Application for United Kingdom Approval of the GB/3516A

Title of document

Page 1 of 16

Transport of Radioactive Material in the United Kingdom using the GB/3516 Package Design

Application for United Kingdom Approval of the

GB/3516A and GB/3516C Package Design Variants for the Carriage of Low Enriched Uranium Oxide Material and Powder

(SVC4348529)

Project Assessment Report ONR-SDFW-PAR-17-047 Revision 0

16 May 2019

Report ONR-SDFW-PAR-17-047 CM9 Ref: 2017/366913

Office for Nuclear Regulation Page 2 of 16

© Office for Nuclear Regulation, 2019 If you wish to reuse this information visit www.onr.org.uk/copyright for details. Published 07/19 For published documents, the electronic copy on the ONR website remains the most current publicly available version and copying or printing renders this document uncontrolled.

http://www.onr.org.uk/copyright



EXECUTIVE SUMMARY Project Assessment Report for the Application for United Kingdom Approval of the GB/3516A and GB/3516C Package Design Variants for the Carriage of Low Enriched Uranium Oxide Material and Powder (SVC4348529)

This report summarises the basis of the regulatory decision by the Office for Nuclear Regulation (ONR) as the Competent Authority (CA) in Great Britain (GB) for the transport of Class 7 (radioactive material) dangerous goods, to issue certificate of approvals (CoA), GB/3516A/AF-96, GB/3516A/IF-96, GB/3516C/AF-96 and GB/3516C/IF-96, for the transport of the GB/3516A and GB/3516C packages by road, rail and sea in the United Kingdom (UK). Permission Requested

International Nuclear Services Limited (INS) has requested approval to transport low enriched uranium oxide in the GB/3516A and GB/3516C package design variants by road, rail and sea in the UK.

This request is made under the United Nations Economic Commission for Europe (UNECE) modal regulations ADR 2019 and RID 2019 (published by the Intergovernmental Organisation for International Carriage by Rail (OTIF)) for the transport of dangerous goods by road and rail and the International Maritime Dangerous Goods Code (IMDG) 2018. ADR and RID are implemented in GB law via ‘The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009’ (CDG) while IMDG is implemented in the UK by ‘The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997’. The modal regulations (ADR / RID / IMDG) are based on the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material, currently SSR-6 (2012 Edition) supported by advisory material in SSG-26. Background

There is an extant certificate of approval for the GB/3516A transport package design variant with an expiry date of end of August 2019. The fissile material mass loadings are dependent on enrichment in accordance with the following table.

Uranium Oxide Material Mass Limits for GB/3516A Transport Package

Enrichment wt% U-235/U (total)

Maximum Uranium Oxide Payload Mass (kg)

per inner pail per package

≤ 5.0 21.5 193.5

≤ 4.55 25.0 225.0

The GB/3516C package design variant is similar to the GB/3516A except that the payload is restricted to uranium oxide powder and its mass is increased by ~10%. The new fissile material mass loadings are again dependent on enrichment in accordance with the following table.

Uranium Oxide Powder Mass Limits for GB/3516C Transport Package




≤ 5.0 24.0 216.0

≤ 4.9 25.0 225.0

≤ 4.8 26.0 234.0

≤ 4.7 27.0 243.0



The uranium oxide is contained within nine pails, arranged on a 3x3 array as illustrated in Annex 1. In order to demonstrate that an increased uranium oxide payload in the GB/3516C design variant was safe, the criticality safety assessment made a number of new key assumptions:

Only uranium oxide powder will be transported in GB/3516C package.

The maximum bulk density of the powder will be no greater than 3.1g(UO2)/cm3.

Under normal conditions of transport, water will not enter the pails (the GB/3516A package approval assumes that the package fully floods under normal conditions of transport).

Assessment and Inspection Work Carried Out by ONR in Consideration of this Request

ONR carried out a programme of assessment of the dutyholder’s transport design safety report (DSR), its claims, arguments, supporting documentation and evidence. The assessment has been carried out by sampling a number of key areas of the DSR. These areas were chosen based on ONR inspectors’ judgement as to their importance to safety as well as any findings and outcomes from previous ONR assessments.

The ONR assessments covered criticality safety analysis, engineering, shielding and safety case requirements aspects of the package approval. The criticality safety assessment targeted the change in contents (increased uranium oxide mass) as well as the engineering related assumptions.

No inspection work was explicitly conducted in support of this application. However, regulatory confidence is drawn from recent inspections of both the consignor, Springfields Fuels Limited (SFL), March 2017 and the criticality safety case author, Sellafield Limited (SL), August 2016. Matters Arising from ONR's Work

There are no outstanding technical or regulatory matters that would challenge the DSR for the GB/3516A and GB/3516C package design variants and preclude the issue of the certificates of approval.

However, as part of their improvement programme, SFL has committed to a number of actions. Progress of these shall be monitored by the ONR site safety inspector via Level 4 project meetings. Conclusion

ONR is satisfied with the claims, arguments and evidence presented within the DSR as well as the supporting analyses and evidence for the GB/3516A and GB/3516C package design variants. ONR is therefore of the opinion that the DSR and subsequent restrictions placed on the certificates of approval demonstrate that the package can be transported safely and in compliance with the regulatory requirements. Recommendation

It is recommended that approval is granted to INS via the issue of the GB/3516A/AF-96, GB/3516A/IF-96, GB/3516C/AF-96 and GB/3516C/IF-96 certificates of approval for the UK transport of the GB/3516A and GB/3516C package design variants via road, rail and sea.



LIST OF ABBREVIATIONS

ADR European Agreement concerning the International Carriage of Dangerous Goods by Road

CA Competent Authority

CDG The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations

CoA Certificate of Approval

CSI Criticality Safety Index

DSR Design Safety Report

GB Great Britain

HOW2 (Office for Nuclear Regulation) Business Management System

IAEA International Atomic Energy Authority

ICAO International Civil Aviation Organization

IMDG International Maritime Dangerous Goods Code

IMO International Maritime Organization

INS International Nuclear Services Limited

keff Effective Neutron Multiplication Factor

ONR Office for Nuclear Regulation

OTIF Intergovernmental Organisation for International Carriage by Rail

PAR Project Assessment Report

RID Regulations concerning the International Carriage of Dangerous Goods by Rail

SDFW Sellafield, Decommissioning, Fuel & Waste

SFL Springfields Fuels Limited

SL Sellafield Limited

SSG (IAEA) Specific Safety Guide

SSR (IAEA) Specific Safety Requirements

TCA Transport Competent Authority

UK United Kingdom

UNECE United Nations Economic Commission for Europe

UO2 Uranium Oxide

wt% Percentage by weight



TABLE OF CONTENTS 1 PERMISSION REQUESTED ............................................................................................. 8 2 BACKGROUND ................................................................................................................. 8 3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN

CONSIDERATION OF THIS REQUEST ............................................................................ 9 3.1 Criticality Safety Assessment .................................................................................... 9 3.2 Engineering Assessment ......................................................................................... 10 3.3 Shielding Assessment ............................................................................................. 11 3.4 Safety Case Requirements Assessment .................................................................. 11 3.5 Inspection Work ....................................................................................................... 12

4 MATTERS ARISING FROM ONR’S WORK ..................................................................... 12 4.1 Inspection Recommendations ................................................................................. 12

5 CONCLUSIONS .............................................................................................................. 12 6 RECOMMENDATIONS .................................................................................................... 13 7 REFERENCES ................................................................................................................ 14 Tables Table 1: Uranium Oxide Material Mass Limits for GB/3516A Transport Package Table 2: Uranium Oxide Powder Mass Limits for GB/3516C Transport Package Annexes Annex 1: GB/3516 Transport Package Illustration



1 PERMISSION REQUESTED

1. International Nuclear Services Limited (INS), submitted an application [1] and corresponding design safety report (DSR) [2] in March 2019 requesting GB competent authority approval of the GB/3516A and GB/3516C package design variants for the carriage of low enriched uranium oxide by road, rail and sea transport in the United Kingdom (UK). An illustration of the package is provided in Annex 1.

2 BACKGROUND

2. The Office for Nuclear Regulation (ONR) is the GB Competent Authority (CA) for the civil carriage of UN Class 7 (radioactive material) goods in Great Britain by road, rail and inland waterway (limited provisions only in UK). The TCA (Transport Competent Authority) is a statutory duty and function given to ONR in law through ‘The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations’ (CDG) 2009 [3]. These regulations transpose into UK law the European modal requirements (ADR [4] and RID [5]) for road and rail transport and limited aspects of ADN for inland waterway transport. For sea transport, the International Maritime Dangerous Goods (IMDG) Code [6] is implemented in the UK by ‘The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997’. The modal regulations (ADR / RID / IMDG) are based on the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material, currently SSR-6 (2012 Edition) [7] supported by advisory material in SSG-26 [8].

3. ONR also acts on behalf of the other UK CAs with respect to the issuing of transport approvals namely: the Secretary of State for Transport and the Maritime and Coastguard Agency for transport in UK waters; the Civil Aviation Authority for air transport; and the Department of Agriculture, Environment and Rural Affairs Northern Ireland for road transport in that part of the UK.

4. There are two extant certificates of approval for the GB/3516 design of transport packages. One for the GB/3516B design variant [9] for the carriage of uranic residues and one for the GB/3516A design variant [10, 11, 12].

5. The fissile mass limits for GB/3516A transport package design variant are presented in Table 1.

Table 1 – Uranium Oxide Material Mass Limits for GB/3516A Transport Package




≤ 5.0 21.5 193.5

≤ 4.55 25.0 225.0

6. The payloads requested for transport within the GB/3516C package design variant are presented in the Table 2. Although they are approximately 10% greater than those allowed by the existing GB/3516A certificate of approval [10, 11, 12], the payload is restricted to uranium oxide powder.



Table 2 – Uranium Oxide Powder Mass Limits for GB/3516C Transport Package




≤ 5.0 24.0 216.0

≤ 4.9 25.0 225.0

≤ 4.8 26.0 234.0

≤ 4.7 27.0 243.0

7. The GB/3516 design of package has received TCA approval for almost two decades

with a significant amount of reassessment carried out over the last seven years; a summary of the recent approval history is presented in the pre-job brief [13].

3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST

8. ONR has carried out a programme of work that involved the assessment of INS’s design safety report (DSR) [2] for the GB/3516A and GB/3516C package design variants regarding the claims, arguments, supporting documentation and evidence. The assessments were undertaken in line with the relevant requirements of the ONR HOW2 Business Management System (BMS) [14] and its associated guidance.

9. The assessment involved criticality safety, engineering, shielding as well as a safety case requirements review. These areas were assessed because of their importance to package safety during transport. Due to the similarity with the recently approved GB/3516A package design [15], the scope of assessment was focused towards the changes that occur with the GB/3516C package approval. The level of assessment reporting was agreed in the decision record [16].

10. The various issues identified and the satisfactory responses received are detailed in the Q1 assessment review form [17] as well as the assessments for criticality safety [18], shielding [19, 20], engineering [21] and the safety case requirements [22]. The key findings and conclusions for each assessment discipline are summarised below.

3.1 Criticality Safety Assessment

11. The GB/3516 package design has been assessed from a criticality safety perspective a number of times over the last seven years. A good understanding of the nuclear criticality physics of the system has been therefore been gained.

12. The uranium oxide payloads currently approved for the GB/3516A package design [10, 11, 12] are presented in Table 1.

13. The GB/3516C package is similar to the GB/3516A design except that the requested fissile mass payloads are approximately 10% greater, as indicated in Table 2. Only uranium oxide powder is allowed to be transported in the GB/3516C package design whereas uranium oxide of any form is allowed within the GB/3516A package.

14. In order to increase the uranium oxide package mass loadings in the GB/3516C transport package application to those presented in Table 1 for the GB/3516A package design, the dutyholder has made the following assumptions in their criticality safety assessment [23]:

Only uranium oxide powder will be transported in the GB/3516C package.



The bulk density of the uranium oxide powder will be no greater than 3.1g(UO2)/cm3.

Water will not enter the pails of the GB/3516C package under normal conditions of transport, however a uranium oxide powder moisture content of 20wt% is assumed. The GB/3516A package design assumes that the pails can fully flood.

15. The dutyholder’s criticality safety criterion is keff + 3σ ≤ 0.95 with a criticality safety index (CSI) of 1.66. This allows 30 (N) packages to be transported in a consignment. To justify this, 150 (5N) packages are modelled in the normal condition calculations and 60 (2N) packages under accident conditions.

16. A number of Q1 questions were raised with the dutyholder [17] on their GB/3516A [24] and GB/3516C [23] criticality safety reports. These related to the effect that temperature could have on criticality safety, the package orientation and water ingress under normal conditions of transport. These questions were satisfactorily addressed in the memoranda presented in [25, 26, 27, 28].

17. Appropriate assumptions have been included as fissile material restrictions in the GB/3516C certificates of approval [29, 30]. The GB/3516A certificates of approval are presented in [31, 32].

18. Although the GB/3516C criticality safety report [23] pessimistically assumes a uranium oxide powder moisture content of 20wt%, the dutyholder has advised [33] that a moisture limit of 0.4wt% should be stated in the certificate of approval so that there is consistency with the manufacturing specification for the uranium oxide powder packed into the GB/3516 package.

19. On the basis of the assessment carried out [18], the subsequent evidence provided by the dutyholder [25, 26, 27, 28] and the restrictions included within the certificates of approval [29, 30, 31, 32] it is judged that adequate criticality safety cases [23, 24] for both the GB/3516A and GB/3516C transport packages have been presented by the dutyholder to provide satisfactory evidence that the relevant regulatory requirements of the IAEA Transport Regulations, SSR-6 [7] have been met.

3.2 Engineering Assessment

20. A full engineering assessment of the DSR has not been carried out due to the similarity of the GB/3516C package design to that of the GB/3516A which was subject to a full regulatory assessment in 2013 and led to the issue of the current certificate of approval for the GB/3516A package design [10, 11, 12]. The assessment concluded that the design meets the regulatory requirements of SSR-6 [7] for a Type AF-96 transport package.

21. The current engineering assessment [21] has therefore taken credit for the work carried out for the GB/3516A package design and has focussed on those areas not covered by the previous review.

22. The Q1 questions raised with the dutyholder [17] related to i) the package tie down arrangements, ii) confirmation that loss of containment did not occur due to excessive pail pressures following impact and iii) confirmation that the pail would not allow the ingress of water during normal conditions and the release of fissile material during accident conditions of transport.

23. Although the assessor was satisfied with the responses to these Q1 questions [21], an amber assessment rating has been assigned to the ONR engineering assessment with a number of future actions recommended:



Carry out a package design review to provide confidence in the reliable delivery of the safety function of each pail seal application under normal and accident conditions of transport.

Implement enhanced pail seal examinations in accordance with relevant good practice.

Limit the number of times a pail seal can be used.

Carry out regular testing of the pail seal functionality, on a statistical sample of packages, in accordance with relevant good practice.

Update the DSR to reflect the current seal status by removing reference to black seal type 06596 from the DSR, pail drawing and plant operating documents. It is noted that reference to black seals has now been removed from the DSR [2]. Confirmation has also been received that all black seals have been removed from the powder packing plant and destroyed [34].

Update the DSR to clarify that the primary water seal is that of the pail rather than the package with appropriate justification.

24. The dutyholder has acknowledged the above actions [35] and committed to addressing them in an agreed timescale.

25. ONR is therefore content that an adequate engineering case has been presented by the dutyholder and that the relevant regulatory requirements of SSR-6 [7] have been met.

3.3 Shielding Assessment

26. The dutyholder’s shielding analysis for the GB/3516C [36] is similar to that which was presented in support of their GB/3516A package approval [37]. An ONR shielding assessment [20] was originally carried out in November 2015 and found that it adequately demonstrated that the package would meet the regulatory dose limits following regulatory routine, normal and accident conditions of transport.

27. The ONR shielding assessor has reviewed this previous assessment [20] and the updated shielding documentation [36] and concludes that there have been no significant changes that would invalidate the previously presented conclusions [19].

28. On the basis of the ONR assessments carried out [19, 20], it is judged that an adequate shielding assessment [36] has been presented by the dutyholder to provide satisfactory evidence that the relevant regulatory requirements of SSR-6 [7] have been met.

3.4 Safety Case Requirements Assessment

29. The composition of the NS-4-FR neutron absorbing resin between the nine inner pails within the GB/3516A and GB/3516C packages is important for criticality safety with the key parameters being:

The boron carbide (B4C) content will be at least 1.444wt%,

The hydrogen content will be at least 4.93wt% and

The density of the NS-4-FR resin will be at least 1.58g/cm3. 30. As these parameters are important from a criticality safety perspective, the engineering

drawings for the GB/3516 transport package [2] include this information. Section 1.12(b) of the certificates of approval [29, 30, 31, 32] note that the NS-4-FR resin forms part of the confinement system and has the composition listed above.



31. ONR has witnessed an enhanced inspection procedure for pail filling and closing. Together with the process change to replace the seals at least every three years, it is considered that these arrangements reduce the likelihood of future pail seal misalignment. Subsequent monitoring over the last six months indicates that there has been no misalignment reoccurrence. It is advised that when pail filling process line 2 is operational, these procedures are inspected.

32. From an operational perspective, it is noted that the transport of the GB/3516A and GB/3516C packages is contingent upon oxide instruction OFC/SO/C601 for internal powder packing being in place and available with step 2 of WES No: 06 updated to reflect the oxide mass limits presented in Tables 1 and 2.

33. Based upon the above, the safety case requirements assessor concluded [22] that the GB/3516 DSR, together with the additional documentary evidence provided by INS, and restrictions placed within the certificates of approval [29, 30, 31, 32], demonstrate that the GB/3516A and GB/3516C package designs meet the regulatory requirements of SSR-6 [7].

3.5 Inspection Work

34. No inspection work was explicitly conducted in support of this application. However, regulatory confidence is drawn from the recent inspections of both the dutyholder, Springfields Fuels Limited (SFL), March 2017 [38] and the criticality safety case author, Sellafield Limited (SL), August 2016 [39].

4 MATTERS ARISING FROM ONR’S WORK

35. There are no outstanding technical or regulatory matters that would challenge the safety of the GB/3516A and GB/3516C package design variants and preclude the issue of the GB/3516A/AF-96 [31], GB/3516A/IF-96 [32], GB/3516C/AF-96 [29] and GB/3516C/IF-96 [30] certificates of approval.

36. However, as part of their improvement programme, SFL has committed to addressing a number of actions [35]. Progress of these shall be monitored by the ONR site safety inspector via Level 4 project meetings [40].

37. Some of these actions have led to the design safety report being revised after the completion of the ONR assessment work. However, the changes have been reviewed [41] and it is considered that they do not invalidate the conclusions presented by the ONR assessment disciplines above.

4.1 Inspection Recommendations

38. The ONR site safety inspector for SFL has been advised that once process line 2 is operational, the pail filling and closing procedure should be inspected [42].

5 CONCLUSIONS

39. This report presents the basis of ONR’s regulatory decision following the assessment of the application for competent authority approval of the GB/3516A and GB/3516C transport package designs.

40. Based on this assessment, ONR is satisfied with the claims, arguments and evidence presented within the DSR, supporting analyses and evidence for the GB/3516A and GB/3516C package variants. The totality of the package safety case and subsequent restrictions placed in the certificates of approval demonstrate that the package can be transported safely and in compliance with regulatory requirements.



6 RECOMMENDATIONS

41. It is recommended that approval is granted to INS via the issue of the GB/3516A/AF-96 [31], GB/3516A/IF-96 [32], GB/3516C/AF-96 [29] and GB/3516C/IF-96 [30] certificates of approval for the UK transport of the GB/3516A and GB/3516C package design variants by road, rail and sea.



7 REFERENCES

[1] International Nuclear Services Ltd. Letter Reference 19053516.01 “Application for UK Certificate of Approval of Package Design for the Carriage of Radioactive Materials – GB/3516A/AF-96, GB/3516A/IF-96, GB/3516C/AF-96 and GB/3516C/IF-96”, 14th May 2019. CM9 2019/139376

[2] Westinghouse Transport Report No. 186 Issue 4 “Design Safety Report in Support of Competent Authority Approval for Fuel Transport Container Package Design No. 3516A & 3516C Type AF & Type IF”, 14th May 2019. CM9 2019/139376

[3] The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009, SI 2009 No1348 as amended by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) Regulations 2011, SI 2011 No 1885

[4] United Nations Economic Commission for Europe (UNECE), European Agreement concerning the International Carriage of Dangerous Good by Road (ADR) 2019 Edition

[5] Intergovernmental Organisation for International Carriage by Rail (OTIF), Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) 2019 Edition

[6] International Maritime Organization (IMO), International Maritime Dangerous Goods (IMDG) Code 2018 Edition incorporating Amendment 39-18

[7] IAEA Safety Standards for Protecting People and the Environment, Specific Safety Requirements No. SSR-6 “Regulations for the Safe Transport of Radioactive Material”, 2012 Edition (www-pub.iaea.org/MTCD/publications/PDF/Pub1570_web.pdf)

[8] IAEA Safety Standards for Protecting People and the Environment, Specific Safety Guide No. SSG-26 “Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material”, 2012 Edition. (www-pub.iaea.org/MTCD/publications/PDF/Pub1586web-99435183.pdf)

[9] GB/3516B/AF-96 Revision 0 issued 13th December 2016 (expires 31st December 2021). CM9 2016/374931

[10] GB/3516A/AF-96 Issue 3 issued 28th February 2014 (expires 31st August 2018). CM9 2014/28709

[11] ONR Letter ‘Application for Short Term Extension (12 Months) of Certificate of Approval Package Design GB/3516A/AF-96 for the Carriage of Radioactive Material’, 21st August 2018. CM9 2018/258448

[12] ONR Letter ‘Short Term Extension (12 Months) of Certificate of Approval Package Design GB/3516A/AF-96 for the Carriage of Radioactive Material’, 6th March 2019. CM9 2019/67598

[13] Pre-Job Brief for the Assessment of the GB/3516C Transport Package as applied for UK Approval by International Nuclear Services (SVC4348529), 21st September 2017. CM9 2017/194979

[14] HOW2 – ONR Business Management System

[15] Transport Approval Assessment Decision Record ONR-SDFW-DR-18-020, GB/3516A Package Approval for the Transport of Low Enriched Uranium Oxide Fissile Material, Twelve Month Extension of Approval for GB/3516A Package Design, 21st August 2018. CM9 2018/258446

http://www-pub.iaea.org/MTCD/publications/PDF/Pub1570_web.pdf

http://www-pub.iaea.org/MTCD/publications/PDF/Pub1586web-99435183.pdf



[16] ONR-SDFW-DR-17-081 Revision 0 “Assessment Scope Decision Record for the Assessment / Approval of GB/3516C Package Design”, 28th March 2018. CM9 2017/195873

[17] Q1 Assessment Review for the GB/3516C Transport Package as Applied for UK Approval by International Nuclear Services (SVC4348529), 24th April 2019. CM9 2017/195877

[18] ONR-SDFW-AR-17-088 Revision 0 “Criticality Safety Assessment for the Transport of Low Enriched Uranium Oxide in the GB/3516A and GB/3516C Package Designs”, 7th May 2019. CM9 2017/365753

[19] “Shielding Assessment File Note for GB/3516A and GB/3516C Package Approvals”, 4th April 2019. CM9 2019/100869

[20] ONR Technical Assessment “GB/3516A (SVC4268501) Radiation Shielding Technical Assessment”, 6th November 2015. CM9 2015/227389

[21] ONR-SDFW-AR-19-007 Revision 0 “Mechanical Engineering Assessment of GB/3516A/AF-96, GB/3516A/IF-96, GB/3516C/AF-96 and GB/3516C/IF-96 Package”, 15th May 2019. CM9 2019/124021

[22] ONR-SDFW-AR-17-105 Revision 0D “Safety Case Requirements Assessment for the UK Approval for the Package, GB/3516C/AF-96, GB/3516C/IF-96, GB/3516A/AF-96 and GB/3516A/IF-96”, 15th May 2019. CM9 2017/450423

[23] Sellafield Ltd Report 3516C/CR01 Issue 01 “Response to the Department for Transport’s Applicants Guide for Transport of Uranium Oxide in the 3516C Transport Package, Part III: Additional Design Information Required for Fissile Materials”, 7th April 2017. CM9 2019/124176

[24] Sellafield Ltd Report 3516A/CR01 Issue 04 “Response to the Department for Transport Guide for Transport of Uranium Oxide in the 3516A Transport Package, Part 3: Additional Design Information Required for Fissile Materials”, 1st August 2012. CM9 2019/81203

[25] Sellafield Ltd Criticality Design Safety Memorandum CDSA/DESM/0813/1911, 3516A/CR01/M01 (Issue 01) “Criticality Safety Assessment of 3516A Package for Uranium Oxide – Consideration of Updated NS-4-FR Material Composition”, August 2013. CM9 2013/305275

[26] Sellafield Ltd Criticality Design Safety Memorandum CDSA/DESM/0518/2368 “Criticality Safety Assessment for 3516A Package for Uranium Oxide – Temperature NCT Stacking Arrangement and NCT Water Ingress”, July 2018. CM9 2018/240516

[27] Sellafield Ltd Criticality Design Safety Memorandum CDSA/DESM/0817/2303, (3516C/CR01/M01) “3516C Transport Package – Response to ONR Criticality Assessment #1 Technical Review”, 17th August 2017. CM9 2017/332599

[28] Sellafield Ltd Criticality Design Safety Memorandum CDSA/DESM/0917/2312, (3516C/CR01/M02) “3516C Transport Package – Response to ONR Criticality Assessment #1 Technical Review”, 25th September 2017. CM9 2017/361676

[29] GB/3516C/AF-96 (Rev.0) Certificate of Approval of Package Design for the Carriage of Radioactive Material. CM9 2017/365754

[30] GB/3516C/IF-96 (Rev.0) Certificate of Approval of Package Design for the Carriage of Radioactive Material. CM9 2018/103321



[31] GB/3516A/AF-96 (Rev.4) Certificate of Approval of Package Design for the Carriage of Radioactive Material. CM9 2019/63241

[32] GB/3516A/IF-96 (Rev.2) Certificate of Approval of Package Design for the Carriage of Radioactive Material. CM9 2019/63270

[33] Westinghouse Document P&PE PRC (19) 1418 Issue 1 “Type 3516 Container – Response to ONR Queries”, 2nd April 2019. CM9 2019/99584

[34] Westinghouse Email “Confirmation that Reference to Black Seals Removed from All GB/3516 Documentation and Any Black Seals in Powder Packing Plant Destroyed”, 29th April 2019. CM9 2019/124277

[35] Westinghouse Letter TOONR Transport 26_19 “Note from Springfields Fuels Limited Regarding the Type 3516 Transport Package Relicensing”, 9th May 2019. CM9 2019/135531

[36] Sellafield Ltd CDSA Design Safety Memorandum CDSA/DESM/0812/1796 Rev 1 “Shielding Analysis in Transporting UO2 in the 3516 Package”, 2nd July 2015. CM9 2017/156811

[37] Sellafield Ltd CDSA Design Safety Memorandum CDSA/DESM/0812/1796 Rev 0 “Shielding Analysis in Transporting UO2 in the 3516 Package”, 15th August 2012. CM9 2014/455412

[38] ONR Intervention Record ONR-COP-IR-16-067 “Springfield Fuels Ltd (Westinghouse Electric Company LLC), Compliance Inspection of Consigner/Carrier of Radioactive Material”, 16th March 2017. CM9 2017/111471

[39] ONR Intervention Record ONR-COP-IR-16-36 “Inspection of Use of Criticality Safety Computer Code MONK”, 24th August 2016. CM9 2016/348414

[40] Email from ONR Site Safety Inspector Confirming that Springfields Fuels Limited Improvement Programme will be Monitored via Level 4 Project Meetings, 7th May 2019. CM9 2019/131891

[41] Email from ONR GB/3516 Project Inspector Confirming that Conclusions of ONR Package Approval Assessments Remain Valid Following Revision of Westinghouse Design Safety Report to Issue 4, 14th May 2019. CM9 2019/139386

[42] Email to ONR Site Safety Inspector for Springfields Fuels Limited Requesting that Pail Filling and Closing Procedure of Process Line 2 should be Inspected Once Operational, 13th May 2019. CM9 2019/137890



Annex 1 - GB/3516 Transport Package Illustration

Nominal dimensions of 3516 container: 1062mm square plan x 908mm high. Maximum authorised gross weight: 693kg

Documents

Application for United Kingdom Approval of the GB/3516A