Executive summary
Date(s) of inspection: December 2023
Aim of inspection
ONR (Office for Nuclear Regulation) Nuclear inspectors carried out a Physical Inventory Take evaluation (PITe) compliance inspection at Sellafield Analytical Services (QS27). The purpose of this inspection was to provide regulatory confidence to ONR (Office for Nuclear Regulation) that the operator has and retains adequate operating records and accounting records, which are traceable to the accounting reports, which are underpinned by suitable arrangements for carrying out a PIT. This inspection sought evidence of arrangements and their implementation to make judgements of compliance against Regulations 6, 9, 10, 11, 15, 20 of NSR19.
To form effective regulatory judgements on Sellafield Ltd.’s compliance with NSR19, I also considered Fundamental Safeguards Expectations (FSE) 7, 8 and 9 as described by the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
To form effective regulatory judgements on Sellafield Ltd.’s compliance with NSR19, I also considered Fundamental Safeguards Expectations (FSE) 7, 8 and 9 as described by the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
ONR seek to draw an independent and informed regulatory judgement that these components of Sellafield Ltd’s system for accountancy and control are implemented in a manner which is proportionate to and appropriate for the qualifying nuclear facility.
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 Reg15 - Material balance report and physical inventory listing - Rating: Green
- NSR19 Reg20 - Weight units and categories of qualifying nuclear materials - Rating: Green
- Overall Inspection Rating - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection comprised of discussions with Sellafield Ltd. staff, reviews of operating and accounting records, arrangements, and procedures for carrying out a Physical Inventory Take (PIT), accountancy and control and a plant walkdown.
The inspection targeted the arrangements for the PIT to assess their adequacy and implementation. I sampled the data included in the source data/accountancy records for completeness and correctness of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility.
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).
I undertook discussions with key Sellafield Ltd. staff involved in accounting for and controlling nuclear material both in the central Nuclear Material Accountancy & Safeguards Team (NMAS) and QS27 Nuclear Material Custodians (NMC) gathering evidence that showed adequate implementation of suitable arrangements for Physical Inventory Take (PIT) of Qualifying Nuclear Material QNM. I was satisfied that Sellafield Ltd. presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted ONR to and to carry out their annual PIT under Regulation 11, and 15 of NSR19. I inspected NMAC arrangements and saw evidence that those arrangements are appropriately implemented. I sampled several batches of QNM throughout the facility and judge that these are managed in accordance with duty holder's arrangements. I gave the Operator regulatory advice regarding additions to documentation.
The inspection targeted the arrangements for the PIT to assess their adequacy and implementation. I sampled the data included in the source data/accountancy records for completeness and correctness of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility.
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).
I undertook discussions with key Sellafield Ltd. staff involved in accounting for and controlling nuclear material both in the central Nuclear Material Accountancy & Safeguards Team (NMAS) and QS27 Nuclear Material Custodians (NMC) gathering evidence that showed adequate implementation of suitable arrangements for Physical Inventory Take (PIT) of Qualifying Nuclear Material QNM. I was satisfied that Sellafield Ltd. presented adequate operating and accounting records that are traceable to and underpin the declarations within the accountancy reports submitted ONR to and to carry out their annual PIT under Regulation 11, and 15 of NSR19. I inspected NMAC arrangements and saw evidence that those arrangements are appropriately implemented. I sampled several batches of QNM throughout the facility and judge that these are managed in accordance with duty holder's arrangements. I gave the Operator regulatory advice regarding additions to documentation.
Overall, based on the evidence sampled at the time of the inspection, I am satisfied that Sellafield Ltd. has demonstrated adequate implementation of its arrangements for Physical Inventory Take (PIT) for its QNM in Analytical services (QS27) in line with Regulations 6, 9, 10, 11, 15, 20 of NSR19. I also judge that Sellafield are broadly meeting the expectations for FSEs (Fundamental Safeguards Expectation) 7, 8 and 9.
Conclusion
Overall, from the arrangements and items I sampled at the inspection, I am satisfied that Sellafield Ltd are meeting the requirements of NSR19 and no matters requiring immediate regulatory attention were identified during this inspection. Based on the evidence provided in Analytical services (QS27) I judge Sellafield Ltd. is compliant in this MBA with the requirements for Physical Inventory Take (PIT) set out in NSR19, specifically, Regulations 6, 9, 10, 11,15, 20. As well as FSE 7, 8 and 9 so I consider, that an inspection rating of Green (no formal action) is merited.