Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
ONR will seek to draw an independent and informed regulatory judgement that the nuclear material accountancy and control arrangements within the MBA QBS1 & QBS0 have an adequate level of quality assurance control arrangements.
This will include seeking evidence that multiple batch IDs can be followed through from origin to generation of the Inventory Change Report (ICR), with an adequate level of QA/QC arrangements both on plant and within the SFL NMA team under regulation 6.
The material flow from QBS0 to QBS1 provides a logical route across two MBAs. This will include multiple IC codes across various QA/QC trigger points, and will allow a robust judgement of the operators QA/QC arrangements to be made.
The intervention will also gain assurance that accountancy reports provided for the MBA QBS1 & QBS0 to the ONR under regulation 12 are traceable and accurate to the supporting source documentation. As part of this, inspectors will examine the underpinning operating and accounting records for the accountancy sample (which will be provided in due course) as well as perform physical verification for a sample of qualifying nuclear material.
ONR will conduct a plant walkdown and hold discussions with relevant Springfields Fuels Limited personnel who have nuclear material accountancy and control responsibilities.
ONR requests discussions with relevant staff and provision of relevant NMAC&S arrangements prior to the intervention; see the proposed detailed agenda in annex 1.
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 6 Measurement Programme and Control - Rating: AMBER
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- FSE 8 Data Processing and Control - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: AMBER
- 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
ONR Safeguards conducted a reactive intervention to draw an independent and informed regulatory judgement that the nuclear material accountancy and control arrangements within the MBA QBS1 & QBS0 have an adequate level of quality assurance control arrangements. This included seeking evidence that multiple batch IDs can be followed through from origin to generation of the Inventory Change Report (ICR), with an adequate level of QA/QC arrangements both on plant and within the SFL NMA team under regulation 6.
The intervention also sought to gain assurance that accountancy reports provided for the MBA QBS1 & QBS0 to the ONR under regulation 12 are traceable and accurate to the supporting source documentation. As part of this, inspectors will examine the underpinning operating and accounting records for the accountancy sample (which will be provided in due course) as well as perform physical verification for a sample of qualifying nuclear material.
ONR will conducted a plant walkdown and held discussions with relevant Springfields Fuels Limited personnel who have nuclear material accountancy and control responsibilities - along with holding discussions with relevant staff and provision of relevant NMAC&S arrangements prior to the intervention; see the proposed detailed agenda in annex 1.
Based on the evidence sampled, I judge that Springfields Fuels Ltd are implementing arrangements in line with (FSE) 8, and NSR19 Regulations 6(1-4), 9, 10(1), 11(1-4), 12(1-2) and 14 for accountancy verification. However, I did identify minor shortfalls against the expectations of ONMACS FSE 10 (10.2).
Furthermore, the evidence sampled throughout the inspection demonstrated that the performance measurement systems, procedures and records represent significant shortfalls against the requirements of NSR19 Regulation6(3), Schedule 2 (6)(7) and the expectations of ONMACS FSE 6.1(117).
Conclusion
Based on the evidence sampled, I judge that Springfields Fuels Ltd are implementing arrangements in line with (FSE) 8, and NSR19 Regulations 6(1-4), 9, 10(1), 11(1-4), 12(1-2) and 14 for accountancy verification. However, I did identify minor shortfalls against the expectations of ONMACS FSE 10 (10.2).
Furthermore, that the evidence sampled throughout the inspection demonstrated that the performance measurement systems, procedures and records represent significant shortfalls against the requirements of NSR19 Regulation6(3), Schedule 2 (6)(7) and the expectations of ONMACS FSE 6.1(117).
In order to track Springfields Fuels Ltd's progress in returning to compliance, I have raised the following Regulatory Issues:
RI-12676 (L3) - Uncontrolled movements of qualifying nuclear material in QBS0 (Storage Areas for Miscellaneous Compounds, Residues & Sources).
RI-12694 (L4) - Absence of peer review checks within monthly ICR generation process at Springfields Fuels Ltd
RI-12693 (L4) - Absence of implementation of daily/weekly checks on portable & accountancy scales in QBS1 (Service Island and Decommissioning Activities)
Upon consideration of the ONR guidance on inspection ratings and application of the EMM, I judge that a rating of amber (seek improvement) is appropriate and an Regulatory Advice will be produced.