Executive summary
Date(s) of inspection:
- January 2023
Aim of inspection
Magnox Ltd has requested a Category A Modification to the contents of Modular Flask DN3358W, previously approved in the Certificate of Approval GB/3358W (Rev.3). The current approval (GB/3358W/B(M)F, Rev. 3) allows for up to 900g of compacts or 700g of particles (or a fractional combination of the two). This modification seeks to extend the allowable contents of the package to include the remaining materials that are intended to be transported in the GB/3358W Package but are excluded from the current approval.
As operation of the GB/3358W is conducted by Magnox, the aim of this inspection is to:
- determine the suitability and adequacy of operating and maintenance instructions to enable reliable human performance and support continued use of the two GB/3358W packages.
- determine whether Magnox is adequately managing ageing and degradation of the two GB/3358W packages noting the extension in expected operating life of the GB/3358 outer packages.
Subject(s) of inspection
- Transport (Nuclear) 5 Package Maintenance and Operation - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
An inspection was conducted in order to support the assessment of a modification to the GB/3358W package.
The Inspectors found that the GB/3358W is being operated in accordance with the PDSR via Magnox’s Limited’s instructions, and that ageing and degradation mechanisms, as well as maintenance, are being adequately managed.
We consider that an overall rating of Green is appropriate as there are no significant shortfalls against good practice. However, as several minor shortfalls against good practice were identified, Regulatory Issues 11204 and 11218 have been raised to track and resolve these shortfalls.
Based on the findings of this inspection, and on the basis that Regulatory Issue 11204 is suitably resolved I recommend that the Project Inspector provides Approval of the requested modification. Whilst no significant shortfalls were found, Magnox Limited and Nuvia will be revising their instructions to account for the requested content modification, as such this regulatory issue should be addressed as part of the PDSR update to ensure good practice is integrated into the instructions.
Regulatory Issue 11218 is related to paint a specification modification. Work to address this RI is not required ahead of the requested approval.
Conclusion
We judge that the GB/3358W is being operated in accordance with the PDSR via Magnox’s Limited’s local instructions, and that ageing and degradation mechanisms, as well as maintenance, are being adequately managed by Magnox Limited.
We consider that an overall rating of Green is appropriate as there are no significant shortfalls against good practice. However, as several minor shortfalls against good practice were identified, Regulatory Issues 11204 and 11218 have been raised to track and resolve these shortfalls.
Based on the findings of this inspection, and on the basis that RI-11204 is suitably resolved I recommend that the Project Inspector provides Approval of the requested modification. Whilst no significant shortfalls were found, Magnox Limited and Nuvia will be revising their instructions to account for the requested content modification, as such this RI should be addressed as part of the PDSR update to ensure good practice is integrated into the instructions.
As RI 11218 is related to paint modification and expected prior to annual maintenance, I am content that work to address this RI is not required ahead of the requested approval. I note however, that the work should be completed in timely way and ahead of the scheduled annual maintenance. Timescales for this RI will be agreed with the dutyholder via routine engagement.