Office for Nuclear Regulation

Compliance inspection of IRR17

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 2019/20 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted an Ionising Radiation Regulations 2017 (IRR17) compliance inspection for both the licensed and authorised site. The scope of the inspection included; the Nucleonic Calibration Facility, 9 Dock, Nuclear Utilities Building and Nuclear Engineering Maintenance and Storage Facility. 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:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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:

Provision of Equipment Monitoring Points (EMPs) within 9 Dock and Nuclear Engineering Maintenance and Storage Facility (NEMSFAC), using standard arrangements and signage, resulting in good housekeeping and segregation.

A number of opportunities for improvements were identified during the inspection and have been recorded as regulatory observations and shared with the site. These include;

A single Level 4 Regulatory Issue is raised for the licensee to address the shortfall in the storage arrangements within the NEMSFAC stable waste store, which did not align with those adopted elsewhere on site:  

A number of shortfalls were identified with respect to the management of radioactive waste assets within the Nuclear utilities Building and NEMSFAC, however ONR maintains adequate oversight of improvements through the Nuclear Safety Improvement Programme (NSIP), including the Asset Management work stream, and on-going routine engagements. Relevant, existing ONR Regulatory Issues will be updated to reflect the findings from this inspection. 

Conclusion of Intervention

Based on the sampling undertaken during the IRR17 compliance inspection, I am satisfied that in general the duty holders (DRDL and HMNB(D)) have in place adequate and consistent arrangements under IRR17. I consider it appropriate to assign a rating of Green (No Formal Action) to this intervention.