Office for Nuclear Regulation

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IRR99 Compliance Intervention - Contamination Control Arrangements

Executive summary

Purpose of intervention

This report presents the findings of a planned, unannounced inspection that was undertaken at the Sellafield site in order to assess Sellafield Limited's (SL) compliance with the Ionising Radiations Regulations 1999 (IRR99) with regards to control of radioactive contamination.

Interventions Carried Out by ONR

The intervention was conducted as a result of ONR receiving intelligence relating to the adequacy of contamination control arrangements on parts of the Sellafield site. This intelligence related to the perceived adequacy and adherence of IRR99 local rules and contingency arrangements associated with work in controlled areas. In view of the nature of the intelligence received, ONR determined that an unannounced inspection should be performed looking at the adequacy of SL's arrangements and testing the extent to which these arrangements are complied with in practice.

The inspection consisted of visits to controlled areas in four facilities on the site in addition to inspecting the arrangements at changerooms used for accessing controlled areas. The ONR team assessed the adequacy of written arrangements and observed the behaviour of workers in the controlled areas in order to determine whether they were adhering adequately to these arrangements. We also discussed the effectiveness of contamination control arrangements with SL Radiation Protection Advisers (RPAs) and representatives from contractors whose employees undertake significant amounts of work in controlled areas.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A This intervention did not include a safety system inspection.

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

We consider that SL has adequate local rules and contingency plans for work in controlled areas and that workers in these areas are complying effectively with these arrangements. Specifically:

The written arrangements contained appropriate information and in most circumstances were prominently displayed at the required locations.

When questioned, workers appeared to have sufficient understanding of the arrangements for restricting the potential for the spread of contamination beyond controlled areas. This was also apparent in the standards of behaviour we witnessed in changerooms at the access points to these areas.

SL appeared to exercise an adequate level of oversight and support for work undertaken by contractors from a contamination control perspective.

The level of support provided by health physics monitors (HPMs) for responding to personal contamination events appeared to be of a high standard, and workers in the controlled areas understood and welcomed the role of HPMs in contingency plans.

Workers who were subject to additional radiological protection controls, such as pregnant and breastfeeding women, are provided with an adequate level of support and oversight to their work.

We nevertheless identified a number of minor areas for improvement:

These matters were raised with SL's corporate EHSQ function and will be taken forward as part of normal regulatory business.

Conclusion of Intervention

It is vital that the contamination control arrangements at Sellafield are robust because of the substantial number of workers who routinely undertake work in controlled areas and the large number of facilities where contamination represents a hazard. The ageing condition of these facilities and the increasing amount of hazard and risk reduction work being undertaken also presents a challenge to ensuring that internal radiation doses are restricted and contamination is not carried beyond the boundaries of controlled areas.

From what we saw on this unannounced inspection, SL's arrangements for controlling contamination and adherence to these arrangements by workers are of an adequate standard. Specifically I consider that SL is complying with the requirements of IRR99 and consequently, I have rated this inspection as Green (No Formal Action).