Executive summary
Date(s) of inspection:
May 2025
Aim of inspection
The purpose of the NSR19 Compliance Inspection at Clarity NDT Limited was to provide assurance to ONR that the operator’s accountancy arrangements are appropriate and proportionate for the qualifying nuclear facility and that they are adequately implemented for nuclear material accountancy and control of Qualifying Nuclear Material (QNM). This includes maintaining adequate operating records and accounting records, which are traceable to the accounting reports provided to the ONR and are underpinned by suitable accountancy arrangements.
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: GREEN
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 2 Organisational Culture - Rating: GREEN
- FSE 3 Competence Management - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - Rating: GREEN
- FSE 5 Reliability, Resilience and Sustainability - 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 Reg03 - Declaration of basic technical characteristics - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg08 - Replacement, amendment and revocation of accountancy and control plan - 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 Reg31 - Declaration of basic technical characteristics, stock list and accounting records for qualifying nu - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This report presents the findings of the ONR Compliance Inspection at Clarity NDT Limited (QCNL) reviewing the arrangements and implementation of the Nuclear Material Accountancy & Safeguards (NMACS).
The purpose of this planned inspection was to inform ONR’s judgement regarding the adequacy of QCNL NMACS arrangements and implementation to demonstrate compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), Regulations 3, 6, 7, 8, 9, 10, 11 and 31(5). This inspection was undertaken in accordance with the Office for Nuclear Regulation (ONR) Safeguards subdivision operational schedule for 2025/2026, based on regulatory intelligence, related to the clarity of references made within the Basic Technical Characteristics (BTC) and Accountancy and Control Plan (ACP) and the ONR integrated inspection strategy for Qualifying Nuclear Facilities with Limited Operation (QNFLO) which details the regulatory risk from the qualifying nuclear material (QNM) holdings along with previous NSR19 compliance level.
To inform my judgements on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance (TAG), the Safeguards Technical Inspection Guidance (TIG) and our safeguards expectations proportionate to a QNFLO, based on the ONR guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
QCNL provides non-destructive testing (NDT) services including undertaking industrial radiography utilising remote control gamma source projectors. The gamma source projectors and related source exchange containers utilise depleted uranium DU as shielding from the gamma ionising radiations emissions relating to the high activity sealed sources (HASS) they contain.
On reviewing the arrangements and implementation of NMACS at QCNL, I found: -
- The BTC is presented on the correct Annex I-H template with no issues raised.
- In my opinion, the implementation of NMACS is adequate at QCNL.
- QCNL have good practices but they are not specifically claimed within the ACP. Standard Operating Procedures (SOP’s) make up the company’s main quality system. The company see the ACP being signposted from the SOP, not the other way round. I explained that if there is a fundamental change to the BTC, which is relevant to the accountancy and control plan, the operator must amend the ACP and send the amended plan to the ONR within the period of 30 days beginning with the day on which the change is made. QCNL then suggested having the ACP as an Annex within the SOP. In my opinion, this would work, as it would be a separate entity and simple to submit to ONR if a reportable change occurred. QCNL had also proactively undertaken a review and updated their BTC and ACP prior to my visit.
I compared the NMACS arrangements and implementation against ONR’s regulatory expectations. Based on the findings, I judge that Clarity NDT Limited (QCNL) does adequately comply with NSR19’s statutory requirements, and does adequately meet ONR’s Safeguards regulatory expectations for NSR19 Regulations 3 and 7(4).
Noting ONR’s inspection rating guidance, I judge that an overall rating of GREEN is appropriate for this review.
Conclusion
This report presents the findings of the ONR Inspection of QCNL, which reviewed their NMACS arrangements and implementation.
I have identified regulatory advice against Regulation 7(4).
I was satisfied with QCNL management and control of NMACS expectations, I have judged that, overall a rating of GREEN is merited for this intervention.