Executive summary
Date(s) of inspection: November 2023
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).
Accountancy and Control Plan (ACP) inspection involves a set of activities carried out by inspectors at a Qualifying Nuclear Facility (QNF) to assure them that the arrangements and procedures describe in the ACP that form the system of accountancy and control are being implemented effectively at the facility. The purpose of an ACP inspection, as detailed in Appendix 4 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3, is to ensure that the operator has established a robust accountancy and control system and that its implementation on site complies with the requirements specified in NSR19.
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - 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 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
- Overall Inspection Rating - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguard's integrated intervention strategy 2023/24 for Sellafield Ltd, ONR Safeguards undertakes several 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 the Accountancy and Control Plan (ACP) and the arrangements being implemented in a manner which is consistent with the ACP, proportionate to, and appropriate for the qualifying nuclear facility within material balance areas (MBAs):
- QS06 (Pu Decommissioning – Finishing Line 3)
- QS35 (Sellafield MOX Plant), and
- QS40 (Dounreay Exotics Storage Facility)
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 identified one minor shortfall relating to authenticated source documentation and continuous use instructions within MBA QS35 for glovebox sweepings containers, and I am raising a Level 4 Regulatory Issue to monitor Sellafield Ltd’s resolution of this shortfall.
I provided one piece of regulatory advice relating to Sellafield Ltd capturing local guidance for facilities in relation to identifying and reporting incidents with relevance to NMACS, as well as communications with the Sellafield Ltd Nuclear Material accountancy and Safeguards (NMAS) team.
Based on the sampled evidence I judge Sellafield Ltd. is implementing appropriate and proportionate arrangements for nuclear material accountancy at QS06, QS35 and QS40 and have met the requirements for nuclear material accountancy set out in NSR19, specifically, Regulations 3, 6(1-4), 9(1) 10(1), 11(1-4), 12, Schedule 2 and ONR regulatory expectations in ONMACS FSEs 4, 6, 7, 8, 9 and 10.
Conclusion
No matters requiring immediate regulatory attention were identified during this inspection.
I have raised one level 4 regulatory issue to monitor the resolution of a minor shortfall.
Overall, on the basis of the evidence sampled, I judge that Sellafield Ltd are implementing appropriate and proportionate arrangements for the accountancy and control of qualifying nuclear material at MBAs QS06, QS35, and QS40, and have met the requirements of regulations 3, 6, 9, 10, 11 and 12and ONR regulatory expectations in ONMACS FSEs 4, 6, 7, 8, 9 and 10.
Therefore, in line with the ONR inspection rating guide, I consider an inspection rating of GREEN is appropriate.