This was a planned inspection in line with the ONR Integrated Intervention Strategy (IIS) plan for 2020/21, of the Devonport Royal Dockyard Licensed and Naval Base Authorised Sites.
The intervention consisted of a remote compliance inspection against the Ionising Radiations Regulation 2017 (IRR17) arrangements. The inspection also provided an understanding of how the modified arrangements in response to the COVID-19 disease had impacted on the arrangements for IRR17. The inspection focused on areas where:
The inspection sampled the implementation of arrangements for harvesting of equipment from Turbulent within 3 Basin. Harvesting is the removal and recycling of key equipment for future use and requires breaking into primary circuits. Along with inspecting harvesting activities I inspected the radioactive effluent storage arrangements within SRC specifically MODIX Tanks which are planned for repurposing.
During the IRR17 inspection, I held telephone discussions with managers, supervisors and operators to obtain evidence to determine the level of compliance. I sampled relevant documentation and I assessed compliance against:
No matters were identified requiring immediate regulatory attention during the inspection.
I concluded that there were no shortfalls identified against relevant good practice (RGP), with respect to Radiological Protection requirements under IRR17.
I did however observe a minor shortfall in COVID19 assessments and application in the workplace. Although controls are well established for testing, self-isolation if identified as positive through a test result, social distancing, hand washing and enhanced cleaning regimes, a level 4 regulatory issue has been raised to ensure the duty holders confirm the adequacy of hygiene arrangements associated with doffing of RPE which have been implemented in line with the COVID-19 arrangements.
Based on the sampling undertaken during the IRR17 remote compliance inspection, I am satisfied that, the duty holders have adequate arrangements for compliance with IRR17.
Therefore, I consider that an inspection rating of Green (no formal action) is merited.