Executive summary
Date(s) of inspection:
May 2025
Aim of inspection
The purpose of the NSR19 Compliance Inspection at Linac NDT Services Ltd (QMEM) 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 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 Linac NDT Services LTD (QMEM) 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 QMEM 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).
QMEM provide radiography and NDT across a wide range of industries. They hold 4 containers, two of which house Cobalt 60 sources for industrial radiography. There is one empty container and one emergency container, which is required for example, if a source will not retract, it can be placed into the emergency container until the problem can be resolved. The QNM never leaves site.
On reviewing the arrangements and implementation of NMACS at QMEM, I found: -
- The BTC is presented on the correct Annex I-H template. I offered regulatory advice noting it is beneficial to have a generic telephone number and email address at Section 2 of the BTC. Sections 10 and 11 could benefit from expansion of specific detail to fully address the headings. QMEM are currently updating the latest version of the BTC, which I observed and will submit with updates in January 2026, when the annual reports are produced and submitted to ONR.
- In my opinion, the implementation of NMACS is adequate at QMEM.
- QMEM have good NMACS practices but they are not specifically claimed within the ACP. QMEM are adequately accounting for and controlling their QNM in my opinion. To ensure the ACP captures the detail required by Regulation 7 and provides a useful tool to QMEM I advised certain sections of the ACP could be improved. Detail is provided throughout this report and captured in the observations and regulatory advice section.
I compared the NMACS arrangements and implementation against ONR’s regulatory expectations. Based on the findings, I judge that Linac NDT Services Ltd (QMEM) 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 QMEM, which reviewed their NMACS arrangements and implementation.
I have identified regulatory advice against Regulations 3 and 7(4) of The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
I was satisfied with QMEM management and control of NMACS expectations, I have judged that, overall a rating of GREEN is merited for this intervention.