- Site: Devonport
- IR number: 21-148
- Date: Jnaury/February 2022
- LC numbers: N/A
Executive summary
Purpose of Intervention
A compliance inspection against the Ionising Radiations Regulations 2017 (IRR17) and the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09) was conducted at Devonport Royal Dockyard Limited (DRDL). As DRDL and HM Naval Base (HMNB) Devonport have joint radiation protection arrangements the inspection involved both DRDL (Babcock) and HMNB Devonport Ministry of Defence (MoD) arrangements.
Purpose of Intervention
This inspection was undertaken as part of the 2021/22 intervention plan and defence propulsion sub-division strategy to assess the adequacy of DRDL’s and MoD’s joint arrangements for compliance with IRR17 and CDG09.
The purpose of this inspection was to consider:
- IRR17 and CDG09 arrangements for producing radiation risk assessments for the transport of radiography sources and Nucleonic Calibration Facility sources from the DRDL non-licensed and licensed sites.
- IRR17 arrangements for the movement of radiography sources on and between the DRDL licensed site and HMNB Devonport.
Interventions Carried Out by ONR
During this inspection an inspection team comprising ONR and the Defence Science and Technology Laboratory (DSTL), who represented the Defence Nuclear Safety Regulator (DNSR), sampled DRDL’s and MoD’s joint arrangements for the transport of sources off site and the movement of sources on and between sites.
The inspection comprised tours of the Nucleonic Calibration Facility (located off the licensed site) and the Non-Destructive Examination Facility (located on the licensed site) and a review of documentation provided as evidence of compliance with the areas sampled.
The arrangements were inspected against L121: Work with Ionising Radiation, Ionising Radiations Regulations 2017 Approved Code of Practice and Guidance and the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as Amended).
In line with the Regulators’ Code, to reduce the burden to DRDL and HMNB Devonport, this compliance inspection was undertaken jointly with two Health and Safety Executive (HSE) inspectors who undertook an IRR17 compliance inspection of the Nucleonic Calibration Facility on the DRDL non-licensed site.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Some areas of good compliance were noted relating principally to source accountancy. However, due to the complexity of the joint DRDL and MoD arrangements and the difficulty DRDL had in demonstrating how their arrangements meet the requirements of IRR17 Regulation 8 Radiation risk assessments ACoP paragraphs 70 and 71, we judge an ‘amber – seek improvement’ rating is appropriate for this inspection.
HSE also issued an Improvement Notice and Notice of Contravention on DRDL for contravention of IRR17 Regulations 9(1) & 9(2) Restriction of exposure. This was due to engineering controls installed to prevent access to the irradiation cells in the Nucleonic Calibration Facility while radioactive sources are exposed being easily circumvented.
Conclusion of Intervention
The inspection findings were presented to DRDL at the close of the inspection. They included the need for DRDL to review and simplify their radiation risk assessment arrangements and to address specific issues relating to the Non-Destructive Examination Facility.