Executive summary
Date(s) of inspection: February 2025
Aim of inspection
The purpose of the NSR19 Compliance Inspection at the Centre for Radiation, Chemicals and Environmental Hazards, UKHSA (Chiltern) 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 operator 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 half day, ONR Compliance Inspection of UKHSA Radiation Chemical and Environmental Hazards Directorate at Chiltern (QNRC), reviewing the arrangements and implementation of the Nuclear Material Accountancy & Safeguards (NMACS).
The purpose of this inspection was to inform ONR’s judgement regarding the adequacy of QNRC 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 planned inspection was undertaken in accordance with the Office for Nuclear Regulation (ONR) Safeguards subdivision operational schedule for 2024/2025, 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 QNRC, I found: -
The correct BTC template has been used and contains an adequate level of detail. I provided regulatory advice on a couple of areas which could be improved:-
- Section 6 – description of containers, does not actually describe the containers used. This would benefit from a review and update.
- Section 10 – would benefit from having a signpost to PIT procedures, and month that QNRC’s PIT is expected to be undertaken.
The ACP and implementation of NMACS is adequate, however some improvements can be made to the ACP, for which I offered the following regulatory advice: -
- ACP could be further improved by adding an organogram or other description to define the relationship of roles.
- Reference Nuclear Safeguards Regulations (EU Exit) Regulations 2019 (NSR19) where appropriate i.e. when describing nuclear material accountancy in the Topic Safety Adviser section.
- A link to the INF1 process Notify ONR | Office for Nuclear Regulation would be beneficial in the Source Holder section and/or FSE4 – ‘Reporting anomalies and investigations’, and signposting in the ACP to appropriate management processes etc, pertaining to controlling and accounting for qualifying nuclear material (QNM) .
- General signposting to appropriate documents and management procedures which would make the ACP a useful tool and would ensure resilience on NMACS related roles.
I compared the NMACS arrangements and implementation against ONR’s regulatory expectations. Based on the findings, I judge that the UKHSA Radiation Chemical and Environmental Hazards Directorate at Chilton (QNRC) NMACS does adequately comply with NSR19’s statutory requirements and does adequately meet ONR’s Safeguards regulatory expectations for NSR19 regulations 6, 7, 8, 9, 10, 11 and 31(5).
Noting ONR’s inspection rating guidance I judge that a rating of GREEN is appropriate for this review.
Conclusion
This report presents the findings of the ONR Inspection of UKHSA Radiation Chemical and Environmental Hazards (RCE) Directorate (QNRC), which reviewed their NMACS arrangements and implementation.
I compared the details of the NMACS arrangements included in the BTC and ACP and supporting documents against ONR’s Safeguards regulatory expectations. Based on the findings during this inspection, I judge the UKHSA Radiation Chemical and Environmental Hazards Directorate NMACS does adequately signpost, underpin, and explain how NMACS is being implemented at the site. Therefore, the NMACS does meet my expectations as described by the Safeguards TIG & TAG and the ACP document and arrangements does meet my expectations as described by the ONMACS FSE as appropriate for QNFLO.
Overall I judge that QNRC does fulfil the reporting requirements of NSR19 Regulation 31(5), and does meet all the regulatory requirements of NSR19 Regulations 3, 6, 7, 8, 9, 10 and 11. I judge that QNRC can improve their current documentation by following the recommendations made throughout this assessment, which can be made as the next revision.
Noting ONR’s inspection rating guidance I judge that a rating of GREEN is merited for this assessment.