- Site: Sellafield
- IR number: 19-117
- Date: October 2019
- LC numbers: N/A
Executive summary
ONR inspected National Nuclear Laboratories (NNL) and Sellafield Ltd (SL) arrangements at Sellafield site, in relation to the safe transport of radioactive material. International Nuclear Services Limited (INS) was also represented during the intervention. INS and Sellafield are delivering the NDA project (mission) and INS is carrying out transport support activities and acting as Carrier for the sea leg of the journey on behalf of Sellafield as the Consignor.
The purpose of the inspection was to support the current permissioning work being undertaken by ONR in licensing the Shipment of SAFKEG GB/2816G transport packages, used to ship radioactive material from Sellafield to France. The shipments are to two locations in France. Subsequent movements will occur between the French locations. 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:
- examine a sample of the various dutyholders’ Management System arrangements, and their implementation, specifically in relation to the permissioning of the application for a Shipment Certificate of Approval, GB/2816G/B(M)F-96T Rev 0;
- gain an understanding of how organisations responsible for packing, loading, consignment and shipping of this package, interface with each other and how the project is holistically controlled;
- as Packer and Loader, gain confidence in NNL’s implementation of the constraints identified in the Design Approval Certificate (GB/2816G/B(M)F-96 Rev 5) and Shipment Submission for Approval. In particular, that the content aligns with Consignee Conditions for Acceptance;
- as Consignor, gain confidence in SL’s implementation of the constraints identified in the Design Approval Certificate (GB/2816G/B(M)F-96 Rev 5) and Shipment Submission for Approval; and
- 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 ‘The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG) and the International Maritime Dangerous Goods (IMDG) Code.
The intervention focused on the packing, loading and consignment of the SAFKEG GB/2816G transport package.
- Meeting requirements identified in the transport safety cases.
- Loading operations.
- Confirmation of contents in consignments.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The findings were shared and accepted by NNL, INS and SL.
The following points were made in the debrief meeting immediately following the inspection:
- It was evident that a number of key documents required prior to packing and loading of the packages were not yet finalised. ONR requested that a number of relevant documents be provided once they are finalised and before use. These are as follows: -
- From NNL, the ‘Packing and transfer of SNM from B170 to Orano’ IMS-I-400-02681
- From NNL, the ‘Quality Plan IMS-QP-SEL-024’ for control of packing and loading
- From NNL, the ‘Experimental Proposal’ for control of the drying process including unloading of the Aliquots and reloading.
- From SL, the Compliance Table that is presented to the Office of Consigning Authority (OCA)
- From SL, the paper to be presented at the OCA Gate 3/4 meeting. It is expected that this will contain contingency plans.
- From INS, Evidence that awareness of the uneven loading of the Security ISO has been communicated to all duty-holders responsible for lifting and NNL as Loader.
- The amount of preparation still to be completed, evidenced by the number of inconsistencies identified by ONR and the timescales for completion is a risk factor to regulatory compliance.
- The Sellafield ‘gated’ process and the use of an Office of Consignment Authority (OCA) gives confidence in shipment compliance.
- During the intervention, Sellafield could not provide evidence, as Consignor, that it had audited INS’ activities. This gap in supplier qualification should be rectified.
- It was noted that the intervention scope did not include further consignments that due to their location were outside ONR’s authority.
Conclusion of Intervention
This inspection identified no issues that would prevent granting a GB Competent Authority Certificate of Approval for Shipment for the SAFKEG design GB/2816G. The Certificate will include the requirement to ensure all Consignee Conditions for Acceptance are met.
There is a risk that due to the amount of preparation to be completed and the required timescales, the contents or operations do not meet the requirements of the Consignee or Package Design Safety Report.