- Site: RRSL
- IR number: 22-020
- Date: April 2022
- LC numbers: N/A
This was a planned inspection of the radiological protection arrangements implemented by Rolls Royce Submarines Ltd (RRSL), undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR), and carried out in-line with the planned inspection programme contained in the RRSL Integrated Intervention Strategy
Purpose of Intervention
The purpose of the intervention was to gain assurance that the licensee was compliant with the requirements of the Ionising Radiations Regulations 2017, and in addition that RRSL’s arrangements supported the implementation of the UK Nuclear Industry Guide to: Respiratory Protective Equipment and HSG53 – Respiratory protective equipment at work – A practical guide.
Interventions Carried Out by ONR
Respiratory Protective Equipment
This inspection was part of the ONR ‘Cross-Sites’ themed inspection focusing on respiratory protective equipment (RPE). The inspection was conducted by ONR radiation protection specialist Inspectors against the requirements of the Ionising Radiations Regulations 2017, The UK Nuclear Industry Guide to: Respiratory Protective Equipment and HSG53 – Respiratory protective equipment at work – A practical guide (Fourth edition).
The ONR inspection team will be referred to as ‘we’ throughout this intervention record.
Corporate Ionising Radiations Regulations 2017 Compliance
The key requirements examined were those relating to the following Ionising Radiations Regulations 2017 regulations:
- Regulation 8 – Radiation risk assessments
- Regulation 9 – Restriction of exposure
- Regulation 10 – Personal protective equipment
- Regulation 11 – Maintenance and examination of engineering controls etc and personal protective equipment
- Regulation 15 – Information, instruction, and training
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety system-based inspection.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
RRSL voluntary requested to participate in this cross-site intervention which was undertaken following an inspection undertaken by RRSL’s Internal Regulation team in 2021. We acknowledged RRSL’s proactive engagement and response to the Internal Regulation team’s recommendations. RRSL have also recognised the need to address outstanding actions from a 2019 ONR intervention, which demonstrates a level of maturity and commitment to make the required improvements.
RRSL have produced, and are working to implement, an RPE improvement forward action plan. It is apparent that a significant amount of improvement work has been and continues to be undertaken. Most of the work undertaken to date has been associated with producing new written arrangements and focus is now required on ensuring the adequacy of the new arrangements, that existing written arrangements align with the new arrangements and on practical implementation.
We judged that RRSL should make further RPE improvements which include documenting how RRSL ensures adequate RPE Suitably Qualified and Experienced Personnel (SQEP), training and refresher training of personnel who undertake fit tests of RPE users, robust contamination control of RPE and RPE storage lockers, delivery of a central RPE maintenance location to support hygienic cleaning in a designated radiological area suitable for such activities, appropriate storage and management of RPE spare parts and filters and provision for ‘rolling up’ local maintenance records to produce a central record of RPE maintenance.
In our opinion some areas sampled, if rated individually against ONR’s General Inspection Guide ONR-INSP-GD-064, were ‘Amber (seek improvement)’. However, when a holistic view is taken, and noting the forward action plan already in place, we judge that an overall inspection rating of ‘Green (no formal action)’ is more appropriate. This is based on RRSL’s obvious commitment to improvement by delivering the RPE forward action plan, RRSL’s governance arrangements for delivery of the plan and the Internal Regulation team’s continued oversight of delivery of the plan.
A level 4 Regulatory issue has been raised on ONR’s issues management system which requires RRSL to update the RPE improvement forward action plan to address the findings detailed in this intervention record, confirm governance arrangements for implementation of the revised plan and for RRSL’s Internal Regulation team to confirm adequacy of implementation of the plan. If implementation of the plan stalls this regulatory issue will be escalated to level 3.
Conclusion of Intervention
We judged, based on the evidence sampled and the work RRSL is undertaking to make improvements at the time of this intervention, that an inspection rating of Green (no formal action) is appropriate.
However, as stated, we noted that if implementation of the RPE improvement forward action plan stalls the level 4 regulatory issue raised will be escalated to level 3.