Executive summary
Date(s) of inspection:
- September 2022
Aim of inspection
The purpose of this inspection was to seek evidence in support of Springfields Fuels Limited’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), specifically evidence that SFL had appropriate Physical Inventory Take (PIT) arrangements in place and that they were adequately implemented.
Specifically, ONR will assessed compliance with the following regulations of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19):
Specifically, ONR will assessed compliance with the following regulations of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19):
- Regulation 6 - Accountancy and control of qualifying nuclear material (Inc schedule 2, specifically parts 2, 7, 13, 14 and 15)
- Regulation 9 - Operation of an accountancy and control plan
- Regulation 10 - Operating records
- Regulation 11 - Accounting records
Subject(s) of inspection
- FSE 3 Competence Management - Rating: Green
- FSE 7 Nuclear Material Tracking - Rating: Green
- FSE 9 Material Balance - Rating: Green
- 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
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Safeguards’ operational schedule 2022-2023 (CM9: 2022/2873), ONR Safeguards is required to undertake a number of safeguards compliance inspections at the Springfields Fuels Limited Site (SFL). An inspection was undertaken to assess Springfields Fuels Limited's compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to evaluating the implementation of arrangements and procedures in relation to performing a Physical Inventory Take (PIT) and internal Physical Inventory verification (PIV) at MBA QBS3 - Enriched Uranium Residues Recovery Plant (EURRP), hex cylinder wash plant. decontamination facilities.
The inspection comprised of discussions with Springfields Fuels Limited's staff, sampling and review of their arrangements, accounting records and other source documentation. This also included plant walkdowns and observing Springfields Fuels Limited's staff undertaking the internal PIV. This was carried out in line with ONR's guidance which can be found on ONR’s website (onr.org.uk).
Based on the sampled evidence I judge Springfields Fuels Limited is implementing appropriate and proportionate arrangements for the undertaking of a PIT at an overall corporate site level. I am not satisfied that Springfields Fuels Limited is implementing the appropriate and proportionate arrangements for undertaking a PIT at MBA QBS3 level and also for the production of the accountancy reports. I consider this to represent a shortfall against have raised a level 4 Regulatory Issue to seek improvement and monitor progress against this compliance shortfall.
Conclusion
- In line with the ONR Inspection Rating Guide, based on the sampled evidence during the course of the intervention at Springfields Fuels Ltd, I consider a rating of GREEN against the following as identified within the scope of inspection:
QBS3 Enriched Uranium Residues Recovery Plant (EURRP), hex cylinder wash plant decontamination facilities - NSR19 Regulations 6, 9 (1), 10 (1), 11 (1-4), 15, 20, schedule 2 and ONMACS FSEs 3, 6, 7, 8, 9
I identified a number of shortfalls which have been raised as Level 4 Regulatory issues and also raised two pieces of regulatory advice.