Executive summary
Date(s) of inspection:
February 2025
Aim of inspection
ONR nuclear safeguards inspectors will conduct an accountancy focussed compliance inspection of the Sellafield Product and Residue Store (SPRS) and SPRS Buffer Store, material balance areas (MBA) QS37 and QS39 on the 11 - 13 February 2025. The purpose of this inspection is to seek evidence in support of Sellafield Ltd.’s compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
These MBAs have been targeted for the following reasons:
- SPRS is in the process of becoming designated by the IAEA. This inspection will enable ONR to have confidence in the declared inventory currently in the store (which is to be placed under IAEA safeguards measures when the store becomes designated by the IAEA)
- Regulatory intelligence gathered from routine assessment of accountancy reporting under NSR19 Regulation 12(1-2) and 14 has indicated an increase in movements of qualifying nuclear material (QNM) within the store in the previous material balance period (MBP) 13 October 2023 to 10 October 2024
Subject(s) of inspection
- 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
Key findings, inspector's opinions and reasons for judgement made
This intervention sought evidence that the declared accountancy reports in the 2023-2024 material balance period (MBP) for the Sellafield Product and Residue Store (SRPS) [MBA QS37] and SPRS buffer and transit area [QS39] are tracible and accurate to underpinning operating and accounting records ahead of designation for the application of IAEA safeguards. ONR sought evidence that arrangements for Nuclear Material Accountancy and Control for Safeguards (NMACS) described in the Basic Technical Characteristics (BTC) [BTC QS37 – Issue 4 – 10/21 and BTC QS39 – Issue 4 – 10/21] and Accountancy and Control Plan (ACP) [NMAS/ACP/SITE – issue 1 – 01/2021 and NMAS/ACP/Annex_QS37/QS39 – Issue 2 – 03/2022] were appropriate and being adequately implemented by those with NMACS responsibilities for the MBAs, and evidence of quality assurance and quality control for NMACS.
To inform my judgements on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance (TAG) [SG-TAST-GD-001 – Issue 4], the Safeguards Technical Inspection Guidance (TIG) [SG-INSP-GD-001 – Issue 4] and safeguards expectations as described in the ONR guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS) [ONR-SAF-FW-001 – Issue 5].
I held discussions with Sellafield Ltd staff with responsibilities for NMACS, reviewed relevant operating and local instructions, and conducted an in-depth verification of source documentation used to for NMACS which underpinned the accountancy reports declared by Sellafield Ltd. I noted a minor shortfall against NSR19 Regulation 3, as the BTC’s for both QS37 and QS39 contain incorrect information relating to accountancy systems and the flow of NMAC’s data within the document appendices. I have raised a Level 4 Regulatory Issue [RI-12436] for Sellafield Ltd to address the shortfall.
Based on the sampled evidence during the course of the intervention at SPRS (QS37) and SPRS Buffer and Transit Area (QS39), I judge that there were no significant shortfalls identified during this intervention. Sellafield Ltd are adequately implementing its arrangements in line with regulatory expectations FSE 7, 8 and 10, and maintaining an appropriate system of accountancy and control for qualifying nuclear material in accordance with NSR19 Regulations 6, 9, 10, 11, 12 and 14. I rated this intervention GREEN.
Conclusion
During this intervention, I noted a minor shortfall against NSR19 Regulation 3, as the BTC’s for both QS37 and QS39 contain incorrect information relating to accountancy systems and the flow of NMAC’s data within the document appendices. I have raised a Level 4 Regulatory Issue [RI-12436] for Sellafield Ltd to address the shortfall.
Level 4 Regulatory Issue [RI-12436]: The BTC’s for QS37 and QS39 contain out of date information relating accountancy systems and the flow of NMACS data with the document appendices. I judge this to be a minor shortfall against NSR19 Regulation 3. Sellafield Ltd should perform an extent of condition for the BTC’s within the SNM area and produce and implement a plan to bring the impacted documents up to date.
Based on the sampled evidence, I judge that there were no significant shortfalls identified during this intervention. Sellafield Ltd are adequately implementing its arrangements in line with regulatory expectations FSE 7, 8 and 10, and maintaining an appropriate system of accountancy and control for qualifying nuclear material in accordance with NSR19 Regulations 6, 9, 10, 11, 12 and 14. I rated this intervention GREEN: