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Amentum Clean Energy UK Limited (MCLR) - Inspection ID: 53462

Executive summary

Date(s) of inspection: 

April 2025

Aim of inspection

The purpose of the NSR19 Compliance Inspection at Jacobs Clean Energy Ltd 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 operating 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: AMBER
  • NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
  • NSR19 Reg07 - Accountancy and control plan - Rating: AMBER
  • 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 Amentum Clean Energy (QSER), 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 QSER 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 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 QSER, I found: -

 

  • The BTC is not presented on the correct Annex I-H template. The information submitted should reflect all headings as set out in the Annex I-H format, with each question being answered against the wording of the heading. For example, Section 4 – Operator: (legally responsible body or individual). This is usually the legal owner as specified on Companies House. I judge the BTC to be inadequate under NSR19, Regulation 3. The BTC requires a full review and update.

 

  • In my opinion, the implementation of NMACS is adequate and lessons learnt are taken seriously. However the ACP is inadequate under NSR19 Regulation 7(4) and requires a full review and update to address minor shortfalls such as - page 1 references Reg 31 but no reference to Nuclear Safeguards Regulations (EU Exit) Regulations 2019 (NSR19), page 3 – incorrect quoting of regulations – ‘Production of an ACP’ is under Reg 6, this is, in fact, Reg 7. Section 4.2 states there is a requirement for annual submission of Programme of Activities (this is not required for NSR19 Reg 31 reduced reporters). NMACS implementation can be supported by signposting more of the existing processes and procedures such as ‘The Safeguards Regulators Training Course, pertaining to controlling and accounting for qualifying nuclear material (QNM).

 

I compared the NMACS arrangements and implementation against ONR’s regulatory expectations. Based on the findings, I judge that Amentum Clean Energy (QSER) does not adequately comply with NSR19’s statutory requirements, and does not adequately meet ONR’s Safeguards regulatory expectations for NSR19 Regulations 3 and 7(4).

 

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 shortfalls identified.

Conclusion

This report presents the findings of the ONR Inspection of QSER 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.

 

In practice I was satisfied with QSER management and control of NMACS expectations, I have judged that, overall a rating of GREEN is merited for this intervention.