Office for Nuclear Regulation

Compliance inspection of LC32 and LC34

Executive summary

Purpose of Intervention

This intervention, conducted at the Licensee’s Devonport Royal Dockyard Limited Devonport licensed site was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted Licence Condition (LC) 32 (Accumulation of radioactive waste) and LC 34 (Leakage and escape of radioactive material and radioactive waste) compliance inspections, focused on the adequacy of the licensee’s arrangements. Evidence was also gathered against ONR Regulatory Issues #6043 (LC 32 management arrangements improvements) and #6044 (LC 34 management arrangements improvements).

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.

No findings were identified as requiring regulatory attention during the conduct of the compliance inspection.

Conclusion of Intervention

On the basis of the evidence sampled against the regulatory expectations of LC 32, the licensee demonstrated it is progressing with improvements to address the shortfalls within its compliance arrangements for LC 32 (Regulatory Issue #6043). Until such a time that these improvements are finalised and implemented, it is my judgement that the shortfalls identified remain open. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Amber (Seek improvement) is merited for LC 32 Accumulation of radioactive waste).

On the basis of the evidence sampled against the regulatory expectations of LC 34, the licensee has made adequate improvements to their LC34 compliance arrangements. A minor shortfall from Regulatory Issue #6044 remains open and greater clarity will be provided to the licensee on regulatory expectations to address this. For this reason, I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (No Formal Action) is merited for LC 34 (Leakage and escape of radioactive material and radioactive waste), and I am recommending the reduction in the regulatory attention level of Regulatory Issue #6044 to a Level 4.