- Inspection date(s): 6/09/22
Aim of inspection
Inspection of corporate arrangements for compliance against the requirements of IRR17.
Subject(s) of inspection
The following actives were the subject of this inspection:
- IRR17 – Rating – Green
This report presents the findings of a planned intervention that was undertaken in order to assess compliance with the Ionising Radiations Regulations 2017 (IRR17) at the Dounreay licenced site.
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 inspections of facilities/ plants. 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
I was content that the facility management and Head of Radiation Protection had demonstrated compliance with IRR17. The facility management, including the facility ATO Holders understood the current and future radiological challenges associated with current work, with adequate dose monitoring and controls demonstrated.
I considered the documents submitted to ONR were of a high standard. The risk assessments and supporting documentation provided, confirmed input from the (facilities) Radiation Protection Adviser.
The findings of this inspection have been shared with, acknowledged and accepted by DSRL’s Assurance Director, Head of Design Authority, Independent Challenge & Oversight Department Manager and Head of Radiological Protection, as part of normal inspection feedback.
Overall, I 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.
I was content that DSRL’s management and Head of RP (and wider RPA team) had demonstrated compliance with IRR17. The facility management, including the Head of RP and facility RPAs understood the current (and future) radiological challenges associated with their areas with adequate dose monitoring and control demonstrated.
I considered the documents submitted to ONR were of a high standard. Notably, the risk assessments were written and prepared to a high standard, albeit with two minor observations noted below.
The risk assessment and supporting documentation provided, confirmed input from the RPA, and I consider the use of ‘hold points’ within the RAs [to ensure workers are able to seek advice/ support if required] was a positive example of good practice.
The DSRL staff who supported the walkdowns demonstrated a thorough understanding of their facilities and the associated operations undertaken. In addition, during both facility walkdowns, I observed open and honest dialogue during face-to-face meetings and facility walk downs (D2176 and D1200). During the second walkdown, it was evident that good RP engagement with the facilities management team was routine.
Throughout the inspection, where arrangements and procedures were discussed, I received copies (where applicable) to sample and support discussions.
Whilst I did not sample or sight any evidence regarding DSRL training material or observe the delivery of training, I do consider the description provided of the processes applied at DSRL, namely the training of HPM and RPS as very thorough.
Change rooms and general housekeeping of all areas I have visited (including general outside areas, administrative buildings and facilities) was noted to be in good condition and well maintained.