Executive summary
Date(s) of inspection:
July 2023Aim of inspection
ONR nuclear safeguards inspectors conducted a nuclear material accountancy focused compliance inspection of the Material Balance Area QBS3 - "A633 Enriched Uranium Residues Recovery Plant (EURRP), A685 Hex Cylinder Wash Plant, A26 & A676 Decontamination Facilities" on the 05 July 2023.
The purpose of this inspection was to seek evidence in support of Springfields Fuels Limited’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance of Springfields Fuels Limited’s compliance against 6(1-4), 9, 10(1), 11(1-4), 12(1-2) and 14 in NSR19.
To form effective regulatory judgements on Springfields Fuels Limited’s compliance with the NSR19 regulations listed above, inspectors considered the ONR guidance for the assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) and the expectations within. There was a particular focus on FSEs 3, 6, 7, 8 and 10.
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 3 Competence Management - 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
- 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 Reg12 - Accounting reports - Rating: GREEN
- NSR19 Reg14 - Inventory change report - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This inspection comprised of discussions with Springfields Fuels Ltd personnel, sampling of documentation, implementation of arrangements and a plant walk down.
I identified no shortfalls in the information described in the Accountancy and Control Plan (ACP) and other relevant arrangements for the Material Balance Area (MBA) QBS3 - Enriched Uranium Residues Recovery Plant (EURRP) and hex cylinder wash plant and decontamination facilities. I observed appropriate implementation of these arrangements on site. I made three observations related to inaccurate or inappropriate references in the written arrangement (ACP and BTC).
Based on the evidence sampled, I judged that Springfields Fuels Ltd is implementing adequate arrangements to collect, record and process accountancy data including operating and accounting records and integration with site-wide data processing systems for generating the accountancy reports, in line with ONR Fundamental Safeguards Expectations (FSE) 6, 7, 8, 10 and 3.
Based on the plant walk down and discussions I held with the key staff on plant and within the safeguards team, I judge that Springfields Fuels Ltd is implementing the arrangements described in their ACP as required by Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) regulation 9 and that the implementation of these arrangements is supporting the accountancy and control of qualifying nuclear material within the MBA QBS3 as required by regulation 6 of NSR19.
I was satisfied that the documentation reviewed, the records sampled, and evidence collected were adequate; therefore, I judge Springfields Fuels Ltd to be compliant against NSR19 regulations 6 (1-4), 9, 10 (1), 11 (1-4), 12 (1-2) and 14.
Conclusion
Overall, I did not identify any shortfalls against NSR19, or fundamental safeguards expectations as described by the ONMACS. On the basis of the evidence sampled at the time of the inspection, I am satisfied that Springfields Fuels Ltd has demonstrated that their arrangements sampled are fit for purpose and being implemented in a proportionate and appropriate manner.
FSE 6
Based on the arrangements and the evidence I sampled as part of this intervention, I am satisfied that Springfields Fuels Ltd has appropriately implemented its arrangements for measurement programme and control, and meet my expectations as described by FSE 6 and therefore award a rating of GREEN – no formal action.
FSE 7
Based on the arrangements and the evidence sampled as part of this intervention and using regulatory intelligence, I am satisfied that Springfields Fuels Ltd has adequate arrangements for the identification, quantification, tracking of the QNM in the facilities, and that these arrangements are appropriately implemented.
I am satisfied that Springfields Fuels Ltd. is meeting ONR’s regulatory expectations outlined in FSE 7 and therefore award a rating of GREEN – no formal action.
FSE 8 & 10
Based on the sampling undertaken, I judge that the Springfields Fuels Ltd’s NUMIS accountancy system is fit for purpose and meets the functional requirements associated with data processing and control and that the system is implemented, and delivers NMACS function, in-line with the claims made within Springfields Fuels Ltd’s ACP and arrangements.
I also judge that from the evidence sampled Springfields Fuels Ltd's NMACS fulfils ONR’s regulatory expectations outlined in FSE 8 and FSE 10 and therefore award a rating of GREEN – no formal action.
FSE 3
Based on the arrangements and the evidence I sampled as part of this intervention and using regulatory intelligence, I am satisfied that Springfields Fuels Ltd has appropriately implemented its arrangements for competence management of personnel with responsibilities in NMACS and meet my expectations as described by FSE 3 and therefore award a rating of GREEN – no formal action.