ONR Transport inspected Sellafield Ltd (SL), operations in relation to the safe transport of radioactive material. This Compliance inspection was one of a series detailed in the ONR-RMT FY16/17 Transport Inspection Programme and was carried out on the 20th and 21st April 2016. This intervention forms part of a programme of work being undertaken by ONR to gain assurance that the planned Vitrified Residue Returns (VRR) from Sellafield to overseas customers are compliant with National and International requirements as identified in "TIE Transport Strategy for SL VRR Programme August 2015" (Trim 2015/304741).
The purpose of the intervention was:
To confirm the adequacy or otherwise of the organisation's Management System arrangements, and their implementation, relating to the safe transport of radioactive materials.
To inform the ONR COP (Transport Inspection and Enforcement) risk based future regulatory programme.
To improve safety outcomes by assuring, and where necessary, intervening to seek improvements in industry compliance with regulatory requirements, the safe and secure conduct of transport of radioactive materials, and the adoption of relevant good practice.
This inspection targeted SL's arrangements in respect of RID 20151 in respect to the arrangement as specified in the GB package validation approval2.
The scope of the inspection was limited to compliance activities at SL covering the loading of a package and the "gated process" used to allow consignments.
Not applicable to Compliance System inspection.
The Inspection team sampled, the transport3 arrangements deployed by SL by comparing the requirements within relevant statutory provisions and management systems standards with both prescribed arrangements and actual practice. The scope of the inspection was limited to those listed below.
The inspection covered 'Gate 1 Proposing' and 'Gate 2 Planning' requirements - 'Planning against Sellafield Ltd Supporting Practice Individual Consignment Process' SLSP 2.07.002 Iss 4.
The loading of the Castor Package D4325 as per GB Competent Authority Validation of Approval of Package Design for the Carriage of Radioactive Material D/4325/B(U)F-96 (Trim Ref 2016/3900)
The topics as identified in the "TIE Transport Strategy for SL VRR Programme August 2015" were shared with SL prior to the inspection.
An inspection plan was created and sent to SL prior to the inspection (Trim ref 2016/151039).
Preparation of Gate 1 and 2. It was noted that the process covering the gated process is under review with the aim to rationalise the process. ONR has sampled the process on a previous intervention (Trim 2015/350192). The document pack was being prepared to be sanctioned by the committee overseeing the Consignment process. This is independent from the actual loading operations. No issues were raised.
The intervention also covered witnessing the loading arrangements of the flask. This was independent, being observed by the Swiss Regulator, Owner of the material and the Company licenced to store the material on arrival in Switzerland. I had a brief discussion with all three representatives who were witnessing the loading operations, no issues were raised.
Oversight by SL ensures that the inner containers are loaded in the correct channel and position. The determination of each inner container has been agreed prior to commencement of the loading operation and with the Customer.
The procedures and processes were sampled for this loading operation and no issues were raised.
1 Compliance with RID 2015 is a requirement of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09).
2 ONR Validation of Approval of Package Design for the Carriage of Radioactive Material GB Competent Authority Validation of Approval of Package Design for the Carriage of Radioactive Material D/4325/B(U)F-96
3 For the purpose of ONR Transport Inspections, 'Transport' comprises all operations and conditions associated with, and involved in, the movement of radioactive material; these include the design, manufacture, testing, documentation, use, maintenance and inspection of all special form radioactive material, low dispersible radioactive material and packages; and the preparation, consigning, loading, carriage including in-transit storage, unloading and receipt at the final destination of loads of radioactive material and packages.