Executive summary
Date(s) of inspection: September 2024
Aim of inspection
ONR nuclear safeguards inspectors conducted a compliance inspection targeting the physical inventory taking evaluation of the Material Balance Area QCPL - NRS Chapelcross on the 25-26 September 2024. The purpose of this inspection is to seek evidence in support of NRS Chapelcross’s compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR will form regulatory judgements and provide a rating in line with ONR’s inspection rating guidance of NRS Chapelcross compliance against the following regulations in NSR19.
- Regulation 6: Accountancy and control of qualifying material
- Regulation 9: Operation of an accountancy & control plan
- Regulation 10: (b) (e): Operating records
To form effective regulatory judgements on NRS Chapelcross compliance with the NSR19 regulations listed above, inspectors will consider the ONR guidance for the assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) and the expectations within. There will be a particular focus on:
- FSE 7 – Nuclear material tracking
- FSE 9 – Material balance
Subject(s) of inspection
- FSE 7 Nuclear Material Tracking - 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
Key findings, inspector's opinions and reasons for judgement made
This inspection was targeted as a result of the receipt of qualifying nuclear materials (QNM) within the NRS Chapelcross site. Prior to this, the dutyholder has declared zero inventory in accordance with Safeguards reporting requirements of the Nuclear Safeguards (EU Exit) Regulation 2019 (NSR19).
The inspection sought to collect evidence of the dutyholder's Physical Inventory Taking (PIT) arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 9 and 10. The inspection sampled the PIT verification process of the Chapelcross Processing Plant (CXPP) area which comprised of discussions with staff, review of associated procedures, operating and accounting records.
The inspection was performed in line with relevant ONR guidance, which can be found on ONR’s website (onr.org.uk).
Based on the sample I inspected, I provided two pieces of regulatory advice for the dutyholder to review and update the following documentations:
- The Chapelcross Site Interface document CX-SICD-034 Issue 1, Interface to Nuclear Restoration Services Company Standard S-164 on Nuclear Materials Management to include site specific processes for QNM.
- The Chapelcross Site Record Schedule F-620 Issue 6 to reference the correct NSR19 Regulation.
I raised a minor observation for the dutyholder to review and ensure that the labelling of QNM items are consistent with the list of inventory items.
Overall, I judge from the evidence sampled, that the dutyholder's PIT procedures, accountancy and control of QNM are being implemented in a proportionate manner, in line with their own arrangements, appropriately signposted to the Nuclear Restoration Services Corporate arrangements and are compliant with NSR19 Regulations 6, 9 and 10 and in line with ONR's Safeguards regulatory expectations, FSE 7 Nuclear Material Tracking and FSE9 Material Balance.
Conclusion
Overall, I judge from the evidence sampled, that the dutyholder's PIT procedures, accountancy and control of QNM are being implemented in a proportionate manner, in line with their own arrangements, appropriately signposted to the Nuclear Restoration Services Corporate arrangements and are compliant with NSR19 Regulations 6, 9 and 10 and in line with ONR's Safeguards regulatory expectations, FSE 7 Nuclear Material Tracking and FSE9 Material Balance.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.