Executive summary
- Date(s) of inspection: December 2022
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 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
- 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
Purpose of intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2022/23 for Sellafield Limited, ONR Safeguards carries out Safeguards compliance inspections at the Sellafield Limited site. One such intervention was performed to inspect Sellafield Limited’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to performing a physical inventory take of qualifying nuclear material. For this intervention the Material Balance Area (MBA) known as QS09, specifically, the First-Generation Magnox Storage Pond (FGMSP) and Sludge Packaging Plant 1 (SPP1) was selected, and the inspection planned as Physical Inventory Take evaluation (PITe) compliance inspection.
This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 9, 10, 11, 15 and 20 and Schedule 2 using the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within particularly FSE 3, 6, 7, 8 and 9.
Interventions carried out by ONR
I carried out a physical inventory take evaluation (PITe) compliance inspection, focussing on the MBA QS09 (FGMSP and SPP1) at the Sellafield Limited nuclear licensed site. The inspection comprised of discussions with staff, reviews of operating and accounting records, and a plant walkdown within the MBA.
The inspection targeted the operator’s arrangements for a physical inventory take (PIT), and their implementation. In particular, this included the methodology by which an inventory was captured, the operating records produced in relation to the PIT and accounting records created. The inspection also targeted whether the PIT was adequately implemented by demonstrably suitably qualified and experienced personnel (SQEP).
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on ONR’s website (onr.org.uk).
Key findings, inspector's opinions and reasons for judgements made
One minor shortfall in compliance against NSR19 Regulation 6, Schedule 12 part 14 was identified during this intervention and related to the lack of written arrangements in place for undertaking a PIT in the qualifying nuclear facilities. I consider this to be a minor shortfall as I judge an adequate PIT was implemented, despite the lack of written arrangements. Sellafield personnel are aware of this shortfall and arrangements will be produced alongside roll-out of a new inventory database. I will track this activity through quarterly level 4 regulatory interactions.
Based on the sample I inspected, I judge Sellafield Limited has adequately implemented their PIT arrangements in FGMSP and SPP1. I also judge that these records were appropriate, traceable to, and adequately underpin the material balance report and physical inventory listing accountancy reports that will be submitted to ONR in line with NSR19 Regulations 15 and 20.
Based on the plant walkdown and discussions I held with the key staff on plant and within the safeguards team I judge that Sellafield Limited are implementing the arrangements described in their Accountancy and Control Plan (ACP) as required by NSR19 Regulation 9 and that implementation of these arrangements is supporting the accountancy and control of qualifying nuclear material within these MBAs as required in NSR19 Regulation 6.
I was satisfied that the documentation reviewed, records sampled, and evidence collected was adequate and I, therefore, judged Sellafield Limited to be compliant against NSR19 Regulations 6, 9, 10, 11, 15 and 20.
Conclusion
Based on the sample inspected, I judge that Sellafield Limited are implementing their arrangements for accountancy and control of QNM in line with regulatory expectations FSE 3, 6, 7, 8 and 9 and are compliant with NSR19 regulations 6, 9, 10, 11, 15 and 20.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.