Executive summary
Date(s) of inspection: May 2023
Aim of inspection
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). The purpose of a PIT is for the operator to establish the physical inventory within an MBA at a given date and involves the operator identifying, counting, measuring or deriving estimates of all qualifying nuclear material (QNM). A PITe inspects the suitability of arrangements made and the adequacy of their implementation as detailed in Appendix 2 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3.
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
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguards’ integrated intervention strategy 2023/24 for Sellafield Ltd, ONR Safeguards undertakes a number of safeguards compliance inspections at the Sellafield site. An inspection was undertaken to assess Sellafield Ltd's compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to evaluating the implementation of arrangements for performing a Physical Inventory Take (PIT). The inspection sampled the PIT arrangements in Special Nuclear Material Stores 5A, 5B, 6B, 8B, 9A, 9C, 10 & 17 (QS04).
The inspection comprised of discussions with Sellafield Ltd staff, sampling and review of Sellafield Ltd operating, accounting records and other source documentation, and plant walkdowns to check implementation of arrangements. It was carried out in line with ONR's guidance which can be found on ONR’s website (onr.org.uk).
Based on the sampled evidence, I am not satisfied that Sellafield Ltd is implementing appropriate and proportionate arrangements for undertaking a PIT at QS04 in line with the claims made in the Sellafield Ltd Accountancy and Control Plan (ACP). However, I judged that the Sellafield Ltd 2023 PIT undertaken at QS04 was able to produce accurate and representative information on quantities of Qualifying Nuclear Material (QNM) within QS04 through the sampling of key operating records and a plant walkdown. I consider this lack of arrangements for undertaking a PIT to represent a shortfall against Schedule 2 Section 14 of NSR19 and I have raised a Level 4 Regulatory Issue to monitor progress against this compliance shortfall.
I identified a minor shortfall relating to Sellafield Ltd legacy source documentation for items of QNM within QS04 not being readily retrievable. This represents a shortfall against MACE 8.3 of ONR's regulatory expectations as outlined in ONMACS. I have raised a Level 4 Regulatory Issue for Sellafield Ltd to conduct an extent of condition review on legacy source documentation for items of QNM.
I provided two pieces of regulatory advice to Sellafield Ltd; one regarding actions to effectively address the awareness of Accountancy and Control Plans for key plant personnel who are responsible for implementing the accountancy and control of QNM on-plant, and another to consider formally capturing key steps performed ahead of producing the PIL and MBR for QS04 in existing local arrangements.
I made one safeguards observation relating to good practice in Sellafield Ltd’s provision of source documentation for the pre-determined accountancy sample in advance of the inspection, which was welcomed and allowed ONR to examine the evidence ahead of the intervention. I recommended that where practical, Sellafield Ltd supply appropriate operating records ahead of future inspections.
Conclusion
I did not identify any significant shortfalls in compliance against NSR19 during this intervention.
In line with the ONR Inspection Rating Guide, based on the sampled evidence during the course of the intervention at Sellafield Ltd QS04, I consider a rating of GREEN against NSR 19 regulations 6(1-4), 9(1), 10(1), 11(1-4), 15(3), 20, Schedule 2 and ONMACSs FSEs 3, 7, 8, 9 and 10.
I have raised two regulatory issues to address minor shortfalls found.