Executive summary
Date(s) of inspection: December 2023
Aim of inspection
ONR nuclear safeguards inspectors will conduct a PITe compliance inspection of the Material Balance Area (MBA) QBS0 - "Storage areas for miscellaneous compounds, residues & sources" on the 12-13 December 2023. The purpose of this inspection is to seek evidence in support of Springfields Fuels Limited’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), specifically evidence that SFL has appropriate Physical Inventory Take (PIT) arrangements in place and that they are adequately implemented.
ONR will form regulatory judgements and provide a rating in line with ONR’s inspection rating guidance of Springfields Fuels Limited’s compliance against the following regulations in NSR19:
- Regulation 6(1-4): Accountancy and control of qualifying nuclear material,
- Regulation 9: Operation of an accountancy & control plan,
- Regulation 10(1): Operating records,
- Regulation 11(1-4): Accounting records,
- Regulation 14: Inventory change reports,
- Regulation 15 – Material balance report and physical inventory listing
To form effective regulatory judgements on Springfields Fuels Limited’s compliance with the NSR19 regulations listed above, inspectors will consider the ONR guidance for the assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) and the expectations within. There will be a particular focus on:
- FSE 3 - Competence management
- FSE 7 – Nuclear material tracking
- FSE 8 – Data processing and control
- FSE 9 - Material Balance
- FSE 10 - Quality assurance and control for NMACS
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: Green
- FSE 3 Competence Management - Rating: Green
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 8 Data Processing and Control - Rating: Green
- FSE 9 Material Balance - 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 Reg14 - Inventory change report - Rating: Green
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: Green
- Overall Inspection Rating - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This inspection was planned at Springfields Fuels Limited (SFL) during 2023/2024, in accordance with the Safeguards Sub-Division strategy and safeguards operational schedule supported by regulatory intelligence derived from operator declarations. This inspection was a Physical Inventory Taking evaluation (PITe) inspection of the operator’s arrangements and their implementation for compliance with the Nuclear Safeguards Regulations 2019 (NSR19) and was conducted in accordance with the safeguards operational schedule for 2023/2024.
The purpose of this PITe inspection was to seek evidence in support of SFL’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), specifically that SFL has appropriate Physical Inventory Taking (PIT) arrangements in place and that they are adequately implemented. The inspection targeted the Material Balance Area (MBA) QBS0 – Storage areas for miscellaneous compounds, residues & sources. The evidence sampled during the inspection was used to judge SFL’s compliance with NSR19, specifically the following regulations 6(1-4), 9, 10(1), 11(1-4), 14 and 15 in NSR19 and expectations.
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.
I carried out a PITe inspection at the SFL site, MBA QBS0. The inspection involved a two-day site visit, including plant walkdowns, discussions with relevant SFL personnel, review of records, and sampling of information contained within electronic databases and other documentation. During the inspection I sought to gain assurance of the adequacy of SFL’s arrangements for the PIT and that these arrangements are implemented adequately.
No significant or minor shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected of SFL’s PIT arrangements, including operating records and accounting records, I judge SFL to be compliant with NSR 19 regulations 6, 9, 10, 11,14 and 15 (including schedule 2) and that SFL are adequately implementing those arrangements for the PIT.
I specifically sampled the arrangements for the PIT at QBS0. I gave regulatory advice that SFL should include a number of operational documents to their document management system to ensure that all documents used are referenced accordingly. However, I judge that this did not impact on the accuracy or completeness of the operator’s PIT.
Conclusion
Based on the evidence sampled during the inspection, I judge that SFL has appropriate Physical Inventory Taking (PIT) arrangements in place and that they are adequately implemented in the MBA QBS0 – Storage areas for miscellaneous compounds, residues & sources. In my opinion SFL are compliant with regulations 6(1-4), 9, 10(1), 11(1-4), 14 and 15 in NSR19 and ONMACS expectations 3, 7, 8, 9 and 10.