This inspection on the Inutec Ltd licensed nuclear site at Winfrith was undertaken to consider the findings of a pre-licencing readiness review of LC 5 and CDG 2009, reviewing progress with resolution of those findings together with an assessment of the adequacy of their current arrangements. This includes inspections of Licence Condition (LC) 5 and the Carriage of Dangerous Goods (CDG) and Use of Transportable Pressure Equipment Regulations 2009, including examining their arrangements for receipt and consignment of Class 7 materials.
During this inspection, I examined arrangements made to comply with the following: -
I found that Inutec Ltd was able to demonstrate compliance through its written arrangements made under LC 5 for the elements I inspected, and the implementation was demonstrated by the radioactive material transport responsible officer.
In my opinion Inutec Ltd demonstrated an adequate degree of compliance with CDG 2009 in respect of their consignment arrangements based on the evidence examined.
I identified a shortfall in Inutec Ltd’s compliance with CDG 2009 schedule 2 Radioactive Emergencies, in so far as they have not issued an emergency plan. In mitigation the plan is at an advanced stage of drafting and I was assured by the SSHEQ Director that it will be issued week commencing 18th March 2019.
ONR previously raised a regulatory issue No 6630 with 3 recommendations, only one of which has been satisfactorily completed.
During this intervention I identified several areas for improvement which require prompt action to address. The two most urgent relate to the draft emergency plan and ineffective action tracking and I have raised regulatory issues accordingly.
In my opinion the Licensee's arrangements made to comply with LC5 are adequate from the arrangements examined, and from the records reviewed.
It is my opinion that adequate arrangements are currently in place for compliance with CDG 2009 regulations, subject to formal issue of the transport emergency plan. Work is required to ensure that management system arrangements for compliance with CDG 2009 are further strengthened.