Date(s) of inspection:
- January 2023
Aim of inspection
To seek assurance that HMNB Clyde’s arrangements associated with the relevant requirements of IRR17 and CDG09 in relation to the production of transport radiation risk assessments and on-site movement of radioactive material are appropriate and that duty holders are working to those arrangements.
Subject(s) of inspection
- IRR17 – Rating: Green
- Transport (Nuclear) 13 Dangerous Goods Safety Advisor (DGSA) and Other Advice – Rating: Amber
- Transport (Nuclear) 6 Package Preparation for Consignment – Rating: Amber
- Transport (Nuclear) 9 Radiation Protection Programme – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
Two specialist radiation protection inspectors 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 HMNB Clyde authorised site. The HMNB Clyde Defence Nuclear Safety Regulator (DNSR) site inspector was present for the inspection.
The inspection was part of the 2022/23 intervention plan and defence propulsion sub-division strategy to assess the adequacy of HMNB Clyde’s arrangements for compliance with IRR17 and CDG09.
The inspection comprised a review of relevant documentation, discussion of the arrangements with relevant personnel and visits to the Radioactive Effluent Disposal Facility (REDF), Non-Destructive Examination Facility and the Nuclear Support Hub (which is in construction).
The inspection found adequate arrangements relating to Radiation Protection Adviser (RPA) appointments, Radiation Protection Supervisor (RPS) appointments and training, Radiation Risk Assessments (RRA), Local Rules, emergency arrangements, source accountancy and movement and vehicles used to transport radiography sources.
Two non-compliances relating to the transport of radioactive material were identified. HMNB Clyde committed to address these non-compliances which will be tracked via a regulatory issue.
We judged an overall inspection rating of green was appropriate for this inspection.
The inspection findings were presented to HMNB Clyde at the close of the inspection.
The inspection found adequate arrangements relating to RPA appointments, RPS appointments and training, RRAs, Local Rules, emergency arrangements, source accountancy, source movement and vehicles used to transport radiography sources.
Two non-compliances relating to the consignment of radiography sources back to the supplier and production of a DGSA annual report were identified. HMNB Clyde committed to address these non-compliances.
We judged an overall inspection rating of green was appropriate for this inspection. A level 4 regulatory issue will be raised for the two transport non-compliances and tracked to completion via a level 4 regulatory interface meeting.