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 an accountancy focussed inspection is to:
- examine operating and accounting records to establish a correct set of data and to provide confidence to ONR that the operator has an adequate nuclear material accountancy and control system established
- examine the specific arrangements and procedures in place for nuclear material accountancy
as detailed in Section 5 of the ONR Safeguards Technical Inspection Guide SG-INSP-GD-001 Revision 3
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - 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
- NSR19 Reg20 - Weight units and categories of qualifying nuclear materials - Rating: GREEN
- NSR19 Reg29 - Stock list and accounting records for conditioned and retained waste - 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 2023/24 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 nuclear material accountancy. For this intervention the Material Balance Areas (MBA) known as QS09 and QS14 were selected, specifically, the Pile Fuel Storage Pond (PFSP) in QS09 and the Wastes Encapsulation Plant (WEP) and Encapsulated Product Store (EPS) in QS14. The intervention was planned as an accountancy focussed inspection on the export of pond-floor debris from PFSP for encapsulation in QS14.
This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 9, 10, 11, 12, 14, 20 and 29 and NSR19 Schedule 2.
Interventions carried out by ONR
I carried out an accountancy-focussed compliance inspection, focussing on the MBAs QS09 and QS14 (PFSP, WEP and EPS) 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 nuclear material accountancy and their implementation.
In particular, this included the methodology by which the miscellaneous debris material collected from the floor of the pond is collected and the qualifying nuclear material content estimated before it is exported to WEP for grouting and storage in EPS. The inspection also targeted whether the accountancy arrangements for this activity 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 and 29(1)(e) and Schedule 2 was identified during this intervention, related to the accurate accountancy of qualifying nuclear material content of grouted containers in final storage in EPS, held on Sellafield’s retained waste inventory.
I raised one regulatory issue to address Sellafield’s accountancy arrangements for PFSP debris material processed through WEP for storage in EPS.
Based on the sample I inspected, I judge Sellafield Limited has adequately implemented their accountancy arrangements for transfers of QNM from PFPS to WEP. I also judge that these records were appropriate, traceable to, and adequately underpin the inventory change reports submitted to ONR in line with NSR19 Regulation 14.
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 provided one piece of regulatory advice relating to measurement basis codes used on inventory change reports for shipments of material from the pond floor to WEP. Sellafield noted the incorrect code was being used for these shipments and had raised a condition report during the intervention to investigate the route cause.
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, 12, 14 20 and 29.
Conclusion of intervention
Based on the sample inspected during the intervention, I judge that Sellafield Limited are implementing their arrangements for accountancy of material transfers from QS09 to QS14 in line with regulatory expectations and are compliant with NSR19 Regulations 6, 9, 10, 11, 12, 14, 20 and 29. I identified one minor shortfall in relation to Sellafield’s accountancy of material following grouting at WEP. I raised a Level 4 regulatory issue to track Sellafield’s progress towards addressing this shortfall.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.
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 and are compliant with NSR19 Regulations 6, 9, 10, 11, 12, 14, 20, 29 and Schedule 2.
I will be raising one level 4 regulatory issue. This issue pertains to accountancy of debris material exported from PFSP to WEP for processing. Sellafield currently do not utilise more accurate measurements for QNM inventory within the debris following grouting in WEP, resulting in significant discrepancies in the waste inventory in EPS and the the QNM inventories reported in statutory reporting. This issue will track Sellafield's progress in their investigations into the issue and any appropriate updates to their arrangements for this material.