Executive summary
Date(s) of inspection: November 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 an accountancy focussed inspection is to:
- examine operating and accounting records to establish a correct set of data and to provide confidence to ONR that the operator has an adequate nuclear material accountancy and control system established
- examine the specific arrangements and procedures in place for nuclear material
accountancy
as detailed in Section 5 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - 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
- 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 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 nuclear material accountancy and control arrangements within MBAs QS04, QS25 and QS28 being implemented in a manner, which is proportionate to, and appropriate for the qualifying nuclear facility. The inspection sampled the arrangements in:
- SNM (North) Store 5 and Store 17 (MBA QS04)
- Finishing Line 4 (MBA QS25)
- Store 9 Extension (MBA QS28)
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).
I provided one piece of Regulatory Advice relating to endoscopy checksheets that are utilised within the SNM (North) stores by the Sellafield Ltd. Nuclear Material Custodian, which are currently not part of the Sellafield Ltd. Management System (SLMS). I prompted Sellafield Ltd. to consider the assurance these checksheets provide and whether they should be incorporated into existing formal written arrangements.
Based on the sampled evidence I judge Sellafield Ltd. is implementing appropriate and proportionate arrangements for nuclear material accountancy at QS04, QS25, and QS28 and have met the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 6, 10, 11, 12(1,2),14 and 20. Noting ONR guidance on inspection ratings, I am providing a GREEN rating for this inspection.
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:
SNM (North) stores 5 and 17 (MBA QS04); NSR 19 regulations 6 (1-4) , 9(1) , 10 (1) , 11(1-4) , 12 , 14, 20 , Schedule 2 and ONMACSs FSEs , 6, 7, 8, 10.
Finishing Line 4 (MBA QS25); NSR 19 regulations 6 (1-4) , 9(1) , 10 (1) , 11(1-4) , 12 , 14, 20 , Schedule 2 and ONMACSs FSEs , 6, 7, 8, 10.
Store 9 Extension (MBA QS28); NSR 19 regulations 6 (1-4) , 9(1) , 10 (1) , 11(1-4) , 12 , 14, 20 , Schedule 2 and ONMACSs FSEs , 6, 7, 8, 10.