Date(s) of inspection:
- November 2022
Aim of inspection
To seek assurance that Vulcan Naval Reactor Test Establishment (NRTE)’s arrangements associated with the relevant requirements of the Ionising Radiations Regulations 2017 (IRR17) and the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09) are appropriate and that the dutyholder is working to the arrangements.
Subject(s) of inspection
- IRR17 – Rating – Amber
- Transport (Nuclear) 9 Radiation Protection Programme – Rating – Amber
Key findings, inspector’s opinions and reasons for judgement made
A specialist radiation protection inspector conducted 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) at the Vulcan Naval Reactor Test Establishment (NRTE) authorised site.
The ONR Vulcan NRTE site inspector, the Defence Nuclear Safety Regulator (DNSR) site inspector and a Defence Science and Technology Laboratory (DSTL) radiation protection specialist were present for part of the inspection.
The inspection was part of the 2022/23 intervention plan and defence propulsion sub-division strategy to assess the adequacy of Vulcan NRTE’s arrangements for compliance with IRR17 and CDG09.
The inspection comprised a review of relevant documentation, discussion of the arrangements with relevant personnel and a visit to the Shore Test Facility.
The inspection found adequate arrangements for appointment of Radiation Protection Advisers, Radiation Protection Supervisors and Dangerous Goods Safety Advisers, production of Local Rules, source accountancy and source movement. However, improvements to arrangements for the production of Radiation Risk Assessments were identified. Vulcan NRTE committed to make these improvements which will be tracked via a regulatory issue.
Vulcan NRTE’s current arrangements are based upon past rather than current activities. Additionally, although lower tier procedures exist for work in radiologically designated areas, RRAs, Local Rules and contingency/emergency plans do not always exist.
Vulcan NRTE demonstrated that it was aware of most of the issues I highlighted during the inspection and that it is in the early stages of producing a prioritised radiation protection improvement plan. Resource constraints have been an issue but, it is anticipated that these will soon be resolved enabling improvement work to begin.
Vulcan NRTE should ensure that the following issues are addressed by the improvement plan:
Vulcan NRTE demonstrated adequate RRAs are being produced for higher risk activities as they arise. However, its arrangements currently do not reflect the requirement to produce RRAs for all work with ionising radiation (and for the transport of radioactive material). Vulcan NRTE should produce arrangements to document how it complies with IRR17 and CDG09 requirements for producing RRAs for all work with ionising radiation (facility, task based and transport) and which detail the responsibilities for production and approval of RRAs.
Arrangements should ensure that the requirements of RRAs flow down into Local Rules and that appropriate IRR17 contingency plan/CDG09 emergency plans are produced and are referred to in Local Rules.
Existing lower tier documentation should be updated as required to reflect revised RRA, Local Rule and contingency/emergency plan requirements.
The transport documents associated with consignment of a Type A package did not meet the requirements of CDG09. Vulcan NRTE, as the consignor, had produced a transport RRA but it did not make a conclusion about whether a radiation emergency was possible and therefore whether a CDG09 emergency plan was required to be produced. Additionally, the consignment was accompanied by a Vulcan NRTE emergency plan (that referred to an excepted rather than a Type A package) despite Vulcan NRTE not being the carrier. Vulcan NRTE should clarify CDG09 dutyholder responsibilities within its arrangements to ensure the correct dutyholder meets the requirements of CDG09.
The inspection findings were presented to Vulcan NRTE at the close of the inspection. A level 4 regulatory issue will be raised and tracked to completion via a level 4 regulatory interface meeting.