Office for Nuclear Regulation

DRDL - IRR17 and LC18 Compliance inspections

Executive summary

Purpose of Intervention

This intervention was conducted at the Devonport site and covered both the licensed and authorised sites. It was undertaken as part of the 2017/18 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted an Ionising Radiations Regulations 2017 (IRR17) compliance inspection for both the licensed and authorised sites and a Licence Condition 18 inspection at the licensed site only. This included a joint inspection of two facilities with the Environment Agency (EA), as they wanted to gain assurance of the analytical efficacy of results generated within the Radiochemical Laboratory (RCL) and 9 Dock Primary Circuit Decontamination Laboratory. During the inspection I targeted the arrangements for:

During the inspection I held discussions with personnel at corporate and operational levels. I sampled relevant documentation and inspected a number of areas on site to see how the arrangements were applied at the point of work. I assessed compliance against:

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

There were a number of areas of industry good practice observed at the site, including:

A regulatory issue was identified which requires action to be taken by the duty holder. The condition of surfaces (including floors, walls and bench tops) in the RCL was not adequate in relation to compliance with Regulations 9 (2) and 11 (1) of the Ionising Radiations Regulations 2017 and LC 32 (1), in terms of their ability to act as a barrier to migration of radioactive material into the wider building fabric. The finding has been discussed with the site and will be recorded on the ONR regulatory issues database at level 3, to enable ONR to monitor progress.

Other minor opportunities for improvements were identified during the inspection and have been recorded as regulatory observations and shared with site. These include reviewing the arrangements for management of signage and clarification of Examination Inspection and Maintenance on assets, along with making clear the location of the remaining “essential contents” of local rules in the local rules notices.

Conclusion of Intervention

Based on the sampling undertaken during the IRR17 compliance inspection, I am satisfied that in general the duty holder has adequate arrangements in place under IRR17; however the regulatory finding identified in respect to the RCL has led me to judge that an ONR inspection rating of amber is appropriate.