Executive summary
Date(s) of inspection: June 2023
Aim of inspection
ONR nuclear safeguards inspectors conducted an accountancy and physical inventory take evaluation focussed a compliance inspection of the Sellafield Ltd Material Balance Areas (MBAs) QS01 (B27 Oxide Fuel Storage Pond Bays 2-5), QS08 (B310 AGR Fuel Storage Pond) and QS20 (THORP Receipt and Storage). 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).
ONR formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance of Sellafield Ltd.’s compliance against the following regulations 6(1-4), 9(1), 10, 11, 12(1-2), 14, 15, 20 and Schedule 2 in NSR19:
To form effective regulatory judgements on Sellafield Ltd’s compliance with the NSR19 regulations listed above, inspectors considered the expectations in ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS), particularly FSEs 7, 8, and 9.
Subject(s) of inspection
- 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: 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 Reg15 - Material balance report and physical inventory listing - 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 inspection and assessment plan 2023/24 for Sellafield Ltd, ONR Safeguards carries out Safeguards compliance inspections at the Sellafield Ltd site. One such intervention was performed to inspect Sellafield Ltd’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy and physical inventory taking. For this intervention the Material Balance Areas (MBAs) known as QS01 (B27 Oxide fuel storage pond bays 2-5) QS08 (B310 AGR fuel storage pond) and QS20 (THORP receipt and storage) were selected and the inspection planned as an accountancy/physical inventory take (PIT) evaluation blended compliance inspection.
This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 9, 10, 11, 12, 14, 15 and 20. Further, a number of Fundamental Safeguards Expectations (FSEs) within ONMACS were used to inform the judgements of compliance against NSR19. In particular: FSE7, FSE8 Control, FSE9 – Material Balance.
I carried out an accountancy/PITe blended compliance inspection, focussing on the MBAs QS01 (B27 Oxide fuel storage pond bays 2-5) QS08 (B310 AGR fuel storage pond) and QS20 (THORP receipt and storage) at the Sellafield Ltd nuclear licensed site. The inspection comprised of discussions with staff, reviews of operating and accounting records, sampling of arrangements documents and their implementation and a plant walkdown within an MBA.
The inspection targeted the operator’s arrangements for nuclear material accountancy and control of Qualifying Nuclear Material (QNM) as well as the physical inventory take of QNM. This included implementation of nuclear material accountancy arrangements, evidenced by sampling of nuclear material accounting report lines from Inventory Change Reports (ICRs) and Physical Inventory Listings (PILs) submitted to ONR. This also included implementation of PIT arrangements including those to prepare and execute PITs in the MBAs sampled.
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on ONR’s website (onr.org.uk).
No significant shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected and the plant walkdown undertaken, I judge Sellafield Ltd has adequately implemented their arrangements for nuclear material accountancy and control of QNM in QS01, QS08 and QS20. I judge the sampled operating and accounting records to be compliant with NSR19 Regulations 10 and 11 respectively. I also judge that these records were traceable to and underpin the sampled declarations within the accountancy reports submitted to ONR in line with NSR19 Regulations 12, 14, 15 and 20. Furthermore, I judge that Sellafield Ltd. broadly met ONR’s regulatory expectations for nuclear material tracking as per FSE 7 and data processing and control as per FSE 8 in ONMACS.
Based on the plant walkdown and discussions I held with the key staff on plant and within the safeguards team 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 implementation of these arrangements is supporting the accountancy and control of QNM within these MBAs as required in NSR19 Regulation 6.
Based on the sample I inspected, I judge Sellafield Ltd has adequately implemented their arrangements for undertaking physical inventory takings in QS01, QS08 and QS20. Furthermore, I judge that Sellafield Ltd. broadly met ONR’s regulatory expectations for undertaking a PIT as per FSE 9 in ONMACS.
I provided four pieces of regulatory advice relating to: Sellafield Ltd improving the level of detail and clarity in written arrangements for undertaking a PIT, removing or updating the plant standards paper reference in the QS01 BTC, use of a safeguards seal for unirradiated items in the dry store of QS20, adding of references to written PIT arrangements into the QS01 QS08 QS20 ACPs. I also made two observations.
I was satisfied that the documentation reviewed, records sampled and evidence collected was adequate and I therefore judge Sellafield Ltd to be compliant against NSR19 Regulations 6, 9, 10, 11, 12, 14, 15 and 20. Further, I judge Sellafield Ltd’s arrangements and their implementation to broadly meet ONR’s regulatory expectations under FSE7, FSE8 and FSE9.
Conclusion
Based on the sample inspected, I judge that Sellafield Ltd are adequately implementing their arrangements for accountancy and control of QNM and undertaking PITs in compliance with the regulatory requirements of NSR19 regulations 6, 9, 10, 11, 12, 14, 15 and 20, and in line with regulatory expectations captured in FSE’s 7, 8 and 9 in ONMACS.
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.
I raised one regulatory issue on the implementation of regulatory advice provided during this QS01 QS08 QS20 accountancy/PIT inspection.