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 Road (ADR) and ADR 2019 was used during this inspection (www.unece.org).
The purpose of the remote inspection was to review Euro NDT’s arrangements associated with the road transport of radioactive material. ONR carried out this remote inspection via telephone with representatives from its Aberdeen site on 25 August 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Euro NDT 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 elements of its radiation risk assessment, restriction of exposure, designation of areas and local rules. A number of non-compliances were identified and discussed during the inspection, which included emergency plans under CDG.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Euro NDT to consider.
Euro NDT demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified three non-compliances with relevant legislation and suggested two improvements. These were all discussed during the inspection and a commitment obtained from Euro NDT to address them.
Euro NDT was given until 6 October 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 IIS Rating of AMBER is given, due to Euro NDT not meeting specific legal requirements and needing to improve some of its arrangements in order to comply with legal requirements, however these are not judged to prejudice overall safety.
Non-compliances will be managed through ONR’s Issues Management arrangements.