- Site: Harwell
- IR number: 21-062
- Date: July 2021
- LC numbers: 5, 25, 26
Executive summary
Purpose of Intervention
The purpose of this inspection was to evaluate Harwell’s (Magnox Ltd.) compliance against the requirements for the civil transport of Class 7 (radioactive materials) dangerous goods, as set out in the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.
The Office for Nuclear Regulation is responsible for regulating the civil carriage of Class 7 dangerous goods within Great Britain as the Transport Competent Authority under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.
The inspection also considered the adequacy of the duty-holders arrangements for compliance with site licence conditions, LC 5 (Consignment of nuclear matter), LC 25 (Operational records) and LC 26, (Control and supervision of operations).
Inspection Carried Out by ONR
The inspection was broadly conducted under the following headings:
- Plant Walkdown
- Consignment of Class 7 Materials
- Class 7 Transport Emergency Arrangements
Plant Walkdown
The plant walkdown was conducted in two phases, the first to witness the preparation and dispatch of a Novapak consignment and package maintenance building, the second to Harwell’s emergency responder facility. During both plant walkdowns a high level of housekeeping standards was noted and Covid-19 arrangements were being followed.
Consignment of Class 7 Radioactive Materials
The duty-holder’s preparations for the dispatch of a Novapak consignment was inspected. The duty-holder summarised Harwell’s transport operations and arrangements. I witnessed the completion of the duty-holder’s quality plans. Once the consignment had left, the inspection was continued and the documents comprising the Quality Plan package were examined.
I confirmed that the Quality Plan had been appropriately completed with all the appropriate fields signed. The Quality Plans are not completed until the consignment reaches the consignee. A Quality Plan from a previous completed consignment was examined to confirm that all the appropriate fields were signed.
Class 7 Transport Emergency Arrangements
I inspected the duty-holder’s Radsafe responder vehicle (which Harwell uses to respond to a transport emergency) and the associated equipment store. The duty- holder explained that the Harwell site was one of four Magnox Limited sites designated as Level 2 and 3 emergency responders.
The duty-holder commented that the current vehicle was shortly to be replaced in response to a recommendation from a recent Internal Oversight Audit Report.
A sample of the equipment was examined and confirmed to be readily available and calibrated where appropriate The housekeeping was observed to be of a good standard.
Radsafe is a national response scheme for transport events involving Class 7 materials, and Harwell provides a Level 2 and Level 3 emergency response. As such, it is always on standby, and the vehicle and required equipment for this were ready. Radiological Accident Contingency Plans were available, with specific arrangements for both a Level 2 and a Level 3 Radsafe response.
Compliance with Licence Conditions 5, 25 and 26
During the inspection of the transport operations, I inspected Harwell’s compliance with LC 5 for consignment of nuclear matter, LC 25 for operational records, and LC 26 for control and supervision of operations. I was satisfied that adequate compliance with LC 5, LC 25 and LC 26 was demonstrated.
Conclusion of Intervention
Based on evidence gathered from this intervention I considered that Harwell (Magnox Ltd.) was compliant with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 for Class 7 (radioactive materials).
During the inspection the duty-holder was able demonstrate adequate compliance with LC 5, 25 and 26. I have therefore rated compliance to these license conditions as Green (no formal action).
Several minor observations were made during the inspection and will be followed up as part of normal regulatory business.