Magnox Dungness A - Radioactive Material (RAM) Transport Intervention
- Site: Dungeness A
- IR number: 17-058
- Date: June 2017
- LC numbers: N/A
Purpose of Intervention
This compliance inspection at Magnox Ltd’s (ML) Dungeness A licensed site was in relation to the safe transport of Radioactive Material (RAM) and was one of a series detailed in the ONR Transport Inspection Programme for the year 2017/18.
The purpose of the inspection was to:
- Sample the adequacy of the arrangements for the transport of RAM, and compliance with the ‘Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009’ (CDG2009) at Dungeness A Power Station.
- To develop ONR’s understanding of the current and future activities at Dungeness A with regard to RAM transport and how these relate to the wider Magnox Limited estate.
- Establish a baseline to allow ONR to monitor future performance / compliance against current transport regulations.
This inspection was conducted jointly with ML own ‘internal oversight’ team.
Intervention Carried Out by ONR
The inspection was conducted against the requirements of the CDG2009, a relevant statutory provision of The Energy Act 2013, which requires carriage by road and rail to be in accordance with the appropriate edition of the European Agreements known as ADR (for road) and RID (for rail). The current editions are ADR 2017  and RID 2017 .
The inspection sampled the transport arrangements deployed by Dungeness A for the safe transport of RAM, including the associated management system documents, including those related to Package Maintenance and Operations, Package Preparation for Consignment, Management and Control of Transport Interfaces, Training and Competence, and Emergency Planning and Testing.
This included the overarching corporate system (Magnox standard procedure ‘S-142 - Dangerous Goods (including Radioactive Materials) Transport’), together with transport specific procedures and sub-documents which were examined and local implementation was discussed / reviewed.
The inspection supported ML’s own internal oversight team as per ONR guidance ‘General Inspection Guide’ ONR-INSP-GD-064 Revision 2.
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspection concluded that the current arrangements at Dungeness A for the safe carriage of RAM arising from decommissioning, continue to be adequate based on the evidence reviewed during this inspection.
Three inspection comments were raised, these were:
- Amendment of Form No. 447 such that it is more specific in identifying the responsible person authorising each step. This comment arose following the ‘Management and Control of Transport Interfaces’ component of the inspection.
- Amendment of a Magnox ‘Authorising Instruction’ on Agresso (also known as Unit4 Business World)  , which serves as Magnox’s training database to provide clarity of information on whether an employee is trained to consign RAM by rail. This comment arose following the ‘Training and Competence’ component of the inspection.
- The transposing of package technical data from third party package authorisations (i.e. Low Level Waste Repository (LLWR) IP2 packages) into their own documentation, there is a risk that Dungeness A could inadvertently miss any updates issued for the use of transport packages.
The inspection also identified good practices, these were:
- The on-site ‘Dangerous Goods Awareness’ training package given to all staff involved in the loading, packing, filling and consignment of RAM.
- The practices and processes which had been evolved for the consignment of RAM from site.
- The waste management processes implemented at the station that has helped reduce radioactive waste being unnecessarily consigned to LLWR. Where appropriate, waste is disposed of by other approved means such as metal recycling, incineration or free release.
- The ongoing simulated trials to maximise and optimise the volume of the Type IP-2 MOSAIK package ready for actual loading and transport to Bradwell is to be commended.
Conclusion of Intervention.
The arrangements examined in this inspection in relation to the transport of RAM are considered adequate for the purposes of compliance with the requirements of CDG2009.
Working with the duty-holder internal oversight was found to be beneficial for the following reasons:
- It was found that more areas of the duty-holders transport arrangements could be covered by the inspection.
- It allowed both ONR and the internal oversight to share inspection good practice and knowledge.
- It allowed ONR to gain confidence in Magnox own internal oversight arrangements
- ML accepted our findings and will consider and address our comments as appropriate.