A reactive intervention was made at Springfields, in order to inspect aspects of a recent minor event, to inspect improvements to radioactive source storage and disposal arrangements, together with the scope of a forthcoming senior level organisational change. A meeting was also held, in response to a request from the licensee, to provide regulatory advice on ALARP measures, particularly in relation to radiological protection standards and methodology.
I was accompanied by an ONR specialist radiological protection inspector throughout this intervention.
A reactive meeting to discuss a recent minor event at the National Nuclear Laboratory Limited tenant facility at Springfields, during the processing of unirradiated uranium carbide fuel, which had been received from Dounreay.
A reactive intervention was conducted to inspect aspects of improvements to radioactive source storage and disposal arrangements, including an inspection of the site radioactive source store.
A reactive meeting was held, at the request of the Managing Director, to discuss some forthcoming senior level organisational changes.
Reactive meeting, at the request of the licensee, to provide regulatory advice on the topic of ALARP, to the licensee and a tenant organisation, particularly relating to radiological, criticality and conventional safety.
I met with the licensee and the National Nuclear Laboratory Limited tenant organisation, to discuss, with the aid of photographs, the event where the uranium carbide powder had heated up, within the fume cupboard, which had then led to partial melting of the fire resistant sheet on the base of the fume cupboard. The operator’s prompt actions resulted in the material being quickly cooled and returned into containment. The response to this minor event was judged to be appropriate, the relevant organisations were informed and the licensee was duly overseeing a timely investigation by the tenant organisation. To clarify the details of the incident, the licensee promptly formally notified ONR in writing, through the formal written event reporting arrangements, in compliance with the licence condition 7 arrangements.
I visited the main site radiation source store to inspect progress, following a previous inspection in 2014, where I had considered the controls and accountancy procedures to be in need of some improvement. The radiation source store had undergone some refurbishment (e.g. new windows and repainted). Radiation sources were much more clearly organised, uniquely numbered and located within locked metal cabinets or within the locked inner room. The licensee had encouragingly identified approximately forty one radiation sources for disposal. The contract for this disposal was shown by the licensee and the disposal was shortly to be undertaken by a suitable contractor. Radiation source records sampled were in good order.
The licensee’s Managing Director provided advance information regarding some potential organisational changes, around the interface between the licensee and the Westinghouse parent body organisation. The changes would be duly assessed in advance, in compliance with the licensee’s organisational capability arrangements and discussed further with ONR when the detail of the proposed changes had been established. The licensee demonstrated effective knowledge of the ONR requirements for independent nuclear safety advice to the Managing Director. I also provided some regulatory advice on the regulation of COMAH matters, where ONR was the ‘joint competent authority’ with the Environment Agency, with HSE Hazardous Installations Directorate acting on behalf of ONR, in support of the ‘joined up’ regulation of the licensee by ONR.
A discussion was held with members of the licensee’s (and National Nuclear Laboratory Limited tenant)radiological protection community, to discuss ALARP and it’s application. Subjects included the need to consider a range of risks e.g. radiation protection, criticality safety and conventional safety, when deciding on an ALARP approach and for each aspect of safety not to work in isolation. The final decision should be an informed judgement, based on the knowledge and experience of those involved. Making a brief record (e.g. in a risk assessment) of the reasons why that approach was chosen can help to clarify the rationale behind the justification. This can also be used to record occasions where what would be considered to be ‘reasonably practicable’ precautions were not taken (e.g. due to more significant conventional safety hazards). Reference was made to ONR published procedures and to industry guidance (e.g. NS-TAST-GD-005). The need for more scrutiny at higher predicted or potential doses and the need to have an effective review when trigger levels were reached (e.g. total dose, contamination surveys) to highlight cumulative effects of several minor jobs or deviatiosn from anticipated conditions. Several examples were used to discuss some of the issues that might need to be considered when deciding what is the ALARP approach. I also provided advice that examples when licensees had failed to reduce radiation doses to ALARP, which may inform the licensee’s understanding of the boundaries of ALARP, could be found in the examples of enforcement action which were included in the appendix attached to the ONR inspection guidance on The Ionising Radiations Regulations 1999. I also discussed an example where a “time at risk” argument had been applied by a licensee in support of an ALARP case, which had been challenged but eventually accepted by ONR, in order to demonstrate the potential for “time at risk” to be a significant component of the demonstration of an ALARP case.
Regarding the incident reported to ONR, I concluded that an inspection rating of “3”, adequate, was warranted for this reactive intervention. The NNL tenant organisation licensee had responded correctly to the minor incident, reported to the licensee and also to Dounreay, (from where the pellets had been sent to Springfields for processing). There was good cooperation demonstrated between the tenant organisation and the two licensees. ONR was informed and during my intervention, the licensee arranged for knowledgeable staff from both the licensee and NNL to be available to discuss the event, with helpful photographs being provided at my meeting.
In view of the good progress effectively demonstrated by the licensee on the topic of radiation sources, I concluded that an inspection rating of “2”, good, was warranted for this intervention.
There was the usual open and constructive dialogue with the Managing Director and the EHS&Q Director and an inspection rating of 3, adequate, was considered appropriate for this early engagement with ONR on a proposed future organisational change, relating to the governance of the licensee, at the interface with the Westinghouse parent body organisation.
I was very encouraged that the licensee and a tenant organisation had chosen to engage with ONR, in a very open and constructive manner, to discuss the broad topic of ALARP, discussing examples from both the licensee and ONR of modern interpretations of ALARP. There was very open and effective engagement with the community of Springfields Radiation Protection Advisers and Health Physicists, representing both the licensee and the National Nuclear Laboratory Limited tenant organisation. This was a very constructive discussion, warranting an inspection rating of 2, good, for IRR 99 aspects and 3, adequate, for licence condition 14, safety documentation aspects.