- Site: Rosyth
- IR number: 20-003
- Date: May 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
This report covers the remote inspection of the arrangements for compliance with Ionising Radiations Regulations 2017 (IRR17), applied to activities occurring on the Laid-Up Submarines (LUSMs), within the Non-Tidal Basin at the Rosyth Royal Dockyard. The area around the LUSMs is identified as an Authorisation Defence site within the HMNB Clyde Authorisation. The inspection forms part of a series of planned interventions in accordance with the ISS strategy and plan. The inspection was remote due to the on-going restrictions associated with the COVID-19 pandemic.
Interventions Carried Out by ONR
The intervention consisted of a remote compliance inspection against the Ionising Radiations Regulation 2017 (IRR17), and the implementation of modified arrangements for IRR17 in response to the COVID19 pandemic.
The scope was originally drafted and agreed between all parties prior to 14th March 2020. Following the implementation of UK Government Policy and controls to restrict the spread of COVID-19, the scope for the inspection was amended to focus on areas where:
- ONR inspectors felt they could inspect remotely, and undertake a meaningful inspection and assessment of compliance; and
- Duty holders could generate enough evidence to demonstrate compliance with standards.
ONR inspectors held discussions with managers, supervisors and operators to obtain evidence to determine the level of compliance. ONR inspectors sampled relevant documentation and carried out telephone interviews with various individuals to understand how arrangements are applied at the point of work. ONR inspectors assessed compliance against:
- ‘Work with Ionising Radiation’ - Approved Code of Practice and Guidance L121.
- ‘The Ionising Radiations Regulations 2017’ - NS-INSP-GD-054 Revision 6.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Areas of good and developing good practice were highlighted during this remote inspection, and opportunities for improvements.
The areas for improvement include:
- HMNB Clyde to demonstrate appropriate ownership of the delivery of updated arrangements for non-tidal basin. This may be evidenced through management of the contractor and a resourced plan for delivery of updated IRR17 arrangements.
- HMNB Clyde and its Contractor Babcock (Rosyth) Ltd should review measures to assure themselves that the health protection measures in support for COVID19 meet the complete expectations of government guidance.
At a later date, the ONR site inspector and a Radiological Protection Inspector will review documentation to assess the link between the safety case for maintenance of the LUSMs and the Radiation Risk Assessment.
Conclusion of Intervention
Based on the limited sample undertaken during the remote IRR17 compliance inspection, ONR is satisfied that adequate arrangements are in place to control activities involving work with ionising radiation on LUSMs in the non-tidal basin. The rating for this limited remote inspection is ‘Green’.