Executive summary
Date(s) of inspection:
August 2025
Aim of inspection
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 Institute of Cancer Research (QICR), 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 QICR 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).
On reviewing the arrangements and implementation of NMACS at QICR, I found: -
The BTC is presented on the correct Annex I-H template. However there are several minor shortfalls for which I have provided regulatory advice, such as: -
The information submitted should fully reflect all headings as set out in NSR19 Annex I-H format i.e.: -
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Section 2 - refers to a past contact. I suggest a generic email and contact, which also provides resilience.
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Section 5 – Type of Qualifying Nuclear Material states – D, T and N are present. QICR only have uranyl acetate and are not likely to purchase any more QNM in the near future. I suggest revising the BTC to reflect reality and align with I-H requirements.
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Section 10 - Has minimal information. I suggest signposting appropriate procedures which specify how QICR conduct their PIT as well as how they account and control for their QNM.
In my opinion, the implementation of NMACS is adequate and lessons learnt are taken seriously. The ACP is broadly compliant with NSR19 Regulation 7(4) with minor shortfalls, as identified below:-
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FSE1 – states a contact which is no longer relevant;
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FSE3 - states a ‘competency, awareness and training procedure’ is present, when it is not.
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FSE 4 signposts Regulation 23 - this is not relevant to QNFLO and may be removed from the ACP.
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FSE8 states the submission date for annual reports is 28 February as QICR had requested in writing a later submission date. This date can be changed to 15 March to align with reporting requirements granted under Reg 31 approval.
I compared the NMACS arrangements and implementation against ONR’s regulatory expectations. Based on the findings, I judge that the Institute of Cancer Research (QICR) is broadly compliant with NSR19 Regulations 3 and 7(4) and suggest a review and update of BTC and ACP, considering my suggestions to expand the documents to fully align with the NSR Regulations.
Noting ONR’s inspection rating guidance, I judge that an overall rating of GREEN is appropriate for this review and I will raise a L4 Regulatory Issue to monitor progress against the minor shortfalls identified.
Conclusion
This report presents the findings of the ONR Inspection of QICR which reviewed their NMACS arrangements and implementation.
I have identified observations, minor shortfalls and regulatory advice against Regulations 3 and 7(4), I will raise a L4 Regulatory Issue to monitor progress against the Findings identified.
I judge QICR to be broadly compliant with NSR19 Regulation 7 and suggest a full review and update of their ACP, considering my suggestions to fully align with Regulation 7(4). I will raise a L4 Regulatory Issue to monitor progress against these minor shortfalls.
I have judged that, overall a rating of GREEN is merited for this intervention.