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). 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). In this inspection additional reference was made to the relevant good practice defined in IAEA SSG-26.
The purpose of the inspection was to review Gilligan Engineering Services Ltd Type A package deign against the requirements of ADR. ONR carried out this inspection remotely via telephone on 29 September 2020.
The chosen inspection sample included:
The inspector sampled the documentation provided by Gilligan Engineering Services Ltd for the design of Type A packages, specifically the SPS Viking Container.
The inspector compared relevant statutory requirements and associated guidance with the evidence provided. A number of examples of the duty holder meeting relevant good practice were identified, including the provision of a suitable certificate of compliance and presentation of the safety dossier in a systematic manner. A number of non-compliances were identified and discussed during the inspection, which included identification of the containment boundary, testing criteria, material properties and drop test approach.
During the inspection, the inspector also suggested certain improvements to documentation that would be prudent for Gilligan Engineering Services Ltd. to consider.
Gilligan Engineering Services Ltd demonstrated that the design of their Type A met the requirements of CDG and ADR in most respects and has agreed to address those areas where shortfalls were identified.
Based on the inspection sample, the inspector identified four non-compliances with relevant legislation and suggested one improvement. These were all discussed during the inspection and a commitment obtained from Gilligan Engineering Services Ltd to address them.
The inspector considers that the package can still be used as a Type A package, this will be further reviewed based on the responses to the issues identified.
Gilligan Engineering Services Ltd. was given until 10 November 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 there being significant shortfalls against identified relevant good practice when compared with appropriate benchmarks.
All non-compliances will be managed through ONR’s Issues Management arrangements.