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LC5 and CDG2009 compliance for Novapak consignment

  • Site: Harwell
  • IR number: 19-003
  • Date: April 2019
  • LC numbers: 5

Executive summary

Purpose of Intervention

This was an unplanned inspection at the Magnox Limited Harwell site to determine the licensee’s readiness to recommence use of the Novapak Type B transport package following ONR enforcement action.

Interventions Carried Out by ONR

During this intervention, I carried out a compliance inspection against the following regulations and licence conditions.

  • Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009
  • LC 5 Consignment of Nuclear Matter

I sought to gain evidence that:

  • Sufficient improvements have been made to Magnox Ltd management arrangements for the acceptance and consignment of Class 7 Transport Packages.
  • The Design Authority, had issued a Certificate of Conformity, verifying compliance with the design specifications, drawings and/or other technical requirements for the Novapaks, as manufactured.
  • Magnox Ltd had performed adequate checks that the Novapaks, as supplied, had not been subjected to unacceptable package damage since the issue of the Certificate of Conformity.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The licensee was able to demonstrate through its documented arrangements that I examined; packages inspected and the staff interviewed that it complied with the requirements of Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 and Licence Condition 5.

It is my opinion that the improvements made by ML to its arrangements for the acceptance and consignment of Class 7 Transport Packages have been effective in securing compliance, as evidenced in their implementation for the Novapak Type B packages. 

Magnox Ltd have a Certificate of Conformity issued by the Design Authority for the Novapak packages supplied, which verified compliance with the design specifications, drawings and/or other technical requirements.

It is my opinion that Magnox Ltd had performed sufficient checks that the Novapaks, as supplied, had not been subjected to unacceptable package damage since the issue of the Certificate of Conformity and that adequate record keeping arrangements were in place.

Conclusion of Intervention

The arrangements made by the Licensee's for compliance with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 and LC 5 are now adequate.  The implementation of these arrangements for the Novapak packages and the supporting documentation inspected were also adequate. I therefore conclude that there are no matters that may impact significantly on nuclear safety that would prevent the use of the Novapak Type B package by Magnox Ltd.