Executive summary
Date(s) of inspection:
- October 2022
Aim of inspection
The primary purpose of this intervention was to inspect Devonport Royal Dockyard Limited (DRDL) and HM Naval Base (HMNB) Devonport Authorised Defence Sites compliance against the Ionising Radiations Regulations 2017 (IRR17) Regulation 17 Designation of controlled or supervised areas, Regulation 19 Additional requirements for designated areas & Regulation 20 Monitoring of designated areas in order that Regulation 9 Restriction of exposure is fulfilled. The areas that the DRDL intervention focused on was DRDLs arrangements for designating areas as controlled and the arrangements for entry and egress. The area that the HMNB intervention focused on was HMNBs arrangements for designation of temporary controlled areas for temporary storage of items that are either contaminated or suspected of being contaminated and awaiting clearance by health physics.
This intervention was intelligence led and follows two events reported at Level 4 RP RIF meetings: one related to entry of a controlled area, more specifically the increase in the number of times a Radioactive Work Control Permit (RWCP) for emergency access to controlled areas has been incorrectly used to access dosimetry and one event related to unauthorised removal of trunking (used on a platform to ventilate a reactor compartment) from a temporary storage area.
Subject(s) of inspection
- IRR17 - rating: Green
Key findings, inspector's opinions and reasons for judgement made
A compliance inspection against the IRR17 was conducted at the DRDL Nuclear Licenced Site and HMNB Devonport Authorised Defence Site. The inspection was led by an ONR radiation protection specialist inspector and an ONR trainee inspector. The Defence Nuclear Safety Regulator site inspector and two Defence Science and Technology Laboratory radiation protection specialists were also present for part of the inspection.
The inspection was part of the 2022/23 intervention plan and defence propulsion sub-division strategy to assess the adequacy of DRDLs and HMNB Devonport's arrangements for compliance with IRR17. The inspection comprised of a review of relevant documentation, discussion of the arrangements with relevant personnel and visits to the New Equipment Maintenance Facility and Tidal X berth.
The inspection found that DRDL has adequate arrangements for compliance with the requirements of IRR17 relating to the designation and entry/egress of controlled and supervised areas. The inspection also found that HMNB Devonport has adequate arrangements for compliance with the requirements of IRR17 relating to the designation of temporary controlled areas and for the management and radiological clearance of waste removed from controlled areas. Opportunities for improvement were identified in some areas following response to recent events and the improvements will be followed up via routine regulatory business.
Conclusion
A compliance inspection against the IRR17 was conducted at the DRDL Nuclear Licenced Site and HMNB Devonport Authorised Defence Site. With the improvements identified during the inspection, together with the documentation sampled prior to and during the inspection and the observations made during the inspection I am content that HMNB Devonport has adequate arrangements for compliance with the requirements of IRR17 relating to the designation of temporary controlled areas and for the management and radiological clearance of waste removed from controlled areas. The inspection also found that DRDL has adequate arrangements for compliance with the requirements of IRR17 relating to the designation and entry/egress of controlled and supervised areas.