Date(s) of inspection:
- October 2022
Aim of inspection
The purpose of this inspection is to gain assurance that the arrangements within the Springfields Fuels Ltd 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 in order to assess compliance with the Ionising Radiations Regulations 2017 (IRR17) at the Springfields Fuels Limited licensed 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 Senior Health Physicists – Radiation Protection Advisors had demonstrated compliance with IRR17. The Health Physicists – Radiation Protection Advisors 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 an adequate standard. The risk assessments and supporting documentation provided, confirmed input from the (facilities) Health Physicists – Radiation Protection Advisors.
The findings of this inspection have been shared with, acknowledged and accepted by Springfields Fuels Limited Senior Health Physicists – Radiation Protection Advisors Independent Nuclear Assessment, 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.
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. The following recommendations were raised:
- Regulation 13(2)(b) of the ionising radiations regulations 2017 requires that any employee under the employer’s control who may be involved with contingency plan arrangements have been issued with suitable dose meters or other devices. At the time of our visit dose meters associated with contingency plans (monitoring at source instruments) relating to contamination were not available at their agreed locations.
- Regulation 18(3) of the ionising radiations regulations 2017 requires that an employer take all reasonable steps to ensure that any local rules which are relevant to the work being carried out are observed. Local rules for entering and leaving C4 areas require monitors be available at the barrier to check for contamination, at the time of our visit we observed monitors being stored remotely from barriers. Their location would preclude employees from following the extant C4 exiting procedure as laid down in the extant local rules.
- Regulation 8 of the Ionising Radiations Regulations 2017 requires that an employer must make a suitable and sufficient assessment of the risk to any employee relating to activities involving with the work ionising radiation. A suitable and sufficient radiation risk assessment should consider the matters outlined in paragraphs 70 and 71 of the approved code of practice associated with the Ionising Radiations Regulations 2017. The risk assessment that was provided during our visit did not consider all aspects that are relevant to the hazard they were assessing, specifically paragraphs 8b relating to assessment of eye and extremity dose and 8k, 8l and 8m relating to doses associated with wounding during work in C3/C4 areas.
- Regulation 15(e) of the ionising radiation regulations 2017 requires that an employer must ensure that employees who are engaged in work with ionising radiation be given appropriate training and that the training be repeated at appropriate intervals. At the time of our visit refresher training for radiological protection was being carried out at intervals of 5 years. From observations of some poor practice of employees whilst on site it would indicate that the frequency of training should be reviewed.
- Regulation 5(1) of the Management of Health and Safety at Work Regulations 1999 requires that every employer shall make and give effect to arrangements as are appropriate, for the effective monitoring and review of the preventive and protective measures. During our inspection it was relayed that radiation protection risk assessments and documentation was being produced without a framework of monitoring and review. It is our opinion that radiation protection risk assessments would benefit from peer review.
- Regulation 5(1) of the Management of Health and Safety at Work Regulations 1999 requires that every employer shall make and give effect to arrangements as are appropriate, for the effective control, monitoring and review of the preventive and protective measures. During our inspection it was observed that there was no control, or monitoring of contamination control procedures at the entrance to the controlled area as it was unmanned and did not have an automated portal monitor.