Office for Nuclear Regulation

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IRR99 Compliance Intervention - Pile Fuel Storage Pond

Executive summary

Purpose of intervention

This report presents the findings of a planned intervention that was undertaken at the Pile Fuel Storage Pond (PFSP) at the Sellafield site in order to assess Sellafield Limited’s (SL) compliance with the Ionising Radiations Regulations 1999 (IRR99).

PFSP was selected for inspection in view of the risks and hazards posed by this legacy facility prior to its decommissioning and remediation.

Interventions Carried Out by ONR

IRR99 includes a range of duties related to controlling harm from exposure to ionising radiations.

The licensee provided a summary of the activities undertaken at the facility and its arrangements for ensuring compliance with IRR99.  Matters discussed included the application of the hierarchy of control measures for restricting exposure to radiation, dose management, control of work, training and supervision of personnel and contingency arrangements.  A plant visit was also conducted to identify whether the licensee’s arrangements were being effectively applied at the point of work.

Explanation of Judgement if Safety System Not Judged to be Adequate

This intervention did not include a safety system inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I consider that the Licensee has adequate arrangements for complying with IRR99.  SL provided evidence that employee doses are monitored effectively and reviewed against Local Area Review Levels (LARLs).  The constraints on space within the facility mean that it is problematic to employ effective passive engineering controls, such as contamination control enclosures, local ventilation and permanent shielding, but the licensee appears to have developed an effective system of active controls and systems of work to restrict exposure to ionising radiations.  This is evidenced by the fit for purpose arrangements that have been demonstrated during the recent metal fuel exports from the facility.

We identified a number of minor areas for improvement:

Conclusion of Intervention

PFSP is a challenging facility from a radiological protection perspective, consisting of ageing, high hazard plant that is subject to a range of ongoing decommissioning activities.  From what we have seen, radiological hazards are being adequately managed by the licensee and SL is complying with the requirements of IRR99.  Furthermore, the licensee demonstrated a clear commitment to safely accelerating hazard and risk reduction.  Consequently, though noting the above minor areas for improvement, we have nevertheless rated SL’s compliance as 3 (adequate).