for assessment for the personnel whose actions have the potential to impact upon nuclear material accountancy control and safeguards. I have raised one Level 3 and two Level 4 Regulatory Issues to track URENCOs corrective actions for the shortfalls found. These regulatory issues will be managed as part of routine regulatory activities to track URENCOs return to compliance.
I therefore consider, noting ONR guidance on inspection ratings, an inspection rating of AMBER – seek improvement is merited here.