ONR inspected the EDF Cyclife Lillyhall facility in relation to the safe transport of Class 7 dangerous goods (radioactive material). This intervention is one of a series detailed in the Transport Inspection Programme for 2017-18.
The purpose of the inspection was to:
Examine a sample to judge the adequacy of the arrangements for the transport of Class 7 Dangerous Goods (i.e. Radioactive Material), and compliance with the ‘Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations 2009' (CDG09) at Cyclife Lillyhall.
To develop ONR's understanding of the current and future activities at Cyclife Lillyhall with regard to transport of Class 7 dangerous goods.
Establish a baseline to allow ONR to monitor future performance / compliance against current transport regulations.
The inspection was conducted against the requirements of the CDG09, a relevant statutory provision of The Energy Act 2013, which requires carriage of Class 7 dangerous goods by road to be in accordance with the appropriate edition of the European Agreement known as ADR. The current edition is ADR 2017.
The inspection examined a sample of the management arrangements used by Cyclife Lillyhall for the safe transport of Class 7 dangerous goods, including the associated management system documents related to consignment of Class 7 dangerous goods from site, radiation protection programme required by ADR17, training and competence of staff involved in transport operations, and transport emergency planning and testing.
This included the management procedure for the transport of Class 7 dangerous goods "Transport of Radioactive materials including a radiation protection programme" Cyclife document reference WP/MRF/015.
To provide ONR with an overview of the packaging operations for transport, a visit was made to the first floor observation area of the main building, the "in transit" storage areas for incoming and outgoing packages and the storage area for equipment packs used in response to an offsite transport emergency.
The inspection concluded that the current arrangements at Cyclife Lillyhall for the safe carriage of Class 7 Dangerous Goods, continue to be adequate based on the evidence reviewed during this inspection.
Three inspection observations were made and conveyed to the licensee, these were:
The emergency arrangements made under Schedule 2 of CDG09 should be further documented to include detail the actions of the consignor (Cyclife) in relation to a transport emergency occurring offsite. The arrangements should include a process for the certification of onward movement of any packages of Class 7 dangerous goods involved in such an emergency.
The management documents relating to transport of class 7 dangerous goods should refer to statutory requirements in the UK and Europe (CDG09 and ADR17). The IAEA Regulations for Safe Transport of Radioactive Material (IAEA SSR-6) may still be referenced additionally for convenience although they are not directly applicable in GB.
The management arrangements for transport of Class 7 dangerous goods should include an explicit instruction for Cyclife Lillyhall to provide a follow-up report to ONR in regard of "INF1" notifications.
The Cyclife document "Appointment and duties of RPA, RPS, RPO and RWA" (Cyclife reference WP/RP/002) should be expanded to include the role of the DGSA for Class 7 dangerous goods to ensure this is captured in relation to the other roles involving advice and supervision relating to radioactive materials.
The inspection also identified good practices, these were:
The radiation protection programme included active and passive radiation monitoring of persons involved in the transport operations (including packing, loading, filling, unloading and consignment). Results of passive radiation monitoring for classified and non-classified workers are reviewed on a regular basis in respect of the ADR17 requirement to keep doses as low as reasonably achievable (ALARA). Sharing of the dose information allows workers to compare doses and adopt best practices.
The equipment for responding to offsite transport emergencies was comprehensive and readily available. The Health Physics staff demonstrated a good understanding of their role in an offsite transport emergency.
I did not identify any significant shortfalls in the arrangements, supporting documents and records I examined in support of my inspection for CDG09 and the related ADR17.