Executive summary
Date(s) of inspection: August 2022
Aim of inspection
The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) require in Regulation 6 that operators “maintain a system of accountancy and control” and that the components of this system must be implemented “in a manner which is proportionate to and appropriate for the basic technical characteristics of the qualifying nuclear facility”. ONR nuclear safeguards inspectors will conducted an accountancy focussed compliance inspection of the Sellafield Ltd Material Balance Area (MBA) QS27 – Analytical Services 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 will formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance of Sellafield Ltd.’s compliance against the following Regulations in NSR19:
- Regulation 6 (1-4): Accountancy and Control of Qualifying Nuclear Material. Including Schedule 2.
- Regulation 9: Operation of an Accountancy and Control Plan (ACP)
- Regulation 10: Operating Records.
- Regulation 11: Accounting Records.
- Regulation 12 (1-2): Accounting Reports.
- Regulation 14: Inventory Change Reports
- Regulation 15: Material balance report and physical inventory listing
To form effective regulatory judgements on Sellafield Ltd.’s compliance with the NSR19 regulations listed above,
I considered the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within. There will be a particular focus on FSE 3, 7, 8 & 9.
Subject(s) of inspection
- 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 Reg12 - Accounting reports - Rating: Green
- NSR19 Reg14 - Inventory change report - Rating: Green
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2022/23 for Sellafield Ltd., ONR carries out safeguards compliance interventions across the Sellafield site. One such intervention was performed to assess compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy in Analytical Services - Material Balance Area (MBA) QS27.
I carried out an accountancy focused compliance inspection at Analytical Services. The purpose of this accountancy focused inspection was to provide confidence to ONR that the operator has and retains adequate operating records and accounting records which are traceable to the accounting reports, and are underpinned by suitable accountancy arrangements. This inspection sought evidence of arrangements and their implementation to make judgements of compliance against NSR19 regulations 6(1-4) including schedule 2, 9, 10, 11, 12(1-2), 14 and 15.
To form effective regulatory judgements on Sellafield Ltd.’s compliance with NSR19, I also considered the following expectations as described by the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS):
- FSE 3 – Competence Management
- FSE 7 – Nuclear Material Tracking
- FSE 8 – Data Processing and Control
- FSE 9 – Material Balance
The inspection comprised of discussions with Sellafield Ltd. staff, reviews of operating and accounting records, arrangements and procedures for accountancy and control, and a plant walkdown.
The inspection targeted the completeness and correctness of the operating and accounting records (source documentation) which underpinned a sample of batches of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility. The inspection also targeted whether these source documents were traceable to the accountancy reports and whether arrangements for generation of source documentation and accountancy reports in Analytical services were adequately implemented.
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).
I undertook discussions with key Sellafield Ltd. staff involved in accounting for and controlling nuclear material both in the central Nuclear Material Accountancy & Safeguards Team (NMAS) and QS27 Nuclear Material Custodians (NMC) gathering evidence that showed adequate implementation of suitable arrangements for accountancy and control of QNM. I was satisfied that Sellafield Ltd. presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted to ONR under Regulation 11,12 and 14 of NSR19.
I inspected NMAC arrangements at site and saw evidence that those arrangements are appropriately implemented. I sampled several batches of QNM throughout the facility and judge that these are managed in accordance with duty holders arrangements.
I gave the Operator one piece of regulatory advice regarding referencing contingency arrangements in an updated ACP.
Overall, based on the inspection sample, I am satisfied that Sellafield Ltd. has demonstrated adequate accountancy and control, is generating accounting and operating records that are complete and correct and is implementing its arrangements for accountancy and control for its QNM in Analytical services (QS27) that meet relevant good practice
I provided feedback to the site on the inspection findings at a close-out meeting.
Conclusion
No matters requiring immediate regulatory attention were identified during this inspection.
Based on the inspection sample I judge Sellafield Ltd. is compliant with the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 6(1-4), 9, 10, 11, 12(1-2), 14 and 15. Noting ONR guidance on inspection ratings, overall, based on my sample I am satisfied that Sellafield Ltd. Analytical Services meets the requirements of NSR19 regulations 6, 9, 10, 11, 12, 14, and 15 as well as FSE 3, 7, 8 & 9 so I consider, that an inspection rating of Green (no formal action) is merited.