- Site: URENCO UK Ltd
- IR number: 21-040 (SAF)
- Date: March 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) inspection was held at URENCO UK Limited (UUK) Residue and Source Storage Facility to provide regulatory confidence on the adequacy of the PIT carried out for the Qualifying Nuclear Material 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), 11 (1 and 3) 15 and Schedule 2.
The purpose of a PITe inspection is to provide regulatory confidence to ONR of the adequacy and implementation of the arrangements made by the operator for conducting a PIT. This in turn, provides confidence in the accuracy of the operator’s physical inventory.
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 the UUK Residues and Source Storage Facility (Material Balance Area QCA9) including that they allow the plant to be in an appropriate state to ensure the best possible results are obtained;
- The staff key to maintaining NMACS and undertaking a PIT are suitably qualified and experienced;
- The implementation of appropriate data processing methods;
- Evidence that the List of Inventory Items (LII) generated during the PIT is correct and complete, consistent and fully traceable to source records.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I reviewed the arrangements for undertaking a PIT at the UUK Residue and Source Storage Facility and discussed them with personnel responsible for the PIT. I carried out a plant walkdown 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, 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 PIT arrangement which I have captured in a Level 4 Regulatory Issue to track completion of the corrective actions.
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). I am satisfied these personnel are competent to discharge their responsibilities during a PIT at QCA9 and have undertaken suitable training and assessment.
I sampled the source documentation underpinning the items listed on the LII produced for the PIT and am satisfied that there is evidence of traceability and alignment from the facility records through to the LII in line with ONR’s regulatory expectations.
Conclusion of Intervention
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 UUK QCA9 in line with Regulations 6(3), 10(1), 11 (1 and 3) 15 and Schedule 2 of NSR19. I have raised one Level 4 Regulatory Issues to track URENCOs corrective actions for the minor shortfalls found in the NMACS arrangements. This regulatory issue will be managed as part of my routine regulatory activities.
I therefore consider, noting ONR guidance on inspection ratings, an inspection rating of GREEN (no formal action) is merited here.