Executive summary
Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road and/or rail transport.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system - Rating: Green
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 - Rating: Amber
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR - Rating: Not rated
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 - Rating: Not rated
- Transport (Non-nuclear) Emergency arrangements - Rating: Amber
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements - Rating: Amber
- Transport (Non-nuclear) Local rules Reg 18 IRR17 - Rating: Amber
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 - Rating: Green
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 - Rating: Amber
- Transport (Non-nuclear) Security Plan - Rating: Amber
- Transport (Non-nuclear) Sub contract arrangements - Rating: Green
- Transport (Non-nuclear) Training - Rating: Green
- Transport (Non-nuclear) Transport documentation - Rating: Green
- Transport (Non-nuclear) Vehicle Requirements Part 8 - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
The inspector identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including suitable IRR17 registration, notification and consent, RPA appointment letter, transport documentation, appropriate package and labelling, appropriate management system and appropriate training.
The inspector identified several areas of non-compliance and discussed these during the inspection. These were the radiation risk assessment, contingency plans, emergency arrangements, local rules, and security arrangements. The inspector also identified several non-compliances in relation to radiological protection aspects regarding the in-transit store at the premises, whereby an enforcement letter has been issued.
Conclusion
The inspection findings were presented to James Fisher Nuclear Limited at the close of the inspection.
I judged an overall inspection rating of amber was appropriate for this inspection.
I adhered to ONR’s Enforcement Policy Statement, which in this instance was issue of an Enforcement Letter due to non-compliances in relation to the radiological protection aspects of the in-transit store. James Fisher Nuclear Limited are required to provide to ONR evidence that the identified non-compliances has been resolved by the 21st July 2023. The non-compliances will be tracked to completion via a level 3 regulatory issue.
James Fisher Nuclear Limited is required to provide to ONR either with evidence that the other five identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 14th July 2023. These non-compliances will be tracked to completion via a level 4 regulatory issue.