Executive summary
Date(s) of inspection:
- September 2023
Aim of inspection
The purpose of this engagement is to gain assurance that the arrangements within NRTE are compliant with the Ionising Radiations Regulations 2017 (IRR17) and review and close out existing Regulatory Issue (RI–11081).
Subject(s) of inspection
- IRR17 – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This report presents the findings of a planned intervention that was undertaken to assess compliance with the Ionising Radiations Regulations 2017 (IRR17) at the MOD NRTE Vulcan nuclear authorised site.
The intervention examined the implementation of MOD NRTE Vulcan’s arrangements used to secure compliance with the requirements of IRR17 through prior sampling of evidence, and discussions with key facility personnel prior to an inspection of facilities. The key requirements examined were those relating to the following IRR17 regulations:
- Regulation 8 – Radiation risk assessments;
- Regulation 9 – Restriction of exposure;
- Regulation 14 – Radiation protection adviser;
- Regulation 15 – Information, instruction, and training;
- Regulation 17 – Designation of controlled or supervised areas;
- Regulation 18 – Local rules and radiation protection supervisors;
- Regulation 20 – Monitoring of designated areas; and
- Details of any IRR17 events and how these have been addressed.
It is in my judgement that MOD NRTE Vulcan senior management (Naval Superintendent Vulcan) and appointed Radiation Protection Adviser have demonstrated compliance with IRR17 for the regulations sampled. The Radiation Protection Adviser understands the current and future radiological challenges associated with the current work, has appropriate dose monitoring mechanisms, and has been able to demonstrate those controls. I consider the documents submitted to ONR of a high standard. The radiation risk assessments and supporting documentation provided have confirmed input from the Radiation Protection Adviser and/ or Health Physicists prior to peer review. Where bespoke in nature, or a of high radiation dose, the Radiation Protection Adviser and/ or Health Physicist(s) is also involved in identification and implementation of additional controls.
The findings of this inspection have been shared with, acknowledged, and accepted by MOD NRTE Vulcan’s Naval Superintendent Vulcan, Radiation Protection Adviser and senior management as part of normal inspection feedback.
One Regulatory Issue, one recommendation and two observations were raised.
- Regulatory Issue. A Regulatory Issue to be raised relating to the exercising/ testing of contingency arrangements. MOD NRTE Vulcan Radiation Protection Adviser is to develop and implement a training exercise schedule for the wider Health Physics/ Radiation Protection professionals on the site. IRR17 regulation 13(2)(c) requires that ‘where appropriate, rehearsals of the arrangements in the plan are carried out at suitable intervals.’. This will be recorded as a Level 4 Regulatory Issue.
- Recommendation. MOD NRTE Vulcan Radiation Protection Adviser to review the annual dose constraints level. IRR17 Regulation 9(4)-(5).
- Observation 1. During the facility walkdowns (Shore Test Facility and Dounreay Submarine Prototype 1), the general housekeeping was noted as poor in some areas.
- Observation 2. The number of radiological protection site events reported to date in 2023 is considered to be low. I invite MOD NRTE Vulcan to consider reviewing the threshold to which low level radiological protection associated events is reported.
Several areas of good practice were also observed whilst undertaking this inspection. These were:
- The quality of radiation risk assessments provided to ONR to sample prior to the inspection were of a high standard. They are structured in a logical order and clearly followed the ACoP.
- I noted the Rolls Royce Head of Radiological Protection has twice this year undertaken internal inspections and the Rolls Royce NRTE Vulcan Radiation Protection Adviser undertakes quarterly facility walkdowns, where her reports are presented to the Facility Safety Case owner(s).
- The common production process of Local Rules Notices at MOD NRTE Vulcan is recognised as being effective whilst containing the correct detail to enable suitable responses when dealing with an incident.
- A high standard of the cleanliness and general ‘housekeeping’ was observed in the dosimetry issue points and change areas for both the Shore Test Facility and Dounreay Submarine Prototype 1 facilities.
- Noted during the Facility walkdowns was the locally introduced ‘interlock arrangement’ when entering controlled areas. MOD NRTE Vulcan have incorporated an interlock mechanism that requires the approved dosimetry (Harshaw TLD) to be inserted which then opens the turnstile door.
Conclusion
Overall, I have judged that, based on evidence sampled prior to and at the time of this on-site inspection, compliance with IRR17 has been demonstrated and an inspection rating of Green (no formal action) is appropriate.