Executive summary
Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review Eckert & Ziegler Environmental Services Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Eckert & Ziegler Environmental Services Ltd (site) on 21/09/2022.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Non-nuclear) Appropriate management system
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR17
- Transport (Non-nuclear) Training
- Transport (Non-nuclear) Transport documentation
- Transport (Non-nuclear) Vehicle Requirements Part 8
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR
- Transport (Non-nuclear) Emergency arrangements
- Transport (Non-nuclear) Local rules Reg 18 IRR17
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17
- Transport (Non-nuclear) Security Plan
Key findings, inspector's Opinions and reasons for Judgements made
The inspector sampled the arrangements deployed by Eckert & Ziegler Environmental 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 purpose of the inspection was to review Eckert & Ziegler Environmental Services Ltd (EZE) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Didcot site on 21 Sept 2022.
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;
- suitable and sufficient emergency planning in accordance with REPPIR19
- 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;
- Equipment on Board – ADR 8.1.5.2; and
- a suitable and sufficient Management System – ADR 1.7.3.
The inspector sampled the arrangements deployed by EZE 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 management arrangements, vehicle equipment, transport documents, training and local rules. The inspector identified a number of non-compliances and discussed these during the inspection, which included updating of radiation risk assessment and emergency plans, testing/review of security plans.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for EZE to consider.
Conclusion of intervention
EZE 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 three non-compliances with relevant legislation and suggested one improvement. The inspector discussed these during the inspection and EZE gave a commitment to address them.
The inspector gave EZE until 2nd Nov 2022 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.
ONR will monitor the identified non-compliances through its Issues Management arrangements.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Eckert & Ziegler Environmental Services Ltd to consider.