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LC32 and LC34 compliance inspection

  • Site: Rosyth
  • IR number: 21-123
  • Date: November 2021
  • LC numbers: 32, 34

Executive summary

Purpose of Intervention

This inspection focussed on the implementation of Rosyth Royal Dockyard Ltd. (RRDL) arrangements for compliance with Licence Condition (LC) 32 (Accumulation of radioactive waste) and LC34 (Leakage and escape of radioactive material and radioactive waste). This inspection formed part of ONR’s Integrated Intervention Strategy for 2021/22.

The inspection purpose was to establish whether RRDL has adequate arrangements for LC32 and 34 and that their application enable RRDL to demonstrate that accumulation of radioactive waste is minimised, so far as is reasonably practicable, and it is at all times adequately controlled or contained such that it cannot leak or escape without being detected.

Interventions Carried Out by ONR

During the inspection, I gained evidence of how RRDL manages radioactive waste generated on the site. Specifically, I:

  • Explored the adequacy of the written arrangements for LC32 and 34
  • Visited the In Dock Installation and submarine reactor compartment to observe implementation of the arrangements at the point of radioactive waste generation
  • Visited the temporary dockside storage facility and the Active Waste Accumulation Facility to observe implementation of the arrangements for radioactive waste stored on the site

In addition, I held discussions on the progress with the Submarine Dismantling Project Stage 2 and the Resin Disposal Project in the context of radioactive waste management at Rosyth to support LC32 and 34 compliance.

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

I consider the arrangements for both LC32 and 34 are aligned to relevant good practice and support compliance. In general, I observed the radioactive waste inventory tracking system provided adequate record of the waste accumulated on the site. I observed good practice with respect to ensuring radioactive waste is at all times controlled or contained such that it cannot leak or escape and is subject to adequate monitoring to ensure any such leak or escape cannot occur without being detected. From the evidence sampled, I consider that suitable maintenance is being conducted on key plant and assets to ensure their safety function is maintained to deliver compliance.

Where minor shortfalls were identified, RRDL took immediate actions to address the matter where possible or demonstrated suitable plans to implement reasonably practicable improvements within appropriate timescales. In my opinion, the identified shortfalls do not undermine confidence in the safe and secure management of radioactive waste on the RRDL licensed nuclear site.

Conclusion of Intervention

From the evidence sampled relating to LC32 and 34 compliance, I concluded that RRDL’s arrangements, and implementation thereof, for minimising the accumulation of radioactive waste on the site, for recording the waste so accumulated, and for ensuring it is at all times controlled or contained such that it cannot leak or escape to be adequate.

I concluded that developments associated with the dockside ILW facility design under SDP Stage 2 to be sufficiently influenced by radioactive waste management to deliver an integrated and waste-led solution that will support compliance with both LC32 and 34.

In my opinion, an inspection rating of Green (No formal action) is appropriate with respect to both LC32 and 34.