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), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2019 during this inspection (www.unece.org).
The purpose of the inspection was to review Sonomatic Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection of Sonomatic Limited’s Grangemouth site remotely (via MS Teams) on 2 February 2021.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Sonomatic Limited 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. The inspector identified a number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP, including: appropriate registration and consent; appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments and appropriate equipment on vehicles. The inspector identified a number of non-compliances and discussed these during the inspection, which included not having a suitable and sufficient RRA, emergency/contingency arrangements being inadequate, deficiencies in transport documents and administrative inadequacies with regards to security arrangements.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Sonomatic Limited to consider.
Sonomatic Limited 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 five non-compliances with relevant legislation and suggested two improvements. The inspector discussed these during the inspection and Sonomatic Limited gave a commitment to address them.
The inspector gave Sonomatic Limited until 16 March 2021 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector gave an inspection rating of AMBER, due to there being significant or systematic failure to implement or meet compliance arrangements.
ONR will monitor the identified non-compliances through its Issues Management arrangements.