Executive summary
Date(s) of inspection:
February 2023
Aim of inspection
I conducted an ACP and PITe compliance inspection of Urenco ChemPlants (UCP). The aim of this inspection was to seek evidence in support of Urenco’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
The purpose of an ACP inspection is to seek regulatory confidence that the operator’s ACP adequately describe the arrangements and procedures adopted to establish and maintain the system of accountancy and control of qualifying nuclear material within the facility and that the arrangements and procedures described within said ACP are implemented and complied with.
The purpose of a PITe inspection is to seek regulatory confidence of the adequacy and implementation of the arrangements made by the operator for conducting a PIT in order to gain regulatory confidence of the accuracy of the operator’s physical inventory.
Subject(s) of inspection
- 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: Not Rated
- NSR19 Reg10 - Operating records - Rating: GREEN
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This inspection focused on substantiating claims, arguments and evidence presented in the UCP ACP document with a specific target on the arrangements for the PIT. This was achieved by reviewing the appropriate section with the operator ACP, a sample of operating instructions and arrangements followed by a plant walk-down and discussion with staff with operational implementation responsibilities within targeted facilities.
Based on the inspection activities and evidence sampled I consider that Urenco are implementing arrangements for the PIT in a manner which is proportionate to and appropriate for the qualifying nuclear facility in line with NSR19 Regulations 6(3), 10 (1) 15 (3), Schedule 2. I also judge that URENCO ChemPlants Ltd are broadly meeting the expectations for Data Processing and Control detailed in FSE 8 and Material Balance in FSE 9 of ONMACS.
I observed that the UCP ACP does not contain an adequate description of the PIT nor adequately reference operating instructions and arrangements however there is an extant minor Regulatory Issue currently being undertaken by the operator with an action to update the ACP as a whole to address this issue. Based on this evidence I did not make a judgement in respect to implementation of the ACP as detailed in Regulation 9 of NSR19
Conclusion
No matters requiring immediate regulatory attention were identified during this inspection.
Overall, on the basis of the evidence sampled at the time of the inspection, I am satisfied that URENCO has demonstrated that it is appropriately implementing arrangements for undertaking a PIT at UNS QBCX in line with Regulations 6(3),10(1),15 (3) and Schedule 2 of NSR19. I also judge that URENCO ChemPlants Ltd are broadly meeting the expectations for Data Processing and Control detailed in FSE 8 and Material Balance in FSE 9 of ONMACS.
During the inspection I observed that the UCP ACP does not contain appropriate signposting to underpinning supporting evidence to fulfil ONR’s regulatory expectations. Based on this evidence I did not make a judgement in respect to implementation of the ACP as detailed in Regulation 9 of NSR19. The shortfall in the ACP will be captured in the extant Level 4 Regulatory Issue RI-11198 being undertaken by the operator with an action to update the ACP as a whole to address this issue.
I therefore consider, noting ONR guidance on inspection ratings, an inspection rating of GREEN (no formal enforcement) is appropriate.