- Site: Transport Competent Authority
- IR number: 21-023
- Date: September 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 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 Glacier Inspection Services Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection on 13 September 2021 at the local office at Methil Business Park, the Fife Energy Park Site where the transport packages, vehicles, transport documentation etc. are located.
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 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, 1.10.2, 8.2 and 8.5;
- adequate safety advice – ADR 1.8.3 and IRR17 regulation 14;
- marking, labelling and placarding of vehicles – ADR 5.2 and 5.3;
- adequate transport documentation – ADR 5.4;
- adequate security arrangements – ADR 1.10;
- documents to be carried on the transport unit – ADR 8.1.2
- equipment on board – ADR 8.1.5.2; and
- 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 Glacier Inspection Services Ltd 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 the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including suitable DGSA/RPA/RPS cover, appropriate dosimetry, a structured approach to training and in general a good standard of local rules and risk assessments. The inspector identified a number of non-compliances and discussed these during the inspection, which included enhancements to and testing of emergency arrangements, clarification of dose investigation levels, management of package design certification and operating and maintenance instructions.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Glacier Inspection Services Ltd to consider.
Conclusion of Intervention
Glacier Inspection Services Ltd demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified five non-compliances with relevant legislation and suggested two improvements. The inspector discussed these during the inspection and Glacier Inspection Services Ltd gave a commitment to address them.
The inspector gave Glacier Inspection Services Ltd until 1 November 2021 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector assigned an inspection rating of GREEN, due to there being relatively minor, deficiencies in compliance arrangements.
All non-compliances will be managed through ONR’s Issues Management arrangements.