ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Rail (RID) and ONR regulated against RID 2019 during this inspection (www.unece.org).
The purpose of the inspection was to review ‘Direct Rail Services Ltd’s arrangements associated with the rail transport of radioactive material. ONR carried out this inspection of the Carlisle site remotely (via telephone) on 18 August 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Direct Rail Services 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. A number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP were identified including: appropriate registration; having RRA’s; having contingency plans for emergencies and training personnel in contingency plans.
A number of minor contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included some elements of the RRAs being inadequate and insufficient evidence to demonstrate full compliance with the emergency planning requirements under CDG.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for Direct Rail Services Ltd to consider.
Direct Rail Services Ltd demonstrated that for aspects of its operations it met the requirements of CDG, RID and IRR17.
Based on the inspection sample, the inspector identified two minor contraventions of administrative requirements against legislation and suggested one improvement. ONR discussed these non-compliances during the inspection and Direct Rail Services Ltd gave a commitment to address them.
ONR gave Direct Rail Services Ltd until 30 September 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an overall IIS Rating of GREEN was given to reflect that legal duties are complied with, although there were minor contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.