- Site: Hinkley Point C
- IR number: 21-017
- Date: July 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C (HPC) Construction Inspection Plan, ONR performs a series of planned compliance inspections to assess the adequacy of NNB Generation Company (HPC) Ltd’s (NNB GenCo’s) arrangements with the Ionising Radiations Regulations 2017 (IRR17) with specific focus on industrial radiography arrangements and restriction of exposure.
This intervention focus followed a number of personnel access challenges into, or personnel residing within radiologically designated controlled areas while industrial radiography was taking place on the NNB GenCo HPC site.
The objectives of the intervention were:
- to gain confidence arrangements are in place to restrict access to radiologically designated controlled areas, and to restrict exposure of those not involved in radiography operations; and
- to consider the investigations undertaken following the incursion events, and how recommendations have been implemented.
Interventions Carried Out by ONR
IRR17 and the supporting Approved Code of Practice and guidance lay down the statutory requirements for the protection of persons against ionising radiation arising from work activities.
The intervention consisted of an examination of the implementation of arrangements to secure compliance with the requirements of IRR17.
The key requirements examined were those relating to the following IRR17 regulations:
- Regulation 8 – Radiation risk assessments
- Regulation 9 – Restriction of exposure
- Regulation 13 – Contingency plans
- Regulation 19 – Additional requirements for designated areas
The IRR17 intervention provided suitable time to discuss arrangements with key staff, examine appropriate documents, and undertake a site visit to understand the complexities and challenges when undertaking open-site radiography during the current phase of the construction works.
The following guidance was used in this intervention:
- Nuclear Safety Technical Assessment Guide – Radiological Protection. NS-TAST-GD-038 Revision 9
- Work with ionising radiation: Ionising Radiations Regulations 2017: Approved Code of Practice and guidance
- HSE information sheet Industrial radiography – managing radiation risks Ionising Radiation Protection Series No. 1 (rev 2 – 2018)
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, this was not a system based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The following summarises the key observations arising from discussions, sampled documentation, and inspection of industrial radiography areas during this intervention:
- I was content that NNB GenCo has suitable procedures and processes in place for all radiography contractors to follow to ensure compliance with IRR17 and the development of radiography package specific radiation risk assessments.
- It was clear learning from events had been incorporated in the ways of working including improved communications between radiography and construction teams, dedicated platform radiography times, and the use of 3D mapping to aid establishment and searching of radiological designated controlled areas when undertaking open site radiography.
- Early engagement between the Tier 1 civils contractor and their Radiation Protection Advisor (RPA) regarding modifications within the East Pool Bunker was welcomed.
- I sought reassurance from NNB GenCo that it had the capability to demonstrate adequate control and management of doses when there are step changes in the frequency of industrial radiography operations taking place.
- Advice was provided to NNB GenCo and Bylor in relation to the consideration of additional measures to restrict access to the East and West Pool Bunker roof stairs, over those already implemented.
- I stressed the importance to NNB GenCo of monitoring the effectiveness of the changes made in relation to informing of radiography and restricting access to radiologically designated controlled areas to ensure this can be maintained when there is a significant increase in open site radiography activities to support MEH installation works.
Conclusion of Intervention
I judged that, on the basis of evidence sampled at the time of this inspection, compliance with IRR17 was demonstrated and an inspection rating of Green (no formal action) is appropriate.