Office for Nuclear Regulation

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DRDL - Planned LC32 and LC34 Inspection

Executive summary

Purpose of Intervention

This intervention was carried out jointly with the Defence Nuclear Safety Regulator (DNSR) on the Devonport licensed and authorised sites. The purpose was to assess the adequacy of the licence condition 32 and 34 arrangements and their implementation. Similarly DNSR assessed the adequacy and implementation of authorisation conditions 32 and 34 on the authorised site. This intervention was undertaken as part of a series of planned interventions supporting ONR's DRDL intervention strategy. The intervention was carried out in accordance with the memorandum of understanding between ONR and DNSR.

Interventions Carried Out by ONR

ONR carried out planned Licence Condition (LC) 32 (accumulation of radioactive waste) and 34 (leakage and escape of radioactive material and radioactive waste) compliance inspections in line with the ONR Technical Inspection Guides NS-INSP-GD-032 Revision 3 and NS-INSP-GD-034 Revision 3 respectively. The inspection plan was given to DRDL in advance of the inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

A System/Structure Based Inspection was not carried out.

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

The inspection was carried out in accordance with the inspection plan and sampled the following:

In the areas sampled the inspection generally found that both solid and liquid radioactive materials and waste are kept in appropriate and well maintained facilities, which are equipped with suitable secondary containment and leak detection systems. However, one radioactive effluent pipeline was identified on the licensed site where the secondary containment and leak detection were inadequate, due to the pipe trench being full of water. The licensee has been advised to [1]sample and remove the water as soon as practicable and to put in place temporary arrangements to ensure secondary containment and leak detection is effective. A longer term solution must then be developed. This was judged to be a significant shortfall against the requirements of LC 34 and a level 3 regulatory issue has been raised and will be followed up on ONR's next visit to site. There was no evidence to indicate that any radioactive material had leaked from the effluent pipeline.

A document review of the arrangements for LC 32 and 34 found the compliance processes were inadequately documented and unclear. A large number of documents were listed as compliance arrangements but the interaction between these documents was unclear and the documentation suite was impenetrable. This was judged a shortfall against LC 32 which requires adequate arrangements and also against the relevant good practice for LC 17 (IAEA GSR Part 2) which requires processes to be documented. DRDL stated that it has recognised deficiencies in their top level compliance arrangements for all licence conditions, and is currently carrying out gap analysis against good practice. This will contribute to improving the compliance principles document. However, improvements will be needed in the compliance arrangements themselves and two regulatory issues have been raised for LC 32 and 34 respectively to seek action to resolve the specific shortfalls in these arrangements.

The movement, quantity and location of radioactive waste are recorded by an electronic system which tracks the material using bar codes. This system appeared effective and was judged adequate. The electronic system constitutes the radioactive waste records but is not identified in the licensed site's records schedule. This was judged to be a shortfall against LC 6 guidance (NS-INSP-GD-006) which states records required to demonstrate compliance with licence conditions should be identified. ONR will seek corrective action to ensure LC 32 records are clearly identified as part of the regulatory issue relating to the compliance arrangements.

Posters were seen instructing personnel not to take packaging into designated areas so as to avoid secondary radioactive waste. Personnel in the processing areas confirmed there has been a reduction in secondary waste and there were no unnecessary items of packaging in the waste bags. No significant accumulations of waste were seen in the areas visited. LC 32 arrangements for minimising rate of production and accumulations of radioactive waste were therefore judged adequate.

Conclusion of Intervention

ONR will raise two issues to improve the compliance arrangements and records schedules for licence conditions 32 and 34. An issue will also be raised to resolve the shortfalls associated with the effluent pipeline secondary containment and leak detection. The inspection is therefore rated as amber for licence conditions 32 and 34.

No items were identified of sufficient nuclear safety significant to required immediate regulatory action.

[1] Post inspection note DRDL have advised ONR that the preliminary results all show activity as at or below limit of detection.