Executive summary
Date(s) of inspection: July 2024
Aim of inspection
ONR nuclear safeguards inspectors conducted a safeguards compliance inspection at Urenco, on 23-24 July 2024. The purpose of this inspection was to seek evidence in support of Urenco’s compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
The increasing maturity of the ONE Capenhurst Operational model meant 24/25 provides an appropriate opportunity for Leadership and Management for Nuclear Material Accountancy, Control and Safeguards (NMACS) to be evaluated efficiently across all three business areas.
ONR forms regulatory judgements and provides a rating in line with ONR’s inspection rating guidance of Urenco's compliance against the following regulations in NSR19:
- Regulation 6 – Accountancy and control of qualifying nuclear material
- Regulation 7 – Accountancy and control plan
- Regulation 9 – Operation of an accountancy and control plan
To form effective regulatory judgements on Urenco’s compliance with the NSR19 regulations listed above, ONR considered, where relevant to inspection activities, the fundamental safeguards expectations (FSEs) detailed in the ONR Guidance for Nuclear Material Accountancy Control and Safeguards (ONMACS). In particular;
- FSE 1 – Leadership and Management for NMACS
- MACE 1.2 – Capable Organisation
- FSE 3 – Competence Management
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: GREEN
- FSE 3 Competence Management - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This inspection focused on seeking regulatory confidence that the operator is maintaining an appropriate system of accountancy and control of qualifying nuclear material that includes suitable arrangements for organisational capability.
I sought evidence of adequate arrangements and their implementation through discussions with Urenco staff, a review of records and documentation relevant to FSE1 & FSE3 in order to make judgements of alignment against regulatory expectations. To support consistency in our judgements we utilised Nuclear Material Accountancy, Control, and Safeguards Assessment Principles (ONMACS) [ONR-CNSS-MAN-001 Issue 5], and ONR’s Technical Inspection Guide: Safeguards [SG-INSP-GD-001, Issue 4].
Based on the inspection activities sampled I judge that Urenco are maintaining an appropriate system of accountancy and control of qualifying nuclear material complaint with the requirements of NSR19 Regulation 6 and are adequately implementing those arrangements in line with our regulatory expectations detailed in FSE 1 (MACE 1.2), and FSE 3 of ONMACS and rated the inspection GREEN. I have provided regulatory advice in relation to alignment with meeting regulatory expectations and observations, which were identified during the inspection. These were fed back to UUK at the end of the inspection who accepted the advice, I have judged that a regulatory issue is a an appropriate way to track this advice with the operator:
- Regulatory Advice: Urenco to determine how to appropriately include Urenco Technical Division (UTD) in future updates of the Governance and Leadership, and Capable Organisation sections of the Capenhurst ACPs, formalising their responsibilities with regards to safeguards for the projects they work on.
- Regulatory Advice: Urenco to determine how to appropriately capture the governance arrangements between UNS and the Site MD into the UNS ACP.
- Regulatory Advice: Urenco to confirm that the ACP appropriately captures explanation why Non-nuclear baseline roles listed as supporting achievement of Safeguards and uranium accountancy objectives are not included in the nuclear baseline resource.
- Regulatory Advice: Urenco to determine how best to formalise succession planning for NMACS to ensure a resilient organisation, and document their approach in their ACPs.
- Observation: The inspection identified that there are inconsistencies in how the role of the Nuclear Material Custodian is performed between the different operators, this was not evident from the ACPs. Urenco should standardised the custom and practice of the NMCs between the three operators, or reflect the differences in the role descriptions in the ACPs.
- Observation: I recommended a review learn improve exercise may be of value in how the site developed the Safeguards Officer role. Urenco should consider if undertaking a “lesson learned” exercise on the development of the Safeguards Officer role, would identify an opportunities to improve for future safeguards roles (e.g. dedicated safeguards manager, HALEU or Carousel associated roles, etc.)
- Observation: During the inspection I observed that the competency assessment procedure wasn’t directly referenced in the UUK ACP. While this activity is as described in the ACP, Urenco should consider directly referencing the competency assessment procedure in the UUK ACP (and likewise for UCP and UNS).
Conclusion
No matters requiring immediate regulatory attention were identified during this inspection.
On the basis of the evidence sampled, I judge that URENCO are adequately implementing arrangements for accountancy and control of QNM in line with regulatory expectations and are compliant with NSR19 Regulations 6, 7, & 9. I also judge that URENCO are meeting the expectations for Organisational Capability detailed in FSE 1 and 3. On this basis, I judge that a rating of GREEN (no formal enforcement) is appropriate.