- Site: Dungeness A
- IR number: 21-136
- Date: November 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
Transport regulations require dutyholders undertaking Class 7 transport activities to have an adequate safety management system. This inspection was undertaken to confirm the adequacy of the management system arrangements relative to the safe transport of radioactive materials (Class 7 dangerous goods).
Interventions Carried Out by ONR
During this inspection, ONR sought to gain evidence of compliance with:
- The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG) 2018
- UNECE Agreement concerning the International Carriage of Dangerous Goods by Road 2021 (ADR) – www.unece.org
- OTIF Regulations concerning the International Carriage of Dangerous Goods by Rail 2021 (RID)
- Ionising Radiations Regulation 2017 (IRR17) – Regulation 8 –Radiation Risk Assessment – Guidance in relation to the civil transport of radioactive material
The inspection comprised a review of the Dungeness A transport management system and its associated procedures, documentation and records.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The transport management system on site is integrated and graded. The Class 7 arrangements are well documented and structured, with a multi-layered system of clear processes, instructions, forms, etc. that are easily accessible to the relevant people.
Various thematic areas pertaining to package preparation, operation, emergency arrangements and training were tested, and it was clear that those sampled were integrated into the Dungeness A management system. Operations relating to Class 7 transport are conducted in accordance with the Dungeness A management system and regulatory requirements.
Some compliance sampling of historic consignments was undertaken. It was clear that consignments are undertaken in accordance with the Dungeness A management system.
Following examination of training and records and based on various interactions with staff undertaking Class 7 transport duties, it was judged that staff with roles pertaining to Class 7 transport are suitably qualified and experienced.
ONR judged that Site was able to demonstrate adequate management arrangements required to discharge its duty as a Class 7 transport operator.
During the inspection, ONR made several observations for improvement that were fed back to Magnox Ltd staff.
Conclusion of Intervention
Overall, based on the evidence from this inspection, it is judged that Dungeness A has an adequate management system to support the continued programme of Class 7 transport operations, as defined in the applicable transport regulations.
There were no significant matters identified that would challenge the adequacy of the Dungeness A management system pertaining to Class 7 transport operations.