- Site: Devonport
- IR number: 21-003
- Date: April 2021
- LC numbers: 32, 34
Executive summary
Purpose of Intervention
This was a planned inspection, in line with the Office for Nuclear Regulation (ONR) intervention plan for 2021/22 of the Devonport Royal Dockyard Limited (DRDL) licensee, on the Devonport nuclear licensed site.
The purpose of this planned inspection was for ONR to determine the adequacy of the implementation of the licensee’s formal arrangements for compliance with Licence Condition (LC) 32 (Accumulation of radioactive waste) and LC 34 (Leakage and escape of radioactive material and radioactive waste).
Interventions Carried Out by ONR
On 27 to 29 April, I, along with the DRDL Compliance Lead Site Inspector and another Nuclear Liabilities Regulation (NLR) specialist inspector, carried out two licence condition compliance inspections of DRDL. The inspection comprised discussions with relevant DRDL personnel, a review of relevant documentation provided before and during the inspection and plant inspections.
The primary requirement of LC 32 is for the licensee to make and implement adequate arrangements to minimise, so far as is reasonably practicable, the rate of production and total quantity of radioactive waste accumulated on the site, and for recording the waste.
The primary requirement of LC 34 is for the licensee to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on the site is at all times adequately controlled or contained so that it cannot leak or otherwise escape from such control or containment.
As part of my preparation for the delivery of this intervention, the following ONR guidance documentation was used:
- NS-INSP-GD-032, Revision 7, issued in January 2021
- NS-INSP-GD-034, Revision 6, issued in April 2019.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
On the basis of the evidence sampled, I judged that the licensee does not have an adequate system for the management of radioactive waste on site. I found a number of instances where waste has not been minimised in a timely manner that, although minor in nature, compound to undermine confidence in the adequacy of DRDL’s overall waste management system. I consider these shortfalls to be the result of gaps in the following areas:
- Organisational accountability and responsibility
- The management of maintenance and assets
- Waste management culture.
I have proposed a Level 3 Regulatory Issue to track the licensee’s progress with improving the waste management system.
On the basis of the evidence sampled at the time of this inspection, I judged that the licensee has adequately implemented its arrangements for compliance with LC 34 (Leakage and escape of radioactive material and radioactive waste).
Conclusion of Intervention
On the basis of the evidence gathered during the inspection, I judge that a rating of Amber (Seek improvement) is merited for LC 32 Accumulation of radioactive waste).
On the basis of the evidence gathered during the inspection, I judge that a rating of Green (No Formal Action) is merited for LC 34 (Leakage and escape of radioactive material and radioactive waste).