Executive summary
Date(s) of inspection: October 2024
Aim of inspection
ONR nuclear safeguards inspectors and a specialist inspector (leadership and management) conducted a safeguards compliance inspection at Springfields Fuels Ltd, on 31 October and 01 November 2024. The purpose of this inspection was to seek evidence in support of Springfields Fuels Ltd.’s compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR forms regulatory judgements and provides a rating in line with ONR’s inspection rating guidance of Springfields Fuels Ltd.’s compliance against the following regulations in NSR19:
- Regulation 7 – Accountancy and control plan
- Regulation 9 – Operation of an accountancy and control plan
To form effective regulatory judgements on Springfields Fuels Ltd.’s compliance with the NSR19 regulations listed above, where relevant to inspection activities, ONR considers 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 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg09 - Operation of an accountancy and control plan - 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 and competence management.
We sought evidence of adequate arrangements and their implementation through discussions with Springfields Fuels Ltd. staff, a review of records and documentation relevant to
FSE 1 and FSE 3, 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 (TIG) for Safeguards [SG-INSP-GD-001, issue 4].
Based on the inspection activities sampled, we judged that Springfields Fuels Ltd. was maintaining an appropriate system of accountancy and control of qualifying nuclear material, in compliance with the requirements under regulations 7 and 9 of NSR19 and was adequately implementing those arrangements in line with our regulatory expectations detailed in FSE 1 (in particular MACE 1.2) and FSE 3 of ONMACS, we judged that the inspection is rated GREEN.
We provided regulatory advice in relation to the evaluation of internal safeguards training, observed good practices and minor observations which were identified during the inspection. These were fed back to Springfields Fuels Ltd at the end of the inspection, who accepted the regulatory advice.
Conclusion
Based on the sample inspected during the intervention, we judged that Springfields Fuels Ltd. was implementing their arrangements for leadership and management of NMACS and competence management in line with the regulatory expectations, in particular FSE 1 and 3, and was compliant with NSR19 regulations 7 and 9.
We identified no shortfalls, we provided regulatory advice in relation to the evaluation of internal safeguards trainings, we highlighted observations made during the inspection.
Upon consideration of the ONR guidance on inspection ratings, we judged that a rating of green(no formal action) was appropriate.