Date(s) of inspection:
- November 2022
Aim of inspection
The purpose of this inspection is to gain assurance that the arrangements within Tradebe Inutec are compliant with the Ionising Radiations Regulations 2017 (IRR17).
Subject(s) of inspection
- LC18 – Radiological protection – Rating – Green
Key findings, inspector’s opinions and reasons for judgement made
Compliance with the Ionising Radiations Regulations 2017 (IRR17) and License Condition 18 “Radiological Protection” at the Tradebe Inutec nuclear licenced site was assessed
The intervention consisted of an examination of the implementation of arrangements to secure compliance with the requirements of IRR17 & LC18 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 Tradebe Inutec senior management and Radiation Protection Advisor had demonstrated compliance with IRR17 and LC18. The Radiation Protection Advisor 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 radiation risk assessments and supporting documentation provided, confirmed input from the Radiation Protection Advisor.
The findings of this inspection have been shared with, acknowledged, and accepted by Tradebe Inutec’s management and Radiation Protection Advisor as part of normal inspection feedback.
One Regulatory Issue and two recommendations were raised.
- The Regulatory Issue raised related to the exercising/ testing of contingency arrangements. When reviewing the Radiological Protection training delivered, it was identified that there have been no exercising/ rehearsals of the contingency arrangements. IRR17 regulation 13(2)(c) requires that ‘where appropriate, rehearsals of the arrangements in the plan are carried out at suitable intervals..’. This will be recorded as a Level 4 Regulatory Issue.
- A recommendation (1) was recorded for Tradebe Inutec to review the business arrangements for producing radiation risk assessments to include early engagement with the sites Radiation Protection Advisor. This recommendation will be followed up via routine regulatory engagements.
- A recommendation (2) was recorded in relation to the assessment and use of eye dosimetry (when being evaluated during the development of the associated risk assessment). Tradebe Inutec to enhance their assessment and usage of eye dosimetry in future operations. This recommendation will be followed up during the permissioning of the forthcoming MOD operations.
Several areas of good practice were also observed whilst undertaking this inspection. These ranged from:
- 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.
- The general standard of ‘house-keeping’ observed on-site was of a good standard.
- An employee was observed presenting a notebook that had been used in a controlled area to the Health Physics surveyors for monitoring. This was noted as evidence of a positive workplace/ employee culture.
- When reviewing ‘information, instruction and training (regulation 15), it was evident that the RPA has led a successful training campaign on radiological protection topics including ‘Basic radiation safety awareness’, ‘Barrier training’, ‘Area designation’ and ‘Radiation risk assessment training’. It was also observed that the Radiation Protection Supervisor training’ delivered at Tradebe Inutec was considered to be of a high standard. The Radiation Protection Supervisors training comprises of initial training and appointment, followed by a series of 12 modules delivered over a 3-year cycle.
Overall, I judged that, on the basis of evidence sampled at the time of this inspection, compliance with IRR17 and LC18 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. Two recommendations and one regulatory issue were raised
Regulatory issue 1. Regulation 13(2)(c) of the Ionising Radiations Regulations 2017 require that rehearsals of the arrangements in the contingency plan are carried out at suitable intervals. At the time of the visit no rehearsals of the associated contingency plans had been carried out. As such Tradebe Inutec should plan a timetable of rehearsals for all relevant contingency plans and a date for completion.
Recommendation 1. Regulation 5 of The Management of Health and Safety at Work Regulations 1999 require that, every employer shall make and give effect to such arrangements as are appropriate for effective planning and control of work activities. As such Tradebe Inutec should review arrangements for producing RRAs to include early engagement with the nominated RPA. This will be followed up via routine regulatory engagements.
The RRAs reviewed are structured to ensure all aspects of IRR17 Regulation 8 ACoP (paragraphs 70 & 71) are considered. In addition, the use of a ‘summary’ page was considered valuable to the reader/ worker. These practices, in my opinion are further examples of good practice.
Recommendation 2. ACOP paragraph 71 associated with the Ionising Radiations Regulations 2017 require that ‘radiation dose rates to which anyone can be exposed should be estimated’. At the time of the visit risk assessments of some work activities did not include estimate of eye dose (Hp(3)). Tradebe Inutec should enhance their assessment and usage of eye dosimetry in future operations. This recommendation will be followed up during the permissioning of the forthcoming MOD operations.
In summary, I judge that the current RRAs being used at Tradebe Inutec are adequate and demonstrate good examples of Relevant Good Practice.