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Fuel Storage Ionising Radiations Regulations (IRR17) compliance inspection

  • Site: Sellafield
  • IR number: 21-074
  • Date: August 2021
  • LC numbers: N/A

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. This report presents the findings of a planned intervention that was undertaken in order to assess compliance with the Ionising Radiations Regulations 2017 (IRR17) within the Fuel Storage Facilities on the Sellafield Site.

Interventions Carried Out by ONR

The intervention consisted of an examination of the implementation of arrangements to secure compliance with the requirements of IRR17 by discussion with key facility personnel and inspection of plant. The key requirements examined were those relating to the following IRR17 regulations and areas:

  • Regulation 8 - Radiation risk assessments;
  • Regulation 9 - Restriction of exposure;
  • Regulation 10 – Personal protective equipment;
  • Regulation 14 – Radiation protection adviser;
  • Regulation 17 – Designation of controlled and supervised areas;
  • Regulation 20 – Monitoring of designated areas (focus on calibration and
  • test);
  • Review of dose exposures (2021 data), plus comparison with previous years;
  • Details of any IRR17 events and how these have been addressed.

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

The ONR inspection team was content the facility management and Radiation Protection Adviser (RPA) had demonstrated compliance with IRR17. The facility management and RPA understood the current and future radiological challenges associated with the plant with adequate dose monitoring and control demonstrated. Additionally, there was good trending of doses and the radiological events sampled were minor, but nonetheless subjected to Sellafield Ltd’s LC 7 arrangements.

The risk assessments provided confirmed input from the RPA Nominee. We advised that ONR is in discussion with Sellafield Ltd regarding improving the visibility of the requirements of the Ionising Radiations Regulations 2017 Regulation 8 (Radiation risk assessments) and this would be tracked at the corporate level.

The ONR inspection lead reiterated the need to ensure areas were kept clear of debris, particularly the temporary C3 areas, as any housekeeping shortfalls are noticeable in what is overall a well maintained, clean facility.

The ONR inspection team was content the facility is aware of the requirement for the testing of installed radiological protection instrumentation, with confidence that Sellafield Ltd is compliant with IRR17 maintenance requirements provided by the sampling of maintenance records for monitors identified for sampling during the plant walkdown.

The ONR inspection lead reiterated the need for the facility to clarify the exit monitoring arrangements as this could lead to confusion for visitors and staff from other facilities.

During the intervention the ONR inspection team gained assurance of the Fuel Storage facilities’ compliance with Sellafield Ltd corporate Covid-19 control measures. The precautions observed in Thermal Oxide Reprocessing Plant (THORP) Receipt and Storage (TR&S) included one-way systems, waiting areas, priority direction indicators, limiting room occupancy, avoiding unnecessary footfall, and marked standing spots to enforce social distancing. Observations during the inspection identified that personnel were complying with the Covid-19 control measures. However, it was noted that the number of staff wearing face coverings has decreased (face masks are not mandatory at Sellafield but are advised and are provided). Overall, the inspection team judged that we had gained assurance regarding compliance with the corporate Covid-19 control measures.

The findings were shared with, acknowledged and accepted by the Fuel Services Senior Operations Manager as part of normal inspection feedback.

Conclusion of Intervention

In conclusion, I, and the inspection team 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.