Executive summary
Date(s) of inspection: June 2024
Aim of inspection
The purpose of this inspection was to provide assurance that Eckert and Ziegler Environmental Services Ltd's accountancy arrangements are appropriate and proportionate for the qualifying nuclear facility and that they are being adequately implemented for nuclear material accountancy and control of Qualifying Nuclear Material (QNM). This includes maintaining adequate operating records and accounting records, which are traceable to the accounting reports provided to the ONR and are underpinned by suitable accountancy arrangements.
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: GREEN
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 2 Organisational Culture - Rating: GREEN
- FSE 3 Competence Management - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - Rating: GREEN
- FSE 5 Reliability, Resilience and Sustainability - Rating: GREEN
- FSE 6 Measurement Programme and Control - Rating: GREEN
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- FSE 8 Data Processing and Control - Rating: GREEN
- FSE 9 Material Balance - Rating: GREEN
- NSR19 Reg03 - Declaration of basic technical characteristics - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg08 - Replacement, amendment and revocation of accountancy and control plan - 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 Reg31 - Declaration of basic technical characteristics, stock list and accounting records for qualifying nu - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The purpose of this planned inspection was to inform ONR’s judgement regarding the adequacy of Eckert and Ziegler Environmental Services Ltd.’s NMACS arrangements and implementation to demonstrate compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), Regulations 3, 6, 7, 8, 9, 10, 11 and 31(5). This inspection was targeted based on regulatory intelligence, related to the clarity of references made within the Basic Technical Characteristics (BTC) and Accountancy and Control Plan (ACP) and the ONR integrated inspection strategy for Qualifying Nuclear Facilities with Limited Operation (QNFLO) which details the regulatory risk from the Qualifying Nuclear Material (QNM) holdings along with previous NSR19 compliance level.
As part of the inspection, I reviewed the operators arrangements and records, spoke to the operator and conducted a plant walkdown to gain assurance of the adequacy of the Eckert and Ziegler Environmental Services Ltd system for NMACS. To inform my judgements on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance (TAG), the Safeguards Technical Inspection Guidance (TIG) and ONR’s Fundamental Safeguards Expectations (FSE) proportionate to a QNFLO, based on the ONR guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
On reviewing the arrangements and implementation of NMACS at Eckert and Ziegler Environmental Services Ltd, I found:
- The correct Annexe format has been used for the BTC and the information provided within is judged as adequate. I judge, from the evidence sampled that this BTC can be rated GREEN.
- >The description of the NMACS arrangements presented within the ACP, and the inspected evidence provided me with assurance that Eckert and Ziegler Environmental Services Ltd implements appropriate and proportionate NMACS arrangements which meet my expectations as described by the Safeguards TIG, Safeguards TAG and ONMACS FSEs as appropriate for QNFLO. I judge, from the evidence sampled that the ACP can be rated GREEN.
The following Regulatory Advice was provided to Eckert and Ziegler Environmental Services Ltd. based on the findings of this Compliance Inspection:
- Regulatory Advice 1 - I advised that an instructional document be produced to detail the procedure for producing and reporting the annual PIL and MBR declarations.
- Regulatory Advice 2 - I advised that document EZE-MS-PR-007 be updated to include or signpost to information on nonconformity and corrective action management procedures for NMACS discrepancies and the Incident Notification Form (INF1) process.
- Regulatory Advice 3 - I advised that details for NMACS notifiable events be included within document EZE-OP-PR-009.
- Regulatory Advice 4 - I advised that document EZE-OP-PR-006 be updated to reflect the current nuclear material accountancy reporting requirements.
- Regulatory Advice 5 - I advised that signposting to the ACP and other relevant NMACS procedures be added to the BTC as it will ensure adequate details of their arrangements for Accountancy, Control and Organisational arrangements are noted.
- Regulatory Advice 6 - I advised the inclusion of additional signposting within the ACP to all the relevant NMACS procedures to allow the ACP to be used as a quick reference and training guide.
The operator’s progress against the regulatory advice provided will be monitored by QNFLO Safeguards Inspectors as part of routine regulatory business.
Based on the findings I judge that Eckert and Ziegler Environmental Services Ltd.’s NMACS arrangements and implementation of the arrangements adequately comply with NSR19’s statutory requirements and meet ONR’s Safeguards regulatory expectations for NSR19 regulations 3, 6, 7, 8, 9, 10, 11 and 31(5).
Noting ONR’s inspection rating guidance I judge that a rating of GREEN is merited for this inspection.
Conclusion
This report presents the findings of the ONR Inspection of Eckert and Ziegler Environmental Services Ltd. which reviewed their NMACS arrangements and implementation.
I compared the details of the NMACS arrangements included in the BTC and ACP and supporting arrangements against ONR’s Safeguards regulatory expectations. Based on the findings during this inspection, I judge the Eckert and Ziegler Environmental Services Ltd.’s NMACS adequately signpost, underpin, and explain how NMACS is being implemented at the site. Therefore, the NMACS meet my expectations as described by the Safeguards TIG and TAG, and the ACP document and arrangements meet my expectations as described by the ONMACS FSE as appropriate for QNFLO.
Overall I judge that Eckert and Ziegler Environmental Services Ltd. fulfil the reporting requirements of NSR19 Regulation 31(5), and meet all the regulatory requirements of NSR19 Regulations 3, 6, 7, 8, 9, 10 and 11.
Noting ONR’s inspection rating guidance I judge that a rating of GREEN is merited for this inspection.