Executive summary
Date(s) of inspection: November 2024
Aim of inspection
The purpose of this inspection is to gain assurance that the arrangements at Nuclear Restoration Services (NRS) Hinkley Point A (HPA) are compliant with the Ionising Radiations Regulations 2017 (IRR17).
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 Nuclear Restoration Services (NRS) Hinkley Point A (HPA) nuclear licenced site.
The intervention examined the implementation of HPA’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 and areas:
- 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
- Details of any IRR17 events and how these have been addressed
It is in my judgement that NRS HPA site senior management and Head of Radiological Protection have demonstrated compliance with IRR17 for the regulations sampled. The Head of Radiological Protection understands the current and future radiological challenges associated with the programmed 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 Accredited Health Physicists prior to peer review. Where bespoke in nature, or a of high radiation dose, the Radiation Protection Advisor body of NRS is also involved in their production.
The findings of this inspection have been shared with, acknowledged, and accepted by NRS Environment, Health, Safety, Security and Quality Manger and Head of Radiological Protection as part of normal inspection feedback.
Two recommendations and four observations were raised.
Recommendation 1. The Head of Radiological Protection reviews relevant radiation risk assessments and considers the potential failures/equipment breakdowns which may impact upon radiological safety and if required undertakes an assessment within the radiation risk assessment.
Recommendation 2. A line/instruction be added to the NRS Hinkley Point A radiation protection management arrangements which directs all Accredited Health Physicists to ensure that Designated Work Certificates remain extant (not expired) prior to use.
Observation 1. NRS Hinkley Point A to consider sign posting the sites radon survey and report within their radiation risk assessments to demonstrate an awareness (and assurance to the workers) that radon has been considered and included in the assessment.
Observation 2. Support the suggestion made by the Head of Radiological Protection to ensure that a ‘record of actions and decisions’ of the ALARP committee are formally recorded.
Observation 3. The Head of Radiological Protection to liaise with the Emergency Planning Officer to seek assurances that all members of the radiation protection team who participate in on-site exercises and rehearsals is documented. IRR17 regulation 13(2)(c) requires that ‘where appropriate, rehearsals of the arrangements in the plan are carried out at suitable intervals.’.
Observation 4. NRS Hinkley Point A to consider the inclusion of dose investigation levels within the Local Rules Notices. As identified in IRR17 Regulation 18, Guidance Para 336 (a) ‘the dose investigation level specified for the purposes of regulation 9(8);’
Several areas of good practice were also observed whilst undertaking this inspection. These included:
- The quality of radiation risk assessments provided to ONR to sample prior to the inspection were of a very high standard.
- The common production process of Local Rules Notices at NRS Hinkley Point A was recognised as being effective whilst containing the correct detail to enable suitable responses when dealing with an incident.
The role of Guardian being used in key areas e.g. entrance to the Radiation Controlled Areas (RCA) was considered a positive appointment. - A high standard of the cleanliness and general ‘housekeeping’ on the NRS Hinkley Point A site, with effective use of stillages around the site to control material.
- All signage (Local Rules Notices and contingency plans etc.) were adequately displayed – presented clearly and in the appropriate locations.
- Change rooms were suitably demarcated, with plenty of stock of PPE available.
- During the plant walk down, it was noted that a Forklift Truck driver was wearing their seat belt and sampled Scaff tags and monitoring instruments were in date.
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.