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) Oldbury 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) Oldbury nuclear licenced site.
The intervention examined the implementation of NRS Oldbury’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 Oldbury 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 (EHSSQ) Manger and Head of Radiological Protection as part of normal inspection feedback.
Four recommendations and two observations were raised.
Recommendation 1. The Head of Radiological Protection to undertake a review of the current radiation risk assessments and ensure where potential accidents/events may occur, the sites contingency arrangements (if in place) are referenced within.
Recommendation 2. The Head of Radiological Protection, reviews radiation risk assessments related to the FED retrievals work and reviews the potential failures/equipment breakdowns which may impact upon radiological safety and undertakes an assessment under the radiation risk assessment(s).
Recommendation 3. NRS Oldbury to develop Radiation Protection Supervisor refresher training and formalise what they consider to be an adequate/suitable period/frequency. This to be developed and implemented within the next six months.
Recommendation 4. A line/instruction be added to the NRS Oldbury radiation protection management arrangements which directs all Accredited Health Physicists to ensure that when revalidating Health Physics Certificates (or Designated Work Certificates), they ensure the radiation risk assessment(s) is within its three yearly review date (and remains suitable and sufficient).
Observation 1. NRS Oldbury 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. 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.’.
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. In addition, when undertaking the site walk down, it was evident that the advice and instructions stated in the radiation risk assessments was being adhered to.
- Thematic review of radiological safety related events allows for committee examination of cultural safety or wider root cause analysis to produce positive outcomes.
- The common production process of Local Rules Notices at NRS Oldbury is recognised as being effective whilst containing the correct detail to enable suitable responses when dealing with an incident.
- Coordination of cross cutting event themes have been used to improve understanding that has in turn made improvements on the site.
- The use of Target Zero briefings to address poor behaviours/actions on-site in and around radiation and contamination controlled areas.
- 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 Oldbury site.
- 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.
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.