Executive summary
Date(s) of inspection:
- February 2024
Aim of inspection
To confirm that the interrupted transport of DN30 packages following expiry of package design approval certificate F/420/AF (Ab) can be completed compliant with package design approval certificate F/420/AF (Bd) and with requirements of CDG 2009, ADR and IRR17.
This inspection will support the decision justification for validation of package design approval certificate F/420/AF (Bd) being progressed under PR-01560.
Subject(s) of inspection
- Transport (Nuclear) 10 Training and Competence - GREEN
- Transport (Nuclear) 11 Emergency Planning and Testing - AMBER
- Transport (Nuclear) 5 Package Maintenance and Operation - GREEN Transport (Nuclear) 8 Management
- and Control of Transport Interfaces - RED
Key findings, inspector's opinions and reasons for judgement made
Urenco UK Limited (UUK) has requested UK Validation of the French package design approval certificate F/420/AF (Bd).
The package is known as DN30, consisting of a 30B cylinder and outer PSP that is used for the carriage of uranium hexafluoride (UF6). The DN30 package is designed to transport UF6 with enrichment up to 5 wt.% U-235.
The previous UK Validation F/420/AF (Ab), and French base certificate, expired on 26 December 2023. The expiration of this approval coincided with a consignment of empty and "heeled" cylinders which has resulted in the "heeled" cylinders remaining at Seaforth dock and unable to be transported to the UUK Capenhurst nuclear licensed site.
This inspection was undertaken in support of the permissioning strategy documented in PR-01560.
The inspectors identified a significant non-compliance in the management and control of transport interfaces and further areas of improvement required to UUK's transport radiation risk assessment (RRA) for transporting DN30 packages and the emergency plan arising from the RRA.
Conclusion
Suitable and sufficient transport RRAs have not been undertaken by the carriers appointed by UUK as required by Regulation 8 of IRR17 and suitable emergency arrangements have not been made by the consignors and carriers as required by Schedule 2, Part 1 of CDG 2009.
ADR 4.1.9.1.8. requires ‘before each shipment of any package, it shall be ensured that all the requirements specified in the relevant provisions of ADR and in the applicable certificates of approval have been fulfilled. UUK and its carriers have not complied with this requirement.
Consequently, when acting as a consignor or agent to other consignors UUK has caused Class 7 dangerous goods to be transported in contravention of Regulation 5 of CDG 2009 and this contravention will be considered against ONR's enforcement guide (ONR-ENF-GD-006 Issue 5.2). Details of the decision and progress against addressing the contravention will be tracked under a Level 2 regulatory issue.