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The University of Liverpool - Inspection ID: 53438

Executive summary

Date(s) of inspection: July 2024

Aim of inspection

The purpose of the NSR19 Compliance Inspection at The University of Liverpool (QULP) was to provide assurance to ONR that the operator’s accountancy arrangements are appropriate and proportionate for the qualifying nuclear facility and that they are adequately implemented for nuclear material accountancy and control of Qualifying Nuclear Material (QNM). This includes maintaining adequate operating records and accounting records, which are traceable to the accounting reports provided to the ONR and are underpinned by suitable accountancy arrangements.

Subject(s) of inspection

  • FSE 1 Leadership and Management for NMACS - Rating: GREEN
  • FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
  • FSE 2 Organisational Culture - Rating: GREEN
  • FSE 3 Competence Management - Rating: GREEN
  • FSE 4 Reporting, Anomalies, and Investigations - Rating: GREEN
  • FSE 5 Reliability, Resilience and Sustainability - 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 Reg07 - Accountancy and control plan - Rating: GREEN
  • NSR19 Reg08 - Replacement, amendment and revocation of accountancy and control plan - 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 Reg31 - Declaration of basic technical characteristics, stock list and accounting records for qualifying nu - Rating: GREEN

Key findings, inspector's opinions and reasons for judgement made

The purpose of this planned inspection was to inform ONR’s judgement regarding the adequacy of The University of Liverpool's NMACS arrangements and implementation to demonstrate compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19);

Regulation 3,Regulation 6, Regulation 7, Regulation 8, Regulation 9, Regulation 10, Regulation 11, Regulation 31(5).

This inspection was targeted based on regulatory intelligence, related to the clarity of references made within the Basic Technical Characteristics (BTC) and Accountancy and Control Plan (ACP) and the ONR integrated inspection strategy for Qualifying Nuclear Facilities with Limited Operation (QNFLO) which details the regulatory risk from the Qualifying Nuclear Material (QNM) holdings along with previous NSR19 compliance level.

As part of the inspection, I reviewed the operators arrangements and records, spoke to the operator and conducted a plant walkdown to gain assurance of the adequacy of The University of Liverpool's system for NMACS. To inform my judgement on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance (TAG), the Safeguards Technical Inspection Guidance (TIG) and ONR’s Fundamental Safeguards Expectations (FSE) proportionate to a QNFLO, based on the ONR guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).

On reviewing the arrangements and implementation of NMACS at The University of Liverpool, I found:

  • The correct Annexe format has been used for the BTC and the information provided within is judged as adequate. I judge, from the evidence sampled that this BTC can be rated GREEN.
  • The description of the NMACS arrangements presented within the ACP, and the inspected evidence provided me with assurance that The University of Liverpool implements appropriate and proportionate NMACS arrangements which meet ONR's expectations as described by the Safeguards TIG, Safeguards TAG and ONMACS FSEs as appropriate for QNFLO. I judge, from the evidence sampled that the ACP can be rated GREEN.

The following Observations and Regulatory Advice were provided to The University of Liverpool. based on the findings of this Compliance Inspection:

BTC - Observation 1 - I advised the following:

  • Paragraph 2 - A generic email be used where possible.
  • Paragraph 10 - Wording be added to the effect of " The RPO undertakes a physical inventory of all materials in January each year under regulation 31(5)(b) of NSR19"
  • Paragraph 11 - This section could signpost the ACP for continuity and be used as a quick reference and training guide.
  • Paragraph 11 - states "you are required to submit an ICR". This is no longer appropriate and should be re-worded to note that ICR's are an internal administrative practice for monitoring control of QNM.
  • ACP - Observation 2 - I advised that details listed for NSR2019 should be changed to NSR19 and the Nuclear Safeguards Act 2018 and not 2019
  • ACP - Observation 3 - I advised that paragraph 3 should state Regulation 7, Accountancy and Control Plan not Regulation 6, Accountancy and Control of qualifying nuclear material.
  • ACP - Observation 4 - I advised the inclusion of wording throughout the ACP from NSR19 should be word for word when stating extracts.
  • ACP - Observation 5 - I advised evidence that QA checks and signatures could be maintained on the ACP by adding a column to the revision table on the front page.
  • ACP - Regulatory Advice 1 - I advised that the document be updated to include or signpost to information on the Incident Notification Form (INF1) process and add a link to the ONR website, I also advised to incorporate further links to ONR Safeguards Guidance to detail the procedure for producing and reporting the annual PIL and MBR declarations
  • ACP - Regulatory Advice 2 - I advised that Section 3,C - Programme of Activities (POA) can be removed as University of Liverpool report under Regulation 31, which does not require this level of reporting and as noted under Regulation 31, Regulation 4, 12 to 15 and 21 to 24 do not apply to an operator of a qualifying nuclear facility with limited operation.

Based on the findings I judge that The University of Liverpool's NMACS arrangements and implementation of the arrangements adequately comply with NSR19’s statutory requirements and meet ONR’s Safeguards regulatory expectations for NSR19 regulations 3, 6, 7, 8, 9, 10, 11 and 31(5) and ONMACS FSE's, FSE1, FSE2, FSE3, FSE4, FSE5, FSE6, FSE7, FSE8, FSE9, and FSE10.

Noting ONR’s inspection rating guidance I judge that a rating of GREEN is merited for this inspection.

Conclusion

This report presents the findings of the ONR Inspection of University of Liverpool, which reviewed their NMACS arrangements and implementation.

I compared the details of the NMACS arrangements included in the BTC and ACP and supporting arrangements against ONR’s Safeguards regulatory expectations.

Based on the findings during this inspection, I judge The University of Liverpool’s NMACS adequately signpost, underpin, and explain how NMACS is being implemented at the site.

I judge that The University of Liverpool, fulfil the reporting requirements of NSR19 Regulation 31(5), and meet all the regulatory requirements of NSR19 Regulations 3, 6, 7, 8, 9, 10 and 11.

Noting ONR’s inspection rating guidance I judge that a rating of green is merited for this inspection.