Executive summary
Date(s) of inspection:
- September 2023
Aim of inspection
The Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations (CDG) 2009 requires a dutyholder’s transport emergency plan to be reviewed, tested, and revised as required at intervals not exceeding three years.
The aim of this inspection was to observe EDF Nuclear Generation Limited’s implementation of a test of its Emergency Plan during Exercise Burgundy. This was to provide regulatory confidence that it had taken reasonable steps to arrange for all those with a role in the emergency plan to participate in the test to such extent necessary to ensure that the test is effective
Subject(s) of inspection
- Transport (Nuclear) 11 Emergency Planning and Testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The Carriage of Dangerous Goods and Transportable Pressure Equipment (CDG) Regulations 2009 requires a duty holder’s transport emergency plan to be reviewed, tested, and revised as required at intervals not exceeding three years.
The aim of this inspection was to observe EDF NGL’s implementation of a test of its Emergency Plan during Exercise Burgundy, to provide regulatory confidence that it had taken reasonable steps to arrange for all those with a role in the emergency plan to participate in the test to such extent necessary to ensure that the test is effective.
Conclusion
The exercise exposed a number of learning points, however I consider that this exercise has met the requirement for the dutyholder (HPB) to take reasonable steps to arrange for all those with a role in the emergency plan to participate in the test to such extent necessary to ensure that the test is effective.
The CESC did not appear to have the appropriate personnel, supporting documentation or training to effectively manage a transport emergency response. The exercise also highlighted deficiencies in EDF NGL’s radiation risk assessments, which resulted in EDF NGL being unable to develop a credible scenario for the exercise that related to identified radiation emergencies within its Emergency Handbook. I consider these to be shortfalls within EDF NGL’s corporate arrangements, rather than a deficiency of HPB.
I do not consider that it would be appropriate to consider these shortfalls when considering the adequacy of the dutyholder’s implementation of it’s transport emergency plan, as the dutyholder for this exercise was Hinkley Point B. Especially as HPB have recognised the shortfall relating to training within the ECC, and this is being managed on a local level by ONR’s HPB Site Inspector. However, recognising the significance of the corporate shortfalls, I have raised a regulatory issue (RI-11828) to ensure these are resolved.
I therefore assign a rating of Green – No Formal Action to the dutyholder.