- Site: Rosyth
- Inspection ID: 50901
- Date: September 2022
- LC numbers: N/A
Executive summary
Purpose of Intervention
Assurance that RRDL’s arrangements associated with the relevant requirements ofIRR17 and CDG09 in relation to the production of radiation risk assessments areappropriate and that duty holders are working to those arrangements.
ONR intends to sample arrangements for:
Producing RRAs for:
- Work on the nuclear licensed site.
- Work on laid-up submarines (LUSM) located in the non-tidal basin onbehalf of MOD (the area around the LUSMs is identified as anauthorised defence site within the HMNB Clyde Authorisation).
- The transport* of civil radioactive material from the RRDL nuclearlicensed site (noting the CDG09/IRR17 link).
- * Transport of material begins with any preparatory process (such aspackaging) and continues until the material has been unloaded at itsdestination.
- How the safety case/s for maintenance/decommissioning of laid-up submarines (LUSM) inform/s RRAs (the transparency of the safety argument from safety case to RRAs). · How relevant RRA information is provided to those involved in work with ionising radiation.
- How RRAs are used to inform the emergency arrangements required.
Subject(s) of inspection
- IRR17 - (Rating: Green)
- Transport (Nuclear) 9 Radiation Protection Programme - (Rating: Green)
Overall Inspection Rating Green
Key findings
A compliance inspection against the Ionising Radiations Regulations 2017 (IRR17) and the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09) was conducted at the Rosyth Royal Dockyard Limited (RRDL) nuclear licensed site.
Purpose of intervention
This inspection was undertaken as part of the 2022/23 intervention plan and defence propulsion sub-division strategy to assess the adequacy of RRDL’s arrangements for compliance with IRR17 and CDG09.
The inspection targeted IRR17 and CDG09 arrangements for producing Radiation Risk Assessments (RRAs), communicating RRAs and using RRAs to inform emergency planning requirements.
The purpose of the inspection was to seek assurance that RRDL’s arrangements associated with the relevant requirements of IRR17 and CDG09 are adequate and that the dutyholder is working to those arrangements.
Interventions Carried Out by ONR
The ONR inspection team comprised a specialist radiation protection inspector and the RRDL site inspector. The inspection team will be referred to as ‘we’ throughout this intervention record.
The inspection comprised a review of relevant documentation, discussion of the arrangements with relevant personnel, attendance at RRDL’s Health Physics Induction Presentation and a visit to the Active Waste Accumulation Facility.
The arrangements were inspected against L121: Work with Ionising Radiation, Ionising Radiations Regulations 2017 Approved Code of Practice and Guidance and the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as Amended).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
RRDL demonstrated that adequate arrangements are in place for compliance with IRR17 and CDG09 requirements for producing RRAs, communicating their content and using RRAs to inform emergency arrangements. RRDL was able to clearly explain its current documentation structure and demonstrate the interface between the RRA, procedures, Local Rules and control of work.
No non-compliances were identified during the inspection.
We identified some areas for improvement in the licensee’s arrangements which we shared with the license at the closing meeting. They will not be tracked via a regulatory issue as they were provided for consideration only.
Conclusion of intervention
On the basis of the evidence sampled, we judged that the licensee’s arrangements for compliance with IRR17 and CDG09 were adequate. A rating of Green (No formal action) was therefore assigned for this inspection.
Judgements made
We judged RRDL’s arrangements to be compliant for the areas sampled.