MOPDT MODIFICATION SYSTEM: THE ONLY UK COMPANY ABLE TO SELF APPROVE CATEGORY C MODIFICATIONS

The Magnox Operating Programme Delivery Team (MOPDT) are responsible for the safe delivery of irradiated fuel from the remaining fuelled Magnox Ltd sites in the UK and the Dounreay site (Scotland) to the Sellafield reprocessing facility. The fuel is transported in a fleet of 42 Type B(M) cuboidal packages referred to as M2 flasks, the transport of which is regulated by the Office of Nuclear Regulation, Radioactive Material Transport (ONR-RMT) referred to in this paper as RMT. Before December 2010 MOPDT was required to submit all changes to the package design (excluding typographical changes) to the RMT for approval. Since this date the RMT has permitted MOPDT to self approve minor changes to the package and/or package design application not primarily affecting package safety, known as a Category C modification. Magnox are currently the only UK applicant able to do this. This paper looks at how this has been achieved using a formal procedure for initiating, assessing and approving modifications structured by a Management Control Procedure (MCP). This ensures any modifications adhere to the requirements set out in the ‘Carriage of Dangerous Good and Use of Transportable Pressure Equipment Regulations’ and provides a means of compliance with the Department for Transport Guide to an Application for the UK Competent Authority Approval of Radioactive Material in Transport. The modification review committee draws on experienced personnel from other areas of Magnox Ltd as well as transport safety case experience, reviews, challenges and categorises the changes to design. The MCP comprises a suite of forms which ensures the correct information is presented, considered and recorded. The benefits of this include better sharing of information between Magnox Ltd and RMT, a higher standard of modification submissions, a more structured approach to the completion of submissions and allows the regulator to focus resource on higher priority/category applications and submissions. Based on the successful implementation process proposals are being drawn to allow self approval of higher category modifications.