- Site: Devonport
- IR number: 20-074
- Date: November/December 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
This was a planned inspection in line with the ONR Integrated Intervention Strategy (IIS) plan for 2020/21, of the Devonport Royal Dockyard Licensed and Naval Base Authorised Sites.
Interventions Carried Out by ONR
The intervention consisted of a remote compliance inspection against the Ionising Radiations Regulation 2017 (IRR17) arrangements. The inspection also provided an understanding of how the modified arrangements in response to the COVID-19 disease had impacted on the arrangements for IRR17. The inspection focused on areas where:
- ONR inspectors assessed they could inspect remotely;
- Duty holders could provide enough documentary evidence supported by interviews to demonstrate compliance with standards.
The inspection sampled the implementation of arrangements for harvesting of equipment from Turbulent within 3 Basin. Harvesting is the removal and recycling of key equipment for future use and requires breaking into primary circuits. Along with inspecting harvesting activities I inspected the radioactive effluent storage arrangements within SRC specifically MODIX Tanks which are planned for repurposing.
During the IRR17 inspection, I held telephone discussions with managers, supervisors and operators to obtain evidence to determine the level of compliance. I sampled relevant documentation and I 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.
- HM Government guidance “Working safely during COVID-19 in factories, plants and warehouses.05th November 2020
Explanation of Judgement if Safety System Not Judged to be Adequate
Not Applicable
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No matters were identified requiring immediate regulatory attention during the inspection.
I concluded that there were no shortfalls identified against relevant good practice (RGP), with respect to Radiological Protection requirements under IRR17.
I did however observe a minor shortfall in COVID19 assessments and application in the workplace. Although controls are well established for testing, self-isolation if identified as positive through a test result, social distancing, hand washing and enhanced cleaning regimes, a level 4 regulatory issue has been raised to ensure the duty holders confirm the adequacy of hygiene arrangements associated with doffing of RPE which have been implemented in line with the COVID-19 arrangements.
Conclusion of Intervention
Based on the sampling undertaken during the IRR17 remote compliance inspection, I am satisfied that, the duty holders have adequate arrangements for compliance with IRR17.
Therefore, I consider that an inspection rating of Green (no formal action) is merited.