Executive summary
Date(s) of inspection:
September 2024
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for the transport of Class 7 dangerous goods by road and/or rail from the Dungeness B nuclear licensed site.
Subject(s) of inspection
- Transport - Consignor Duties - Rating: AMBER
- Transport - Dangerous Goods Safety Advice - Rating: GREEN
- Transport - Emergency/Contingency Planning and Testing - Rating: GREEN
- Transport - Management Systems - Rating: GREEN
- Transport - Package Maintenance and Operation - Rating: AMBER
- Transport - Package Manufacture and Supply Chain - Rating: GREEN
- Transport - Radiation Protection Advisor - Rating: GREEN
- Transport - Radiation Risk Assessment - Rating: GREEN
- Transport - Training and Competence - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
We reviewed a range of topics and identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are as low as reasonably practicable, including Management Systems, development and implementation of site and plant operating instructions, the appointment and capacity of consignors of Class 7 dangerous goods, corporate Radiation Protection Advisers (RPAs) and Dangerous Goods Safety Advisers (DGSAs), and the training and competence of employees.
We identified a shortfall in management arrangements to ensure that operation of the DN2080 package design is compliant with the requirements of the EDF certificate of approval for this self-approved IP-2 package, for example operating within the specified temperature range. A regulatory issue (RI-12340) has been raised with the dutyholder to address this.
We identified that the list of EDF corporate approved carriers for Class 7 dangerous goods included organisations that are no longer Class B approved carriers. A regulatory issue (RI-12243) has been raised with the EDF corporate DGSAs to address this.
Conclusion
The inspectors presented their findings to the dutyholder at the close of the inspection.
We rated seven of the nine thematic areas as GREEN and we judged that an overall inspection rating of GREEN was appropriate in accordance with our guidance in NS-INSP-GD-064 Issue 5.5.
The dutyholder is required to address the identified shortfall and we will track and monitor this to completion via a Level 4 regulatory issue. In addition, two identified shortfalls will be addressed by EDF Energy NGL corporate and we will track and monitor those to completion via Level 4 regulatory issues.