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 Element Materials Technology Sheffield Ltd.’s (hereafter referred to as EMT) arrangements associated with the road transport of radioactive material. ONR carried out this inspection of EMT’s site remotely (via MS Teams) on 15 February 2021.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by EMT 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: consent gained from the Health and Safety Executive (HSE), having Local Rules covering transport, appointment of a Radiation Protection Adviser and suitable dosimetry. 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 (including testing/rehearsal), lack of a dangerous goods safety advisor (DGSA), inadequate instruction and training of staff and administrative inadequacies with regards to security arrangements.
It was noted that the last time EMT transported radioactive material was in August 2018 and that there is no work planned currently that would require transport of radioactive material. However, EMT do want to have the option to transport radioactive material in the future.
During the inspection, the ONR inspector informed EMT that in his opinion, should EMT transport radioactive materials under its current arrangements, it would be non-compliant with both CDG09 and IRR17. The ONR inspector requested EMT to formally write to ONR to confirm that it would not transport radioactive material until it was able to demonstrate compliance with CDG09 and IRR17.
EMT subsequently wrote to ONR 15 March 2021 (the day of the inspection) to confirm that it would not transport radioactive material until it has ensured it is able to demonstrate it is fully compliant with CDG09 and IRR17.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for EMT to consider.
EMT demonstrated that for certain aspects of its operations it met the requirements of CDG09, ADR, and IRR17. Based on the inspection sample, the inspector identified six non-compliances with relevant legislation and suggested one improvement. The inspector discussed these during the inspection and EMT gave a commitment to address them.
The inspector gave EMT until 26 April 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 shortfalls against identified relevant good practice when compared with appropriate benchmarks as well as systematic failure to comply with administrative legal requirements. It was also taken into account that EMT does not actively transport radioactive material at present (since 2018 and has voluntarily agreed to cease transport of radioactive material until it is able to demonstrate compliance with CDG09 and IRR17).
ONR will monitor the identified non-compliances through its Issues Management arrangements.