Executive summary
Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review Urenco UK’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Capenhurst Works (UUK) on 06/10/2022.
Subject(s) of inspection
The chosen sample included:
- Transport (Nuclear) 9 Radiation Protection Programme
- Transport (Non-nuclear) Emergency arrangements
- Transport (Nuclear) 7 Safe Carriage of Packages
Key findings, inspector's opinions and reasons for judgement made
The inspector sampled the arrangements deployed by Urenco UK 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.
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).
The purpose of the inspection was to review Urenco UK (UUK) Ltd’s arrangements specifically related to the use of the UX-30 package and the updated requirements introduced by the designer. ONR carried out this inspection at the Capenhurst site on 6 October 2022.
The chosen inspection sample included:
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- 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;
The inspector sampled the arrangements deployed by UUK for relating to the use of the UX-30 package in transport.
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. The inspector identified a number of minor non-compliances and discussed these during the inspection, which included the Radiation Risk Assessment required updating and re-issue, the emergency plan required updating and the pre-trabsport inspection checklist required re-issue.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for UUK to consider.
UUK 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 three improvements. The inspector discussed these during the inspection and UUK gave a commitment to address them.
The inspector gave UUK until 31 Oct 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 Urenco UK to consider.
Conclusion
The inspector gave Urenco UK until 31/10/2022 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.