Executive summary
Date(s) of inspection: August 2022
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 a PIT is for the operator to establish the physical inventory within an MBA at a given date and involves the operator identifying, counting, measuring or deriving estimates of all qualifying nuclear material (QNM). A PITe inspects the suitability of arrangements made and the adequacy of their implementation as detailed in Appendix 2 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3.
Subject(s) of inspection
- FSE 3 Competence Management - 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 Reg06 - Accountancy and control of qualifying nuclear material - Rating: AMBER
- NSR19 Reg09 - Operation of an accountancy and control plan - Rating: AMBER
- NSR19 Reg10 - Operating records - Rating: GREEN
- NSR19 Reg11 - Accounting records - 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 2021/22 for Sellafield Ltd, ONR Safeguards undertakes a number of safeguards compliance inspections at the Sellafield site. An inspection was undertaken to assess Sellafield Ltd's compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to evaluating the implementation of arrangements for performing a Physical Inventory Take (PIT). The inspection sampled the PIT arrangements in:
- Fuel Handling Plant Magnox Decanners (Material Balance Area (MBA) QS23)
- Magnox Reprocessing Fuel Operations (MBA QS03)
- Finishing Line 5 (FL5) (MBA QS25)
The inspection comprised of discussions with Sellafield Ltd staff, sampling and review of Sellafield Ltd operating, accounting records and other source documentation, and plant walkdowns 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 sampled evidence I judge Sellafield Ltd is implementing appropriate and proportionate arrangements for the undertaking of a PIT at QS23 and QS03. I am not satisfied that Sellafield is implementing appropriate and proportionate arrangements for undertaking a PIT at QS25 in line with the claims made in the Sellafield Ltd Accountancy and Control Plan (ACP). I consider this to represent a significant shortfall against regulation 9(1) of NSR19 and I have raised a Level 3 Regulatory Issue to seek improvement and monitor progress against this compliance shortfall.
Based on the sampled evidence, I judge that the Sellafield Ltd 2022 PIT undertaken was unable to produce accurate and representative information on estimates of Qualifying Nuclear Material (QNM) within specific areas of QS03. I consider this to represent a significant shortfall against regulation 6(3) and schedule 2(4) of NSR19 and I have raised a Level 3 Regulatory Issue to seek improvement and monitor progress against this compliance shortfall.
I identified a minor shortfall relating to the use of parallel accountancy systems at QS03, where two different types of measurement equipment were being used by Sellafield Ltd to generate source documentation on the same QNM resulting in record discrepancies. This represents a shortfall against MACE 8.3 of ONR's Regulatory Expectations as outlined in ONMACS. I have raised a Level 4 Regulatory Issue for Sellafield to conduct a review of the measurement systems being utilised to generate source documentation accountancy records during the QS03 PIT.
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:
Fuel Handling Plant Magnox Decanners (QS23); NSR 19 regulations 6 (1-4) , 9(1) , 10 (1) , 11(1-4) , 15 , 20 , Schedule 2 and ONMACSs FSEs 3, 6, 7, 8, 9.
Magnox Reprocessing fuel operations; NSR 19 regulations 6 (1-4) , 10 (1) , 11(1-4) , 15, 20 and ONMACs FSEs 3, 6, 7, 8, 9.
Finishing Line 5 (QS25); NSR 19 regulations 6 (1-4), 10 (1) , 11(1-4), 15, 20, Schedule 2 and ONMACs FSE 3, 6, 7, 8, 9.
I have identified two significant shortfalls against the following regulations which resulted in AMBER ratings against:
Magnox Reprocessing Fuel Operations (QS03), NSR 19 regulations 6 (1-4) and 9(1)
Finishing Line 5 (QS25) NSR 19 regulations 9(1).