The purpose of the inspection was to:
On 11 August 2016 ONR was informed that analysis undertaken in the High Level Area at the Magnox Harwell LETP was suggesting that there was potentially more ILW in the Heels waste project material than originally estimated. Consequently additional analysis samples are being taken in order to develop the detailed fingerprint of the Heels material.
As a result it now seems unlikely that Magnox Harwell will be ready to consign the Heels material until after the end of the calendar year.
Magnox Harwell believes that although the Heels inventory is likely to change and result in an increased A2 value, it will still remain well within the safety margin justified by the DN3391/A on-site transport safety case. They also believe their safety arguments and all of the proposed Compensatory Measures, as submitted in the Special Arrangement application would remain valid. Consequently ONR judged that it remained worthwhile to continue with the inspection as arranged.
The inspection included a 'walk round' the proposed route to be taken by the package under the Special Arrangement, interviews with staff and documentary review.
The Special Arrangement Compensatory Measures were found immature / not in place and consequently considered inadequate.
The Special Arrangement Compensatory Measures for the Heels material were not available for inspection. Therefore Magnox Harwell will need to demonstrate to ONR that the arrangements developed and implemented to satisfy the Special Arrangement Compensatory Measures are adequate before approval for the application can be given.
Based on the training arrangements for the CHILW TC-19 (IP-2) drum and overpack, it is the opinion of the Inspector that Magnox Harwell is able to implement sufficient and adequate training for the operators who will be using a TC-19(IP-2) drum and overpack for the Heels move.
Subject to satisfactory implementation of the remedial actions outlined in ONR letter ONR-COP-TRA-16-199, it is the opinion of the Inspector that Magnox Harwell's Management System is adequate (with regard to compliance with CDG09) for the development of a document suite to control the Special Arrangement movement of LETP Heels.
It is the opinion of the Inspector that the processes and controls employed in package maintenance are adequate based on documentary evidence of previous maintenance activities.
Magnox have emergency arrangements in place for the transportation of radioactive material between facilities at Magnox Harwell. The Heels material is contained in HLA TC-19 (IP-2) rated drums for which Magnox Harwell have specific emergency instructions.
The proposed additional security arrangements planned for the Special Arrangement are considered adequate by the nominated site Security Inspector. However the finalised security arrangements will need to be inspected by ONR.
Magnox Harwell will submit an update to its Special Arrangement application once it has refined the Heels material fingerprint information. Following this, ONR will conduct a readiness inspection of the compensatory safety measures prior to issue of any approval for the Special Arrangement shipment.