- Site: Transport Competent Authority
- IR number: 21-014
- Date: July 2021
- LC numbers: N/A
Executive summary
ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Goodfellow Cambridge’s (GC) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at GC’s Huntingdon premises listed above on 20th July 2021.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- suitable and sufficient Contingency Planning and/or Emergency Arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- adequate Security arrangements – ADR 1.10;
- a suitable and sufficient Management System – ADR 1.7.3.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by GC for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. The inspector identified a number of examples of GC meeting relevant good practice in reducing risk to levels that are ALARP, as a consignor of excepted packages. Good practice included having local rules; appropriately qualified radiation workers; contingency plans and security arrangements.
The inspector identified two non-compliances whereby GC’s radiation risk assessment only covered operations it did not specifically cover transport and its management system was not appropriate for transport.
During the inspection, the inspector also suggested one minor improvement to transport practices that would be prudent for GC to consider.
There was sufficient evidence for the inspector to rate the inspection as ‘Amber’ reflecting the fact that although some specific legal requirements were not met, there was no prejudice to overall nuclear safety or security objectives.
Conclusion of Intervention
GC demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified two non-compliances with relevant legislation and suggested one improvement. The inspector discussed these during the inspection and GC gave a commitment to address these.
For this intervention, the inspector gave an inspection rating of Amber as some specific legal requirements were not met.
The inspector gave GC until 13th August 2021 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
ONR will monitor the identified non-compliances through its Issues Management arrangements.