Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review Breedon Trading Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Breedon Trading Ltd (Clatchard Quarry Site) on 19/01/2023.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Non-nuclear) Appropriate management system
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17
- Transport (Non-nuclear) Emergency arrangements
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17
- Transport (Non-nuclear) Local rules Reg 18 IRR17
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17
- Transport (Non-nuclear) Security Plan
- Transport (Non-nuclear) Training
- Transport (Non-nuclear) Sub contract arrangements
- Transport (Non-nuclear) Transport documentation
- Transport (Non-nuclear) Vehicle Requirements Part 8
Key findings, inspector's opinions and reasons for judgement made
The inspector sampled the arrangements deployed by Breedon Trading 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 significant number of non-compliances and discussed these during the inspection, which included Radiation Risk Assessment unsuitable, no DGSA appointed, Source contamination checks expired, inadequate management arrangements, no recorded driver training and missing vehicle equipment. As a result of these non-compliances the dutyholder has been issued with a Prohibition Notice.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Breedon Trading Ltd to consider.
Conclusion
The inspector gave Breedon Trading Ltd until 28/02/2023 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.