Transport inspection of High Technology Sources Limited
- Site: N/A
- IR number: 15-071
- Date: January 2016
- LC numbers: N/A
Purpose of intervention
The purpose of the inspection was to:
- Sample the adequacy of the arrangements for the transport of radioactive material, and compliance with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 of High Technology Sources Limited (HTSL).
- Develop ONR’s understanding of the management and emergency arrangements for carriage of Class 7 material following the acquisition of the company by James Fisher Nuclear Limited (JFNL) in 2015.
- Examine changes to arrangements in response to 2015 incident involving an excepted package being shipped with a dose rate slightly in excess of the required level (this incident did not result in any excess risk to the public or workers) and provide advice on the use of third party sources in Sentinel 880 containers.
- Inform the ONR Transport Inspection & Enforcement Sub-Programme’s near and medium term intervention strategy.
Interventions Carried Out by ONR
The inspection was conducted through a site visit to the office of HTSL, interviews with staff and documentary review.
The inspection was conducted against the requirements of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 SI 2009:1348 (CDG 09), an applicable provision of the Energy Act 2013, and one which requires carriage by road to be in accordance with the appropriate edition of a European Agreement known as ADR. The current edition is ADR 2015. In particular, although not exclusively, the inspection considered arrangements in respect of ADR 1.3 - Training, ADR 1.7.2 - Radiation Protection Programme, ADR 1.7.3 - Management System, ADR 1.8.3 - Safety Advisor, ADR 1.10 Transport Security, and CDG09 Regulation 24 - Radiological Emergencies.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A – not a System/Structure Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspection concluded that the current arrangements of HTSL concerning the safe carriage of radioactive material continue to be adequate.
HTSL to consider the following findings:
- The transition arrangements for roles and responsibilities from the previous directors to the new management structure under JFNL ownership requires substantial expansion and extension to ensure that current arrangements for safe carriage continue to be compliant with statutory requirements. Within the change management arrangements HTSL should consider defining roles, assigning responsibilities, identifying the competencies required for each role and how they may be attained and confirmed, and specifying handover arrangements to ensure continued compliance.
- HTSL intends to apply for membership of Radsafe from April 2016. HTSL should ensure that an adequate level of emergency response capability is maintained, especially in regard of their dual role as both carrier and consignor, considering that whilst Radsafe membership would supplement HTSL’s they would still need to maintain their own emergency arrangements to meet their duties as a consignor.
The inspectors were satisfied that these issues did not present a significant risk to workers or the public, so long as the current management and emergency arrangements remain in place and transition to new arrangements ensures the same level of compliance. The management committed to review the inspection findings and implement appropriate action. No formal regulatory action was considered necessary.
Conclusion of Intervention
The inspection found current arrangements to be Adequate for the purposes of ADR, and in compliance with the requirements of CDG09.