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Compliance inspection of IRR17

  • Site: Devonport
  • IR number: 19-017
  • Date: May 2019
  • LC numbers: 18

Executive summary

Purpose of Intervention

This intervention was conducted at the Devonport site and covered both the licensed and authorised sites. It was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted an Ionising Radiation Regulations 2017 (IRR17) compliance inspection for both the licensed and authorised site. The scope of the inspection included; the Nucleonic Calibration Facility, 9 Dock, Nuclear Utilities Building and Nuclear Engineering Maintenance and Storage Facility. During the inspection I targeted the arrangements for:

  • The management of solid, liquid and aerial radioactive materials and wastes across the facilities, on both the nuclear licenced site and authorised defence site.
  • The maintenance and management of radiological monitoring equipment. This is a service provided off the licenced and authorised sites at the Nucleonic Calibration Facility (NCF), Devonport. Inspection of the arrangements was made under Section 6 of the Health and Safety at Work Act 1974 (as amended) (HSWA’74).

During the inspection I held discussions with personnel at corporate and operational levels. I sampled relevant documentation and inspected a number of areas on site to see how the arrangements were applied at the point of work. I assessed compliance against:

  • IRR17 compliance - ONR’s Technical Inspection Guides (TIG) - principally NS-INSP-GD-054.
  •  ‘Work with Ionising Radiation’ - Approved Code of Practice and Guidance L121.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

There were a number of areas of industry good practice observed at the site, including:

Provision of Equipment Monitoring Points (EMPs) within 9 Dock and Nuclear Engineering Maintenance and Storage Facility (NEMSFAC), using standard arrangements and signage, resulting in good housekeeping and segregation.

  • Provision of standard Radiological Controlled Area (RCA) survey information in a readily accessible easy to read format, along with a consistent briefing format.
  • Radiological Protection Advisor (RPA) and Radioactive Waste Advisor (RWA) walk down reports for radiological controlled and surprised areas. These provided clear photographic evidence of radiological, convention and cultural shortfalls with respect to the management of radioactive materials.
  • Respiratory Protective Equipment (RPE) inspection instructions, including the use of photographic material, providing clear expectations for the operators during routine maintenance activities.

A number of opportunities for improvements were identified during the inspection and have been recorded as regulatory observations and shared with the site. These include;

  • Review the requirement and effectiveness of the continuous in-air monitoring within the Resin Storage Area (RSA).
  • Review examination, inspection, maintenance and testing (EIMT) and records of IBC containers used to collect potentially radiological contaminated effluent.
  • Review of access/egress area for personal into the RUBB tent due to a potential conventional hazard (fall in step).

A single Level 4 Regulatory Issue is raised for the licensee to address the shortfall in the storage arrangements within the NEMSFAC stable waste store, which did not align with those adopted elsewhere on site:  

  • DRDL to implement improvements to the storage of radioactive waste within the NEMSFAC stables, to align with the arrangements in place across the wider site.

A number of shortfalls were identified with respect to the management of radioactive waste assets within the Nuclear utilities Building and NEMSFAC, however ONR maintains adequate oversight of improvements through the Nuclear Safety Improvement Programme (NSIP), including the Asset Management work stream, and on-going routine engagements. Relevant, existing ONR Regulatory Issues will be updated to reflect the findings from this inspection. 

Conclusion of Intervention

Based on the sampling undertaken during the IRR17 compliance inspection, I am satisfied that in general the duty holders (DRDL and HMNB(D)) have in place adequate and consistent arrangements under IRR17. I consider it appropriate to assign a rating of Green (No Formal Action) to this intervention.