Executive summary
Date(s) of inspection: June 2024
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road and/or rail transport.
Subject(s) of inspection
- Transport - Consignee Duties - Rating: Green
- Transport - Consignor Duties - Rating: Green
- Transport - Dangerous Goods Safety Advice - Rating: Green
- Transport - Emergency/Contingency Planning and Testing - Rating: Amber
- Transport - Management Systems - Rating: Green
- Transport - Package Maintenance and Operation - Rating: Green
- Transport - Radiation Protection Advisor - Rating: Green
- Transport - Radiation Protection Programme - Rating: Green
- Transport - Radiation Risk Assessment - Rating: Amber
- Transport - Security - Rating: Green
- Transport - Training and Competence - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspector identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including, suitable IRR17 registration, notification and consent, appropriate local rules and comprehensive arrangements covering all aspects of transport.
The inspector identified two areas of non-compliance which were the radiation risk assessment and contingency plans. These were discussed during the inspection.
Conclusion
The inspection findings were presented to Stork Technical Services Limited at the close of the inspection.
I judged an overall inspection rating of amber was appropriate for this inspection. I identified significant shortfalls against relevant good practice when compared with appropriate benchmarks, but without prejudice to overall nuclear safety. I adhered to ONR’s Enforcement Management Model, which in this instance was issue of an enforcement letter due to non-compliance in relation to radiation risk assessment and contingency plans.
Regarding the IRR17 Reg 8 and 13 non-compliances, Stork Technical Services Limited is required to provide to ONR either with evidence that the identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 1 October 2024. The non-compliances will be tracked to completion via a Level 3 Regulatory Issue.
I judged an overall inspection rating of amber was appropriate for this inspection. I identified significant shortfalls against relevant good practice when compared with appropriate benchmarks, but without prejudice to overall nuclear safety. I adhered to ONR’s Enforcement Management Model, which in this instance was issue of an enforcement letter due to non-compliance in relation to radiation risk assessment and contingency plans.
Regarding the IRR17 Reg 8 and 13 non-compliances, Stork Technical Services Limited is required to provide to ONR either with evidence that the identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 1 October 2024. The non-compliances will be tracked to completion via a Level 3 Regulatory Issue.
Regarding the CDG09 non-compliance, Stork Technical Services Limited is required to provide to ONR either with evidence that the identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 1 October 2024. The non-compliances will be tracked to completion via a separate Level 4 Regulatory Issue.