The purpose of the inspection was to:
The inspection was conducted through a visit to the Berkeley site, interviews with staff and documentary review.
The inspection was conducted against the requirements of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 SI 2009:1348 (CDG 09), a relevant statutory provision of the Energy Act 2013, and one which requires carriage by road to be in accordance with the appropriate edition of a European Agreement known as ADR. The current edition is ADR 2015. In particular, although not exclusively, the inspection considered arrangements in respect of ADR 1.7.3 – Management System, ADR 1.3 - Training, ADR 1.8.3 - Safety Advisor, and CDG 09 Regulation 24 – Radiological Emergencies. In addition International Atomic Energy Agency (IAEA) Guidance SSG-26 on the interpretation of classification of material as LSA II was discussed at the request of site.
N/A – not a System/Structure Based Inspection.
The inspection concluded that the current arrangements of Berkeley concerning the safe carriage of radioactive material arising from decommissioning continue to be adequate.
One finding was made which Berkeley will consider further in relation to the integration of the consignor’s emergency arrangements with the carrier’s, the development of these arrangements and how rehearsals or exercises test these arrangements.
The interpretation of IAEA guidance in relation to the ADR requirement for activity in LSA II to be “distributed throughout” the material was discussed in relation to the assay of material from Vault 2 as it is processed for packaging in IP2 packages, prior to storage in the Intermediate Level Waste (ILW) store on site and eventual transport to and disposal in the Geological Disposal Facility (at a site yet to be determined). ONR will consider Berkeley proposals for analysis and sorting of the material from Vault 2 in relation to its potential classifications as LSAII material and respond to the site in due course.
The inspectors were satisfied that the issues observed in relation to current arrangements for carriage of Class 7 material did not present a significant risk to workers or the public, and the site management committed to review the inspection findings and implement appropriate corrective action. Consequently, no formal regulatory action was considered necessary on this occasion.
The inspection found current arrangements for packaging and consignment of Class 7 material (low specific activity and surface contaminated objects in industrial and excepted packages) to be adequate for the purposes of ADR, and in compliance with the requirements of CDG09.