Executive summary
Date(s) of inspection: February 2024
Aim of inspection
ONR nuclear safeguards inspectors conducted an Accountancy and Control Plan (ACP) compliance inspection of Sellafield Ltd. Magnox Reprocessing (QS03) and Magnox Decanners (QS23) on the 27 February 2024.The purpose of this inspection was to seek evidence in support of Sellafield Ltd.’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR formed regulatory judgements and provides a rating in line with ONR’s inspection rating guidance of Sellafield Ltd.’s compliance against Regulations 3, 6, 9, 10, 11, 12, 14 and 20 in NSR19. To form effective regulatory judgements on Sellafield Ltd.’s compliance with the NSR19 regulations listed above, ONR considered the Fundamental Safeguards Expectations (FSEs) as detailed in the ONR Nuclear Material Accountancy, Control, and Safeguards Assessment Principles (ONMACS) guidance. There was particular focus on FSEs 7 and 8.
Subject(s) of inspection
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 8 Data Processing and Control - Rating: Green
- NSR19 Reg03 - Declaration of basic technical characteristics - Rating: Green
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: Green
- NSR19 Reg09 - Operation of an accountancy and control plan - Rating: Green
- NSR19 Reg10 - Operating records - Rating: Green
- NSR19 Reg11 - Accounting records - Rating: Green
- NSR19 Reg12 - Accounting reports - Rating: Green
- NSR19 Reg14 - Inventory change report - Rating: Green
- NSR19 Reg20 - Weight units and categories of qualifying nuclear materials - Rating: Green
- Overall Inspection Rating - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This Accountancy and Control Plan (ACP) and accountancy compliance intervention at Sellafield Ltd. – Material Balance Areas (MBAs) QS03 (Magnox reprocessing) and QS23 (Magnox decanners) – was undertaken to assess Sellafield Ltd.’s compliance with the requirements of The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19). The intervention focused on reviewing the ACP arrangements for each MBA, ensuring the ACPs are being implemented in a manner which is proportionate to and appropriate for each MBA as the plants change operational phase and move into Post Operational Clean Out (POCO). This intervention also reviewed the source documentation used to substantiate the accounting reports that Sellafield Ltd. have provided to ONR as the plants have changed function over the course of 2022-23.
During this intervention, I spoke to Sellafield Ltd. personnel fulfilling a variety of different roles, I sampled a number of documents including accounting and operating records and other source documentation. I was given presentations outlining the MBA’s current and planned activities and I undertook a plant walkdown to check the implementation of arrangements within targeted facilities. This intervention was carried out in line with ONR’s guidance, which can be found on ONR’s website.
Based on the intervention activities and evidence sampled, I judge that Sellafield Ltd. has appropriate arrangements for tracking nuclear material in QS03 and QS23 and that those arrangements are being adequately implemented in accordance with NSR19 Regulations 3, 6, 9 (1) and NSR19 Schedule 2 requirements to implement and comply with the arrangements and procedures described in the ACP and BTC. ONR regulatory expectations detailed in Fundamental Safeguards Expectations (FSEs) 7 and 8 of the ONR Nuclear Material Accountancy, Control and Safeguards Assessment Principles (ONMACS) were also adequately met.
After reviewing the records provided by Sellafield Ltd. prior to the intervention, and following the presentations given, I provided Regulatory Advice that both the Basic Technical Characteristics (BTC) and ACP for QS03 will require updates now that reprocessing is complete.
I gave two further pieces of regulatory advice relating to quality assurance and accessing source documentation and raised one regulatory issue relating to written arrangements in place for the estimation of Qualifying Nuclear Material (QNM) content of fuel debris and fragments of fuel rods in skips.
For all batches sampled, I am content that Sellafield Ltd. are maintaining adequate operating and accounting records required by NSR19 Regulations 10 and 11 and that these records are traceable to and underpin the declarations within the accounting reports submitted to ONR in line with NSR19 Regulations 12, 14 and 20.
Conclusion
On the basis of the evidence sampled at the time of the intervention, I judge that Sellafield Ltd. are adequately implementing arrangements for accountancy and control of QNM in line with regulatory expectations and are compliant with NSR19 Regulations 3, 6, 9 10, 11, 12, 14, 20 and Schedule 2. I also judge that Sellafield Ltd. is meeting the expectations for nuclear material tracking as detailed in FSEs 7 and 8.
A Level 4 Regulatory Issue was raised to address the lack of written arrangements and source documentation for the estimation of QNM content in “scooped” batches in QS23. This will track actions and bring Sellafield Ltd. come back into compliance with NSR19 Regulations 11(1)(b), 11(2) and Schedule 2. 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 appropriate here.