Executive summary
- Date(s) of inspection: February 2023
Aim of inspection
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). The purpose of an accountancy focussed inspection is to:
- Examine operating and accounting records to establish a correct set of data and to provide confidence to ONR that the operator has an adequate nuclear material accountancy and control system established.
- Examine the specific arrangements and procedures in place for nuclear material accountancy.
As detailed in Section 5 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3.
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - Rating: GREEN
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- FSE 8 Data Processing and Control - 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
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguards integrated intervention strategy 2022/23 for Sellafield Ltd., ONR Safeguards undertakes a number of safeguards compliance inspections at the Sellafield Ltd. site. An accountancy-focussed inspection was undertaken to assess compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. The inspection was carried out in the AGR dismantling plant, Material Balance Area (MBA) QS17.
The inspection comprised of discussions with Sellafield Ltd. staff, sampling and review of Sellafield Ltd. operating, accounting records and other source documentation, organisation learning materials, and a plant walkdown to check implementation of arrangements. It was carried out in line with ONR's guidance which can be found on ONR’s website (onr.org.uk).
Based on the inspection sample I judge Sellafield Ltd. has presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted to ONR and is compliant with the requirements for nuclear material accountancy set out in NSR19, specifically, regulations 6, 9, 10, 11, 12, 14 & 20.
In relation to Sellafield’s compliance with NSR19 regulation 6, I am satisfied that the Sellafield Ltd. system of accountancy and control is underpinned by adequate implementation of arrangements relating to ONR Fundamental Safeguards Expectations 4 (Reporting, Anomalies, and Investigations), 7 (Nuclear Material Tracking), 8 (Data Processing), and Material Accountancy and Control Expectation 10.2 (Quality Assurance and Control Measures). Sellafield Ltd. had reported material previously unaccounted for in an AGR dismantling cell through their official arrangements, so I have raised a minor regulatory issue to track completion of actions from Sellafield Ltd.’s internal investigation.
Noting ONR guidance on inspection ratings, I consider this inspection to merit a rating of green. I am raising one minor regulatory issue as discussed above, and I have provided Sellafield Ltd. with regulatory advice regarding the adequate implementation of their arrangements for reporting, anomalies, and investigations and ONR’s expectations for incident reporting. I also observed good practice regarding Sellafield Ltd.’s preparations for the inspection, and their quality assurance mechanisms for accountancy reports.
Conclusion
In line with the ONR Inspection Rating Guide, based on the sampled evidence during the course of the intervention at Sellafield Ltd, I consider a rating of green against the following as identified within the scope of inspection:
- NSR19 Regulations: 6, 9, 10, 11, 12, 14 & 20
- ONMACS FSEs: 4, 7, 8, 10 (specifically MACE 10.2 paragraph: 218)
One Level 4 Regulatory Issue was raised for the purposes of tracking the completion of actions established by the ‘Basic Cause Investigation' (BCI)