Inspection of Magnox Ltd Oldbury's arrangements against the requirements of CDG 2009 and ADR 2017
- Site: Oldbury
- IR number: 17-146
- Date: October 2017
- LC numbers: N/A
Purpose of Intervention
Purpose of Intervention
The purpose of the inspection was to:
- Sample the adequacy of the arrangements for the transport of radioactive material, and compliance with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09) at Oldbury.
- Enhance ONR's understanding of the current and future activities at Oldbury and other stations with regard to the transport of Class 7 dangerous goods.
- Support the permissioning process for transport package approvals.
- Establish a baseline to allow ONR to monitor future performance/compliance against current transport regulations.
Interventions Carried Out by ONR
The inspection was conducted against the requirements of 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 Oldbury, in respect of the safe transport of radioactive material, against the requirements of CDG09.
In addition, the inspection supported the concurrent inspection being carried out by the ONR Site inspector on LC6 (Document, records, authorities and certificate) and LC17 (Management Systems) arrangements.
The intervention focused on the following areas;
- M2 Flask Permissioning in relation to DECP ‘In reactor' Breeder Fuel Consignments.
- Consignment of radioactive material offsite.
- Support to other Magnox sites regarding the decommissioning and consolidation of radioactive material using Ductile Cast Iron Containers (DCICs).
- Support to the Site Inspector on the inspection of LC6 and LC17 arrangements.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A - not a System/Structure Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspection concluded that the current arrangements at Oldbury for the safe carriage of Class 7 dangerous goods continue to be adequate based on the evidence reviewed. In addition, the M2 Flask Design Authority management systems examined supported the ongoing permissioning process.
Three inspection observations were made and conveyed to the licensee, these were:
- Review of Oldbury processes to meet Dangerous Goods (Including Radioactive Material) Transport S-142 Issue 4.
- Review transport processes to define the meaning of ‘damage' to the various transport packages being used.
- Review the unloading and loading arrangements of the laundry consignments from UniTech to ensure the packages being unloaded are not mixed with the ones being returned.
The inspection also identified good practices, these were:
- The procurement of lifetime spares to see the M2 flask fleet through to the end of the Magnox Operating Plan (MOP) and the active monitoring of the spares to ensure any re-ordering is managed in a systematic manner.
- Support given to Dounreay Site Restoration Ltd (DSRL) to retrain their staff in the M2 flask operations ready for the commencement of ‘in reactor' fuel shipments and the ongoing support via the weekly telecom between Magnox Ltd, Sellafield Ltd (SL) and DSRL.
- Commencement of early engagement for the handover of the M2 flask design to Sellafield at the end of MOP, including discussions on maintenance and spares requirements.
Conclusion of Intervention
The findings were shared with, and accepted by Oldbury. I made some suggestions regarding potential improvements. I did not identify any significant shortfalls in the arrangements which I deemed to be adequate overall.