NNL Central Lab - Intervention to support the Permissioning of Transport Package GB/2816G
- Site: Sellafield
- IR number: 18-161
- Date: December 2018
- LC numbers: N/A
Purpose of Intervention
ONR inspected National Nuclear Laboratories (NNL) and Sellafield Ltd (SL) arrangements at Sellafield site, in relation to the safe transport of radioactive material.
The inspection was intended to support the current permissioning work being undertaken by ONR in licensing the SAFKEG GB/2816G/B(M)F-96 transport package, used to ship radioactive material from Sellafield to France. This intervention forms part of a programme of work being undertaken by ONR to gain assurance that the planned movement of material will be complaint with National and International requirements.
Purpose of Intervention
The purpose of the inspection was to:
- sample the adequacy of the organisation’s Management System arrangements, and their implementation, relating to the safe transport of radioactive materials.
- gain an understanding of how organisations involved in the licensing / shipment interface with each other and how the project is holistically controlled.
- ensure that organisations understand their duties and responsibilities with respect to GB law.
- gain a further understanding of the package / stillage arrangements (including requirements for further design / manufacture) and the loading process in order to accelerate the ONR permissioning process.
- gain confidence in NNL’s implementation of the transport safety case (and in particular, the operating instructions).
- inform the ONR SDFW programme of potential risks.
- improve safety outcomes by assuring (and where necessary, intervening) to seek improvements in industry compliance with regulatory requirements (pertaining to the safe transport of radioactive materials) and the adoption of relevant good practice.
Interventions Carried Out by ONR
The inspection reviewed NNL and SL arrangements to meet the requirements of CDG, ADR and RID Intergovernmental Organisation for International Carriage by Rail. (RID) 2017.
The intervention focused on the package and loading arrangements of the GB/2816G transport package.
- Meeting requirements identified in the transport safety cases.
- Loading operations.
- Confirmation of contents in consignments.
- Training of operators carrying out nuclear transport operations.
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 findings of the inspection were shared and accepted by NNL and SL.
The following points were raised in the hot de-brief:
- NNL are the legal duty holder under ADR/RID regulations as packer and loader. Operators need basic transport awareness training for the operations they are carrying out. (SL Fuel handling Plant may have suitable awareness training packs that could be used).
- It is recommended that NNL carry out receipt inspection of the 2 new SAFKEG packages in order to ensure that they are complainant with the package design (and record the findings of this). This should include any previous LFE, such as staining in the inner side of the outer package and marks on the CV itself.
- The inner pot lid closing mechanism should be reviewed, to ascertain whether it can be secured in a positive manner (e.g. use of tape).
- The pen used to label and identify the inner bags should be compatible with the PVC bag used.
- Instructions to replace the spacer in the SAFKEG should be provided (LFE from DSRL)
- A power driver should not be used to torque or run the package nuts. (LFE from SL).
- The wattage of the inner containers (accumulative) should meet package design transport restrictions.
- A set of spares should be available (not to be confused with on-site package spares). A method to record the use of spares should be employed (an example of good practice can be found in the Vitrified Residue Returns Quality Plan)
- All LFE from the dry-run should be reviewed with changes made where necessary.
- The package design operating instructions should be translated (and verified) into the facility operating instructions correctly.
- The package design content restrictions (e.g. activity, mass, isotopic content etc.) should be adequately transferred into the facility operating instructions. The most restrictive limit should be used.
- The consignor should confirm how monitoring has been undertaken with the customer (e.g. what type of monitoring equipment has been used and monitoring locations).
- The consignor should have early access to the documentation regarding package operations and maintenance.
Conclusion of Intervention
This inspection identified no major issues of safety concern the loading arrangements and future transport of the radioactive material from Sellafield to France.