Executive summary
Date(s) of inspection:
- August 2024
Aim of inspection
The focus of this intervention is on restriction of exposure, contingency arrangements, and control of designated areas associated with industrial radiography and the use of gamma radiography sources.
As the volume of open site radiography increases the control of the designated areas can become more challenging.
In addition, with the increased number of radiography worksites and exposures, the potential for the enactment of the contingency plans increase. This will also include the interaction s fire response arrangements and evacuation routes.
The intervention is to gain continued confidence that arrangements are in place to restrict exposure and access into designated areas of those not involved in radiography operations.
The intervention will also consider any radiography related event investigations undertaken and how the recommendations have been implemented.
Industrial radiography represents a significant risk to health and safety if not appropriately managed.
Recognising that NNB GenCo do not undertake industrial radiography themselves, and that ONR has recently assessed and issued a Ionisation Radiations Regulations 2017 (IRR17) Consent for the management of industrial radiography for NNB GenCo, the intervention will primarily look at the arrangements of the industrial radiography contractors working on the site.
Keys areas to be examined:
- Radiation risk assessments and the identification of fault scenarios and potential dose exposures.
- Dose monitoring and trending.
- Contingency plans and how the training associated is undertaken and monitored.
- Control of the radiography designated area – monitoring, signage and restriction of access.
- Observation of industrial radiography being undertaken.
- Observation of the application of the General Fire Precautions and Emergency Arrangements.
The intervention will be undertaken in relation to the requirements of the Ionisation Radiations Regulations 2017, and the Regulatory Reform (Fire Safety) Order 2005
Subject(s) of inspection
- IRR17 - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The inspection provided suitable time to discuss arrangements with key contractors, examine appropriate documents, and undertake a site visit to gain continued confidence, ahead of primary circuit, and mechanical, electrical, heating and air conditioning (MEH) bulk radiography activities that arrangements are in place to restrict exposure to as low as reasonably practicable (ALARP).
I also considered how access into designated areas is managed of those not involved in radiography operations, and that contingency arrangements, including fire safety and emergency preparedness arrangements within radiography areas are understood, and the radiography staff are appropriately trained.
NNB GenCo do not undertake industrial radiography themselves, with the inspection focussed on the arrangements of the industrial radiography contractors undertaking this work.
I was accompanied by an ONR fire safety inspector, and the ONR Radiological Protection & Criticality Head of Profession.
The ONR fire safety inspector focus was on assessing the fire safety and emergency preparedness arrangements within a radiography area, and on the pre work preparations, including the requesting and accepting of the radiography permit before taking receipt of the gamma source.
His engagement with the radiography supervisor provided him with the confidence that the supervisor and his team were all suitably knowledgeable regarding the safety arrangements in advance of committing to work. This included a detailed and practical understanding of all aspects of how to react to an emergency fire situation. The barrier controls were robust, and the selection of the “sentry” locations was appropriate to the environment that the work was taking place.
I was content that the industrial radiography contractors have suitable arrangements in place to restrict exposure of those not involved in radiography operations, they have suitable contingency arrangements in place, and these are exercised regularly and the radiographers are appropriately trained.
A small number of observations relating to contingency response equipment, and fire safety arrangements were made during the inspection, with actions agreed at the time, and these will be followed up via normal regulatory interactions.
Conclusion
I judged that, on the basis of evidence sampled at the time of this inspection, compliance with IRR17 and the Regulatory Reform (Fire Safety) Order 2005 was demonstrated, and an inspection rating of Green (no formal action) is appropriate.