The key regulatory activities undertaken during the two day inspection were based around:
CHS visit took place over the 2nd and 3rd March 2016. On the 2nd March (Day 1) we had an introductory meeting with relevant site personnel. I explained the role of the ONR Conventional Health & Safety (CHS) Team and the purpose of the visit which was to sample asbestos management arrangements and enquire about a possible presence of DMO electrical switchgear. I advised all present that any additional matters arising from the site familiarisation visit will be addressed according to the significance of the findings.
The EHSS&Q Manager provided an overview of the current and forthcoming activities on the site scheduled for the next 2 years. The site is in an advanced decommissioning stage moving towards Care & Maintenance. In March 2015 the site completed an 8 year-long bulk asbestos removal project where 3,300 tonnes of asbestos materials were stripped from 16 heat exchangers, turbine hall and 4 reactor buildings. There is a significant amount of ACMs throughout the site that still needs to be managed in line with regulatory expectations. The site holds an asbestos register with approximately 2000 asbestos related entries indicating the location and condition of ACMs. The overarching procedure for the management of asbestos is described in the Site Asbestos Management Plan (SAMP).
The EHSS&Q Manager introduced the Lead Asbestos Competent Person (LACP).
ONR carried out visits to a number of specific areas within the licensed site to review the effectiveness of the asbestos management arrangements against the requirements of CAR ACOP 2012 and MHSWR 1999.
Throughout day 1 ONR Inspectors visited different areas of the site. I was accompanied by the Industrial Safety Advisor, the LACP and the ONR site Nuclear Inspector. I visited the Turbine Hall to get an appreciation of the extent of ACMs present in the building. The Turbine Hall is planned to be demolished in the future therefore it was imperative to find out what challenges will be associated with the presence of ACMs and the demolition works.
I visited Chapelcross Processing Plant (CXPP) to look at the condition of asbestos panels incorporated into a framework of windows, and Reactor Building 2 where bulk asbestos stripping job have been completed. I visited the Electrical Maintenance Department (EMD) workshop to look at asbestos lagging and encapsulation work on pipes.
ONR CHS Principal Inspector visited Hangar 39 pad, Hangar 45, Low Level Waste (LLW) yard and met with two Safety Representatives, the Industrial Safety Advisor and the Construction Manager. ONR Inspector – Electrical Specialist - assisted in visiting those areas. ONR Principal Inspector sampled a range of activities such as workplace transport, interaction between people and vehicles, storage of asbestos waste, use of loading equipment such as flatbeds and load angels.
On the 3rd March (day 2) I visited the Maintenance Workshop and met with Deputy Maintenance Supervisor (Rigger Supervisor) – to discuss how information about asbestos risks is communicated to workforce and how it is applied into work planning.
ONR Principal Inspector met with Works Control Manager. They discussed the work control process and the extent to which provision of information regarding the presence of asbestos containing materials is contained within the works control process.
Afterwards, within the Maintenance Workshop ONR Inspectors visited the area where heavy machinery is housed. I looked at the guarding and made enquiries into maintenance arrangements.
We visited the Old Admin Building (Creca Room) – location of two asbestos register entries identified as high risk areas.
On day two ONR Inspector -Electrical Specialist made a separate visit to a number of locations to establish whether DMO switchgear is present and used on site. He has also met with the Senior Authorised Person (SAP) to discuss the matter.
In the afternoon of day two I met with site Safety Representatives to explore their experiences of the site asbestos management arrangements. I was accompanied by the two ONR Nuclear Inspectors. I informed Safety Representatives about the findings of the ONR visit and discussed any issues or concerns they have had, whilst the ONR CHS Principal Inspector met with the LACP to further explore arrangements for management of asbestos as per the site SAMP.
Day two concluded with the provision of regulatory feedback to the duty holder.
The CAR 2012: Approved Code of Practice and Guidance (CAR ACOP 2012), sets out the requirements for work with asbestos. Regulation 4 sets out the duty to manage asbestos in non -domestic premises. The Management of Health and Safety at Work Regulations 1999 (MHSWR 1999) sets out the general frame work for health and safety arrangements, risk assessment and management and requires the Chapelcross site to have health and safety arrangements that are appropriate for the nature of the activities and the size of the undertaking.
Chapelcross is in a process of revision their approach to managing asbestos within a draft SAMP that is due to be issued in April 2016. This document implements a new company asbestos management standard, launched in September 2015 – Document S-267. The document sets out the procedures and associated roles and responsibilities for working with ACMs and has been updated to better reflect the requirements of CAR 2012. In conjunction with S-267 Chapelcross sets out its local asbestos management control procedures within Site Interface document.
The site maintains an electronic version of asbestos register. Asbestos surveys and periodical inspections of ACM locations are carried out by off-site based analysts. An external asbestos removal contractor is used for licenced and non-licenced work.
Upon reviewing site asbestos arrangements and verifying its application in practice it has been identified that the arrangements need to be improved to satisfy the requirements of CAR 2012. SAMP does not reflect practical arrangements, there are insufficient measures to control risks associated with presence of ACMs, and there is a visible lack of monitoring and maintenance of ACMs. Some ACMs have been found damaged. Periodical asbestos monitoring inspections and records relating to inspections which already have taken place needs updating.
There is insufficient training of personnel responsible for asbestos management duties. There is no deputy to LACP to adequately deal with asbestos risks in case of LACP absence. There was concern that SAMP has not been implemented as intended and it does not form an integrated part of work planning arrangements.
Relevant Information about location and condition of asbestos is not widely available to all workers/contractors as asbestos risk register is withdrawn from circulation among staff. Information relating to risks associated with presence of ACMs is not proactively utilised in work planning. The site is in a process of transferring information from a historical asbestos register to a current one, but information has not been updated for several months.
In terms of other areas of ONR intervention, there was evidence that the assessment of risks associated with pedestrian and vehicle interactions in the LLW yard was not suitable or sufficient. ONR provided advice on segregation of pedestrians from vehicles, use of banksmen, visibility assessments and the use of visibility aids. The site committed to produce a revised traffic management plan taking into account the hierarchy of controls to deal with the risks associated with interaction of vehicles and people. It was recommended that the site considers a site-wide approach to the revision of this activity.
With regard to the presence of DMO switchgear, ONR is satisfied that obsolete systems are operated safely on site in an unsafe manner. ONR Inspector -Electrical Specialist- established that all of the station’s original high voltage system had been taken out of service, de-energised and earthed. The site has implemented Engineering Advice Note EAN140 “Operational restrictions on Reyrolle HH Switchgear and other similar cast iron construction switchgear” which requires such switchgear to be made dead before operating.
The overall impression gained from the inspection was that there are shortcomings in management knowledge and application of relevant standards. Chapelcross have a good attitude towards managing conventional health and safety on site and have clearly put a significant amount of effort into managing CHS hazards present; however there are gaps in their proactive approach to management of specific H&S risks and hazards.
A number of priority actions were identified during the inspection and the site committed to take prompt action to rectify the deficiencies identified.
There was a positive recognition by the management that the matters raised during the intervention merited their attention and action. The management was keen to complete the required improvements and also intended to reflect on and understand their current position. The site was required to provide written confirmation of their commitments to necessary improvements.
The Enforcement Management Model was considered and an enforcement letter will be sent to Chapelcross regarding the priority actions, with progress against the remaining areas for improvement being monitored via discussion with the site. This in turn indicates that a CHS rating of ‘5 – Significantly below standard’ should be applied to the visit. Issues will be added to the ONR Regulatory Issues database for tracking purposes.