Office for Nuclear Regulation

Transport – Inspection ID: 22-014

  • Site: Transport Competent Authority
  • IR number: 22-014
  • Date: August 2022
  • LC numbers: N/A

Executive summary

Purpose of intervention

This report records the findings of my inspection of EDF Nuclear Generation Limited’s management arrangements for the refurbishment of the Mk A2 AGR Transport Flask (Design No. 2834) package (hereafter referred to as the A2 Flask). The refurbishment is being undertaken by Doosan Babcock on behalf of EDF Nuclear Generation Limited; to inspect the implementation of EDF Nuclear Generation Limited’s arrangements. I inspected the records produced and held by Doosan Babcock, and the facility where refurbishment is being undertaken.

The purpose of the inspection was to satisfy ONR that refurbishment is being undertaken adequately on the A2 flask, in accordance with an established management system, and that modifications are appropriately controlled and recorded. It was also to provide confidence in Doosan Babcock’s ability to meet the projected flask throughput numbers to support the projected increase in flask demand for operating and defueling AGR (Advanced Gas-cooled Reactor) stations.

Interventions carried out by ONR

I carried out this inspection against the requirements of The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended) and the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) 2021.

Prior to the inspection I undertook a desktop inspection of documentation provided. This was followed by a physical inspection of the maintenance facility and further inspection of the records associated with the refurbishment.

Key findings, inspector’s opinions and reasons for judgements made

I undertook both a desktop inspection and facility walkdown. I inspected the arrangements for ensuring adequate traceability of parts and spares during the refurbishment, and the procedures in place to control defects and modifications and had no concerns. I discussed the Intelligent Customer Oversight undertaken by EDF Nuclear Generation Limited during the refurbishment.

I have reservations regarding the accuracy and level of checking of records, and the understanding of the safety significance of the A2 flask by both the Doosan Babcock operators, and the third-party inspector employed by EDF Nuclear Generation Limited. I have raised a Level 4 Issue to address these shortfalls, which I do not consider to have significant safety consequences. I consider this to be proportionate given limited refurbishment activities are underway and EDF Nuclear Generation Limited has committed to address my concerns.

Conclusion of intervention

I am satisfied that EDF Nuclear Generation Limited have a robust, established management system in place for refurbishment of the A2 flask, and that it is being implemented adequately by Doosan Babcock. I am content that spares are being managed appropriately, in line with EDF Nuclear Generation Limited’s approved management system, and that flask modifications are appropriately controlled.

Overall, other than the identified shortfalls, I am content that EDF Nuclear Generation Limited is retaining appropriate oversight and management of Doosan Babcock’s activities.  I consider the shortfalls I identified to be relatively minor and do not compromise nuclear safety.

I have assigned a rating of Green – No Formal Action for this inspection.