To obtain an overview of the Imperial College Reactor Centre (ICRC) arrangements for managing non-nuclear health and safety and undertake site familiarisation, including the inspection of selected activities underway during visit.
One of ONR’s key strategic themes is influencing improvements in nuclear safety and security. The Cross ONR Programme strategic direction for 2015-2020 delivers its contribution to this theme by providing coherent support and advice to other ONR regulatory programmes in conventional health and safety. In addition, the ONR Conventional Health & Safety (CHS) Team sub-programme strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Some of these topics are management of asbestos, work at height, control of contractors and control of work with substances hazardous to health.
The 100 kilowatt light water reactor entered decommissioning stage in 2015. The project involves the removal of all radiological and non-radiological waste and the demolition of the reactor centre to enable the site to be de-licensed. Reactor's fuel was successfully removed and transported to Sellafield for storage in July 2014, significantly reducing the safety hazard on site.
The reactor was not designed to be de-fuelled and the control rods and the neutron start up source are still within the core. At present the main activities taking place on site relate to removal of in-core internals (control rods) and construction of concrete shielding cell. The nature of the works is that there is a high reliance on lifting equipment to complete key activities undertaken. In addition, demolition activities will face challenges relating to the presence of Asbestos Containing Materials (ACMs). This intervention sampled key activities proceeding during the visit.
The key regulatory activities undertaken during a one day inspection were based around:
During the introductory meeting with site personnel the role of ONR Conventional Health & Safety Team and the purpose of the visit were explained. ICRC provided a company overview, an overview of future operations & a summary of arrangements for managing non-nuclear H&S.
A walkdown of a number of RCA and non-RCA locations was undertaken to learn more about the site layout and key activities undertaken by ICRC, sample activities underway at the time of the visit and obtain an overview of the management arrangements in place. As a result, this visit was one that enabled insight into a number of elements of CHS management rather than being a detailed inspection of one particular CHS topic.
Regulatory judgement was based on determining compliance with sections 2 & 3 of the Health & Safety at Work etc Act 1974 and relevant statutory provisions made under the Act. A number of key relevant statutory provisions were referred to during the visit, including:
The visit concluded with the provision of regulatory feedback to the duty holder.
A number of areas of good practice were seen during the visit in addition to areas for improvement. These were summarised during feedback provided at the conclusion of the visit, as were the visit outcomes/actions required by ICRC.
Areas of good practice seen during the visit included: storage and periodic check markings on lifting accessories, slings, anchor points and lanyards; indicative markings for Safe Working Loads on lifting equipment; checks carried out on lifting points used for transport of concrete blocks; asbestos hazard awareness among staff; storage of compressed gas cylinders; and general condition of the external yard around the offices.
Areas requiring improvement included: labelling of 140 litres of cadmium containing containers (priority); procedures for unlocking site fire exits (priority); revision of procedures for the safe operation of 5-tonne overhead travelling crane and re-assessment of risks relating to people/machinery interaction (priority); and review of ICRC asbestos management arrangements and written Asbestos Management Plan in a view to retain ownership of such arrangements at a local level.
The overall impression gained from the inspection was a positive one. The ICRC senior managers appear to have a good attitude towards managing conventional health and safety on site and were receptive to the regulatory advice provided. There are some gaps in the management of specific H&S risks and hazards and there is further assurance on compliance to be explored with the site.
Priority actions were identified during the inspection. 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 address and implement the required improvements.
As a result of this regulatory interaction, confidence was obtained in ICRC intent to act on the priority observations made. Therefore, matters required attention will be confirmed to the site by email and the response monitored. Progress against the areas for improvement will be assessed via discussion/correspondence with the site.