Executive summary
Date(s) of inspection: July 2024
Aim of inspection
ONR nuclear safeguards inspectors conducted a nuclear material accountancy focussed compliance inspection of the Sellafield Ltd. ThORP Receipt and Storage (QS20) on the 2nd of July 2024. 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).
To form effective regulatory judgements on Sellafield Ltd.’s compliance with the NSR19 regulations listed above, inspectors considered the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within.
Subject(s) of inspection
- 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 Reg15 - Material balance report and physical inventory listing - 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 2024/25 for Sellafield Limited, ONR Safeguards carries out Safeguards compliance inspections at the Sellafield Limited site. One such intervention was performed to inspect Sellafield Limited’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. For this intervention the Material Balance Areas (MBA) known as QS20 was selected, specifically, ThORP Receipt and Storage (TRS). The intervention was to judge whether Sellafield had adequate arrangements for the consolidation of Advanced Gas-cooled Reactor (AGR) fuel into new 63 can rack pond furniture, and that these arrangements were being implemented.
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 and 15 and FSEs 7 and 8.
I carried out an accountancy-focussed compliance inspection, focussing on the MBA QS20 (ThORP Receipt and Storage) at the Sellafield Limited nuclear licensed site. The inspection comprised of discussions with staff, reviews of operating and accounting records, and a plant walkdown within the MBA.
The inspection targeted the operator’s arrangements for nuclear material accountancy and their implementation. In particular, this included the methodology by which AGR fuel is consolidated from 20 compartment skips into 63-can racks within the ponds. The inspection also targeted whether the accountancy arrangements for this activity was adequately implemented by demonstrably suitably qualified and experienced personnel (SQEP).
Based on the sample I inspected, I judge Sellafield Limited has adequately implemented their accountancy arrangements for consolidation of AGR fuel from skips into 63 can racks in TRS. I also judge that these records were appropriate, traceable to, and adequately underpin the inventory change reports submitted to ONR in line with NSR19 Regulation 14.
Based on the plant walkdown and discussions I held with the key staff on plant and within the safeguards team I judge that Sellafield Limited 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 qualifying nuclear material within this MBA, as required in NSR19 Regulation 6.
I identified a shortfall during the inspection, a discrepancy in the accountancy of two slotted cans in the TRS AGR Pond was reported during consolidation activities. A slotted can was found to be in the wrong location, and the expected can had been reprocessed in 2018 with no accountancy actions carried out to correct the discrepancy at the time. I am raising a level 4 regulatory issue (RI-12156) for Sellafield Limited to provide additional information on the extent to which this incident could reoccur. Sellafield Limited, as per their own arrangements, have reported the incident to ONR (INF-4198).
I was satisfied that the documentation reviewed, records sampled, and evidence collected was adequate and I, therefore, judged Sellafield Limited to be compliant against NSR19 regulations 10, 11 and 14 and FSEs 7 and 8.
Conclusion
Based on the sample inspected, I judge that Sellafield Limited are implementing their arrangements for accountancy and control of QNM in-line with regulatory expectations and are compliant with NSR19 requirements and Fundamental Safeguards Expectations.
I am raising one Level 4 regulatory issue as follows:
RI-12156 –I identified a discrepancy in the accountancy of slotted cans in the TRS AGR Pond. During consolidation activities, a slotted can was found to be in the wrong location; the expected can had been reprocessed in 2018 with no accountancy actions carried out to correct the discrepancy at the time. This regulatory issue will track Sellafield Ltd’s efforts to report the extent of further slotted can ID discrepancies in QS20.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of green (no formal action) is appropriate.