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Sellafield - Inspection ID: 53032

Executive summary

Date(s) of inspection

  • June 2026

Aim of inspection

International Nuclear Services (INS) is managing a programme of work on behalf of the Nuclear Decommissioning Authority (NDA) to return vitrified high-level waste to customers in Germany. The waste is transported in CASTOR packages via a multi-modal transport chain (rail and sea).

The dutyholders involved in the end-to-end transport are as follows:

  • Packer / Consignor / Loader: Sellafield Ltd
  • Rail Carrier: INS (operations delivered by Direct Rail Services under contract)
  • Rail Unloader: INS
  • Sea Loader: INS
  • Sea Carrier: Pacific Nuclear Transport Ltd (PNTL)

The purpose of this intervention is to witness key transport activities and confirm that dutyholders are:

  • Operating safely
  • Complying with The Regulation concerning the International Carriage of Dangerous Goods by Rail (RID)
  • Adhering to their own established arrangements and procedures

Subject(s) of inspection

  • Transport - Carrier Duties - Rating: GREEN
  • Transport - Consignor Duties - Rating: GREEN

Key findings, inspector's opinions and reasons for judgement made

I undertook an inspection of the German Vitrified Residue Returns (VRR) shipment comprising seven CASTOR packages transported between Sellafield Ltd and the Isar Interim Storage Facility, Germany, by rail, sea and road. The inspection focused on compliance with the requirements placed upon transport participants under the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID).

The inspection scope included the following dutyholders and associated transport duties:

  • Sellafield Ltd – consignor activities, including preparation of packages and conveyances for transport and loading operations at Sellafield.
  • Direct Rail Services (DRS) – carrier duties associated with rail transport between sites.
  • International Nuclear Services (INS) – unloading of packages from rail conveyances and loading onto the maritime vessel.
  • Pacific Nuclear Transport Ltd (PNTL) – participant duties were outside the scope of this inspection.

At the time of the intervention, packages had already been loaded with inventory, and the majority of preparatory consignment activities had been completed. These activities were therefore not directly sampled during this inspection, having been previously examined under ONR intervention IR-54638.

The inspection focused on package condition checks, radiological monitoring arrangements, interfaces between transport dutyholders, transfer of responsibilities throughout the transport chain, and implementation of the approved Quality Plan (QP/95) and Transport Documentation File (TDF).

Activities at ABP Port of Barrow were observed jointly with the Maritime and Coastguard Agency (MCA). Regulatory responsibility and enforcement authority for the observed maritime and port Class 7 activities rest with the MCA (and HSE where applicable). ONR's observations were undertaken in support of its wider assessment of the effectiveness of the end-to-end transport arrangements for radioactive material (considering that ONR issued the transport Certificate of Approval for the packages used in this shipment) and should not be interpreted as the exercise of primary regulatory oversight of those activities.

Due to logistical constraints, inspection activities were undertaken out of operational sequence. Rail transport of the seven packages occurred over three separate consignments (3-3-1), with all seven packages subsequently loaded onto the vessel as a single maritime consignment. For clarity, this report presents findings in accordance with the transport dutyholder chain rather than the chronological sequence in which activities were observed.

Preparation for Consignment

Preparation for consignment activities are undertaken by Sellafield Ltd with independent witnessing and assurance activities provided by DRS, INS and GNS. Packages are loaded into dedicated transport frames within the Flask Maintenance Facility (FMF) before being secured onto dedicated KXAC rail wagons. The train is configured in accordance with an approved transport plan to ensure compliance with operational and transport restrictions.

As package preparation activities had largely been completed before the inspection commenced, sampling was focused on the seventh and final package within the consignment (HAW28M-098M).

I sampled the following aspects:

  • Package Marking - I observed that package markings included the Proper Shipping Name (PSN), UN number, unique package identification, Competent Authority identification, gross mass, consignor and consignee details, and the prescribed trefoil symbol. Sampling against RID requirements, the applicable Certificates of Approval (CoA) and QP/95 demonstrated compliance. Prior to the intervention, ONR had identified that package markings did not explicitly display the GB Competent Authority identification associated with the UK transport approval. Sellafield Ltd had subsequently applied supplementary markings to address this omission. ONR considered these arrangements to provide an appropriate means of demonstrating compliance with RID requirements.
  • Package Labelling - I observed that package labels accurately displayed transport category, key radionuclides, activity and Transport Index (TI) values. Sampling against QP/95 confirmed consistency between recorded values and package documentation.
  • Placarding - I observed that placarding had been applied to the conveyance in accordance with RID requirements.
  • Radiological Monitoring - I observed Sellafield Ltd undertaking contamination monitoring through trunnion swab sampling. Samples were appropriately identified, analysed and recorded within the TDF and Quality Plan. Sampling confirmed compliance with applicable contamination limits. Dose rate measurements were undertaken to demonstrate compliance with transport requirements. The highest recorded combined neutron and gamma dose rate at two metres from the conveyance was 32 µSv/h, which is within the applicable regulatory limit. Surface dose rate measurements had been completed previously and were appropriately recorded within transport documentation.
  • Package Securing Arrangements - I observed the package being secured to the transport frame and the frame subsequently secured to the rail wagon using calibrated tooling in accordance with B550/QP/95. Sampling confirmed implementation of the approved torquing arrangements and fitting of trunnion guards prior to transport.

Overall, I judged the arrangements sampled for preparation of the package and conveyance to be adequately implemented and consistent with RID requirements.

Loading Operations at Flask Maintenance Facility (FMF)

I observed loading operations within FMF being undertaken in accordance with approved operating instructions and Quality Plan requirements:

  • OI/02 – Operating the 130 Tonne Overhead Crane (EWE 1772), Issue 9, 11/2024
  • OI/05 – Movement of Flasks in FMF, Issue 14, 02/2026
  • QP/95 – Receipt of Laden CASTOR HAW 28M flasks from REF, storage and export, Issue 7, 08/2023

Specifically, I observed:

  • Loading of package HAW28M-098M onto a KXAC rail wagon.
  • DRS involvement in witnessing loading activities and providing independent assurance of loading arrangements.

Sampling of package documentation confirmed consistency between package mass records, Certificates of Approval and Quality Plan requirements. I also confirmed implementation of torquing requirements specified within the approved continuous use instruction.

I judged loading activities to be undertaken under suitable procedural control and supported by appropriate independent oversight.

Site Rail Movements and Clearance for Transport

Movement of the conveyances on the Sellafield rail network was controlled through approved railway instructions and site transport arrangements.

I observed completion of the transport clearance process, including:

  • Completion of the clearance certificate by a Sellafield Ltd Duly Authorised Person.
  • Formal transfer of documentation to Consignment Services (CS).
  • Retention and distribution of approved Quality Plan records.

Sampling of transport documentation demonstrated that required approvals, classifications and authorisations had been completed prior to departure. In particular:

  • Section H of CS0007 (Consignment Checklist for All Classes of Dangerous Goods, Issue 13) for HAW28M‑096 confirms that vehicle placarding had been completed and witnessed by CS.
  • CS0055 (Dangerous Goods Classification) - arrangements differ from standard transport management processes, with a CS Consignment Officer completing the form rather than the requesting plant Dangerous Goods Dispatch Officer (DGDO).
  • The clearance certificate for HAW28M‑096 was appropriately signed by the relevant dutyholders.

I noted that compliance was achieved through the involvement of a CS Consignment Officer in activities normally assigned to the requesting plant Dangerous Goods Dispatch Officer (DGDO). While effective in practice, this arrangement is discussed further under Observation 3.

Train Preparation and Departure

I observed preparation of the train for departure and sampled evidence supporting compliance with carrier responsibilities under RID:

  • The train consisted of three laden conveyances forming a single consignment.
  • DRS undertook visual inspections of conveyances and packages prior to departure.
  • Responsibilities were formally transferred between Sellafield Ltd and DRS through completion of transport documentation.
  • The train departed the Sellafield site in accordance with the approved transport plan.

Sampling of the Multimodal Dangerous Goods Note (MDGN) confirmed consistency with package documentation and Quality Plan records.

I considered DRS's implementation of carrier responsibilities to be consistent with RID requirements sampled during the intervention.

ABP Barrow Marine Terminal

Whilst ONR does not hold regulatory powers to formally inspect activities at ABP Barrow Marine Terminal, ONR accompanied the MCA to observe package transfer operations and the effectiveness of arrangements across the transport interface.

I observed:

  • Arrival of the train at the port facility.
  • Presence of compliant conveyance placards and package labels.
  • Transfer of package HAW28M-096 from rail conveyance to maritime transport frame.
  • Completion of package condition inspections by INS and GNS following lifting operations.
  • Loading of the package onto the vessel in accordance with the approved loading plan.
  • Formal transfer of responsibilities from INS to the vessel operator.

Sampling of the Transport Documentation File confirmed the presence of valid UK and German package design approvals.

I observed that package transfer activities were undertaken in a controlled manner with appropriate oversight and documentation.

Conclusion

Based on the sampling undertaken, I judge that the transport participants inspected had implemented suitable arrangements to support compliance with the relevant RID requirements associated with the shipment of vitrified residue return transport packages.

Three observations were identified relating to demonstration of dose rate compliance, document configuration control and the alignment of transport management arrangements. None of these observations represent an immediate shortfall requiring regulatory action. I expect the matters identified to be considered within ongoing transport management system improvement activities and future continuous improvement programmes.

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