Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
An increasing trend in low level contamination events in Magnox Repro was observations as the facility transitioned from operating to POCO operations. The aim of this inspection was to understand how the licensee’s arrangements are being implemented regarding radiological control including control and supervision and operating instructions (work planning, work pack production given the new working arrangements for POCO activities).
Subject(s) of inspection
- IRR17 - Rating: Green
- LC24 - Operating instructions - Rating: Green
- LC26 - Control and supervision of operations - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
IRR17
This element of the inspection sampled compliance with IRR17 regulations 9, 15, 16, 17 and 18.
Regulation 9 – Restriction of exposure
Regulation 15 – Information, instruction and training
Regulation 16 – Co-operation between employers
Regulation 17 – Designation of controlled or supervised areas
Regulation 18 – Local rules and radiation protection supervisors
The inspection comprised of an initial discussion with the RPA for B205 focussed around compliance with the IRR17 regulations stated above, followed by a walkdown of the facility and a discussion with the facility RPS. No major issues were identified, however, some minor observations were made as follows:
Doses to personnel are well controlled, but contractors are not viewed as part of the work-force. This may lead to insufficient supervision, although many contractors working in the facility have been there for a long time and were very familiar with the facility. Regulatory advice was given regarding the supervision of contractors to ensure it is adequate to comply with IRR17 regulation 16.
Local rules are not well controlled and entry requirements were confusing in some areas. Several sub-changerooms were noted to be untidy, which may lead to contamination control issues. The RPS for the area understood his supervision duties well, but was unclear on the specific requirements of the RPS role and could not differentiate his DAP duties from his RPS duties. Regulatory advice was given to the RPA to review signage, provision of local rules and tidiness of barriers for controlled areas to ensure that it complies with IRR 17 requirements.
LC24
This element of the inspection sampled compliance with nuclear site licence condition 24 - Operating Instructions. "The licensee shall ensure that all operations which may affect safety are carried out in accordance with written instructions hereinafter referred to as operating instructions".
As part of the inspection preparations, Sellafield Ltd provided examples of several Operating Instructions (OIs) for POCO glovebox washout activities. The OIs were developed in accordance with the Licensee's arrangements and were generally written to a good standard. Specifically, with regards to LC 24(4) -“The Licensee shall make and implement adequate arrangements for the preparation, review and amendment of such OIs”, the OI author was clearly articulate the process for reviewing and developing OIs. Whilst the facility Condition Reports for the past 12 months suggest there are issues with regards the updating of OIs as the facility moves into POCO, evidence was provided of the updated and new OIs and no OIs are outstanding on their review. There remains, however, the potential that some OIs should be withdrawn which are still active as the safety case is developed for ceasing operations is not fully in place. This will be raised with the ONR Safety Case owner for their wider consideration.
LC26
This element of the inspection sampled compliance with nuclear site licence condition 26 – control and supervision. “The licensee shall ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.” The sample included discussions with a variety of staff responsible for both performing and planning supervisory activities. Different descriptions of what is meant by supervision levels specified in the risk assessment process were provided (e.g., 100%, 50% supervision). Additionally, there were discrepancies in how people describe the different supervisory roles, such as ASQEP, Team Leader and DAP. However, there was no evidence that activities were not being sufficiently supervised and the arrangements clearly allow for significant management discretion when determining required levels of supervision. This will be raised with the ONR LC26 owner for their consideration with regards to wider Licensee arrangements.
Conclusion
IRR17
The inspection was rated green with no formal action taken.
LC24
The inspection was rated green with no formal action taken.
LC26
The inspection was rated green with no formal action taken.