Date(s) of inspection:
- May 2023
Aim of inspection
The aim of this inspection was to satisfy ONR that refurbishment is being undertaken adequately on the GB/2834 package, in accordance with an established management system, and that modifications are appropriately controlled and recorded, following shortfalls identified during an inspection of the refurbishment facility in August 2022, to allow entry of the refurbished A2 flasks into the operational fleet.
A Regulatory Issue (RI-11022) highlighted shortfalls with data verification, and the inspection report raised areas which did not meet regulatory expectations with regards flask painting and foreign material exclusion (FME). This inspection followed up on these areas to ensure Regulatory confidence in the ability of EDF Energy to ensure the flasks are refurbished in line with the requirements of the safety case, which includes the Package Design Safety Report (PDSR) and Package Operation and Maintenance Manual (POMM).
Subject(s) of inspection
- Transport (Nuclear) 1 Management Systems – Rating: Green
- Transport (Nuclear) 4 Package Modification Control – Rating: Green
- Transport (Nuclear) 5 Package Maintenance and Operation – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
EDF Energy Nuclear Generation Limited has applied for a modification (N240) to the Mk A2 AGR Transport Flask (Design No. 2834), hereafter called the A2 flask, package design certificates for transport by road and rail within the United Kingdom, for the refurbishment and entry into operational service of 15 A2 flasks.
The A2 flask (variants A-E) is used to carry irradiated Advanced Gas-cooled Reactor (AGR) fuel between EDF Nuclear Generation Limited’s AGR nuclear power stations and the Sellafield Nuclear Licensed site. The A2 flask is categorised as a Type B(M) package. EDF Nuclear Generation Limited proposes to introduce 15 A2 flasks that have never been in operational service but have been placed in storage as strategic spares across the United Kingdom following manufacture in the 1990s.
EDF Energy Nuclear Generation Limited has contracted the task of refurbishing the A2 flasks to two organisations (Altrad Babcock and Sellafield Ltd). This report presents the findings of my inspection of the implementation of EDF Nuclear Generation Limited’s arrangements at the Altrad-Babcock refurbishment facility.
I inspected the records produced and held by Altrad Babcock, and the facility where refurbishment is being undertaken. The facility was previously inspected in August 2022, and shortfalls were identified with data verification and training of operators. Regulatory observations were also raised around painting of the A2 flasks and foreign material exclusion.
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 Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) 2021. I undertook a physical inspection of the maintenance facility and further inspection of the records associated with the refurbishment.
I undertook a desktop inspection and a facility walkdown. I discussed the open Regulatory Issue (11022) action, painting, foreign material exclusion and followed the documentation record for a specific flask (E117). I was content that foreign material exclusion was being adequately managed, and that defects were being recorded and verified appropriately. I was content that the shortfalls identified during the previous inspection were no longer valid, and that positive improvements had been made in the area of defect recording and verification. I observed the inspection data from the painting records, and was content that the painting process was adequately controlled on site. However, the paint requirements within the safety case documentation deviated slightly from those noted in the operational documentation. I was informed by EDF NGL that the paint specification was used by Sellafield Ltd on the existing fleet, and the EDF documentation had not been updated to reflect current practice. I consider this to be a shortfall against regulatory expectations, however I do not consider it to be significant to nuclear safety as the paint is being applied in line with good practice. I have raised a Regulatory Issue to address the shortfall.
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 Altrad Babcock. I consider that significant positive improvements have been made regarding the verification of defects and I am content to close the remaining action associated with Regulatory Issue RI-11022. I am content that foreign material exclusion is being appropriately managed, and consider the development of 3D printed FME caps to be innovative.
I am content that the flasks are being painted in line with relevant good practice, reflecting that which is currently done to the operational fleet. However, I am not content that the current EDF parent documentation reflects this good practice. I do not consider this to be a significant nuclear safety issue, as the flasks are being painted in line with RGP. I consider this to be a legacy documentational shortfall which can be rectified during the next routine update to the package design safety assessment and package operation and maintenance manual.
I have assigned a rating of Green – No Formal Action for this inspection.