Executive summary
Date(s) of inspection:
Aim of inspection
The purpose of this inspection is to gain assurance that the arrangements within Magnox Harwell 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
This report presents the findings of a planned intervention that was undertaken to assess compliance with the Ionising Radiations Regulations 2017 (IRR17) at the Magnox Limited Harwell nuclear licenced site.
The intervention examined the implementation of Magnox Harwell’s arrangements used to secure compliance with the requirements of IRR17 through prior sampling of evidence, and discussions with key facility personnel prior to an inspection of facilities. 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; and
- Details of any IRR17 events and how these have been addressed.
It is my judgement that Magnox Harwell site senior management and Head of Radiological Protection have demonstrated compliance with IRR17 for the regulations sampled. The Head of Radiological Protection understands the current and future radiological challenges associated with the current work, has appropriate dose monitoring mechanisms, and has been able to demonstrate those controls. I consider the documents submitted to ONR of a high standard. The radiation risk assessments and supporting documentation provided have confirmed input from Radiation protection advisers prior to peer review.
The findings of this inspection have been shared with, acknowledged, and accepted by Magnox Harwell’s Head of Radiological Protection and senior management as part of normal inspection feedback.
One Regulatory Issue, one recommendation and one observation were raised.
A Regulatory Issue to be raised relating to the locally produced Radiation Protection Monitoring personnel training records. It was evident on inspection that there were gaps in the records relating to individuals’ competencies. This does not provide confidence/ assurances to the Head of Radiation Protection re. the SQEP-ness of Radiation Protection
Head of Radiation Protection to initiate a review of the management arrangements re. recording and managing the training/ competency records of RPMs employed on-site.
Head of Radiation Protection to review internal audit strategy. Head of Radiation Protection aspires to undertake 3 audits per calendar year, however due to additional work commitment (assuming temporary responsibility of Emergency Planning Officer whilst Magnox Harwell recruits), the Head of Radiation Protection has only to date undertaken one internal audit.
Local Rules are considered lengthy – whilst noted that Magnox Harwell do use the ‘one page pictorial’ template, Magnox Harwell has an additional body of text (some Local Rules are 10 pages). It is suggested that Magnox Harwell may consider reviewing their arrangements re. reducing the length of Local Rules.
Several areas of good practice were also observed whilst undertaking this inspection. These were:
- 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.
- Radiation Protection Supervisors training and refresher training. It is noted as Magnox Harwell’s refresher training of Radiation Protection Supervisors is considered good practice. The delivery of nine modules over a 3-year cycle ensures the Radiation Protection Supervisors maintain SQEP and Continuous Professional Development.
- Positive behavioural working culture observed, which includes a good reporting culture on-site.
- During the plant walkdown, signage was adequately displayed and in good condition. Equally, the facility was generally tidy and equipment (inc. emergency equipment) was readily available and well stocked.
Overall, I have judged that, based on evidence sampled prior to and at the time of this on-site inspection, compliance with IRR17 has been demonstrated and an inspection rating of Green (no formal action) is appropriate.
Conclusion
Overall, I have judged that, based on evidence sampled prior to and at the time of this on-site inspection, compliance with IRR17 has been demonstrated and an inspection rating of Green (no formal action) is appropriate.