Executive summary
Date(s) of inspection: November 2022
Aim of inspection
ONR nuclear safeguards inspectors are scheduled to visit Sellafield Ltd. on 30th November 2022 for the purpose of conducting an Accountancy and Control Plan (ACP) Compliance Inspection of the Sellafield Ltd Magnox and AGR fuel storage pond. The purpose of this inspection is to is to seek evidence in support of Sellafield Ltd.’s’ compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR will form regulatory judgements and provide a rating in line with ONR’s inspection rating guidance of Sellafield Ltd.’s compliance against the following Regulations specified in the (EU Exit) Regulations 2019 (NSR19):
- Regulation 9 – Operation of an accountancy and control plan.
To form effective regulatory judgements on Sellafield Ltd.’s compliance with the NSR19 regulations listed above, ONR will consider the following expectations as outlined in 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
- FSE10 - 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
Key findings, inspector's opinions and reasons for judgement made
I carried out an ACP compliance inspection, focussing on the MBAs QS10 and QS21 at the Sellafield Ltd. nuclear licensed site. The inspection comprised of discussions with staff, demonstration of accountancy systems, and reviews of associated procedures, training records, operating and accounting records.
The inspection targeted two components. First, the new Computerised Nuclear Material Accountancy System (CNMAS) which is currently in the process of user acceptance testing (UAT). This involved a demonstration of the CNMAS system and review of associated procedures and training. Second, the procedures surrounding the review and ongoing management of the site ACP and Sellafield Site Sellafield Ltd. ACP annex for QS10 and QS21. As part of these targets I ensured that both were adequately implemented by demonstrably suitably qualified and experienced personnel (SQEP).
No significant shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected, I judge Sellafield Ltd. has adequately implemented the following elements;
- Data-processing system as claimed within the ACP,
- Maintain effective arrangements to manage the competence of those with assigned nuclear material accountancy control and safeguards (NMACS) roles and responsibilities,
- Arrangements and procedures for NMACS
- The NMACS system performance is being monitored and reviewed through any performance metrics established in associated procedures.
Based on the demonstration of CNMAS, discussions with relevant staff, and review of associated procedures I judge that Sellafield Ltd. are implementing the arrangements described in their Accountancy and Control Plan (ACP) as required by NSR19 Regulation 9 and that the implementation of these arrangements is supporting the accountancy and control of qualifying nuclear material (QNM) within these MBAs as required in NSR19 Regulation 6.
I provided four pieces of regulatory advice relating to; the ongoing development of the nuclear material accounatncy system and its management through an existing regulatory issue, the appropriate management of ACP updates, reference to relevant ONR guidance within Sellafield procedures, and minor discrepancies within the ACP requiring an update to be managed as part of an ongoing regulatory issue. These will be managed through ongoing regulatory issues.
Conclusion
Based on the sample inspected, I judge that Sellafield Ltd. are implementing their arrangements for the operation of an ACP and that the implementation of these arrangements is supporting the accountancy and control of QNM in-line with regulatory expectations and are compliant with the following NSR19 requirements:
- Regulation 6 – Accountancy and control of qualifying nuclear material
- Regulation 9 – Operation of Accountancy and Control Plan
I did not identify any significant or minor shortfalls in compliance against NSR19 during this intervention.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of green (no formal action) is appropriate.