To obtain an overview of Low Level Waste Repository (LLWR) Ltd. 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. Two of these topics are workplace transport safety and control of contractors.
The nature of the LLWR site is that there is a high reliance on vehicle movements to complete key activities undertaken on site. In addition, LLWR have a significant number of contractors working on the site. Therefore, this intervention sampled significant vehicle movements and contractor activities underway during the visit.
The key regulatory activities undertaken during the two day inspection were based around:
During the visit LLWR provided a company overview, an overview of future operations & a summary of arrangements for managing non-nuclear H&S.
Two walkdowns of a number of non-RCA locations were undertaken to learn more about the site layout and key activities undertaken by LLWR, sample activities underway at the time of the visit and obtain an overview of the management arrangements in place, focussing on workplace transport activities. 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:
A number of areas of good or best 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 LLWR.
Areas of good or best practice seen during the visit included the level of training provided to CHS personnel, widespread use of podium steps across the site, general housekeeping, and the condition of vehicle routes/pedestrian walkways in the area around the offices.
Areas requiring improvement included: driver visibility of a Komatsu 360o excavator being used for piling operations (priority), LLWR standards and expectations regarding excavator quick hitch devices, the need to formalise arrangements for inflating split rim wheels, formal arrangements for assessing driver visibility for vehicles used on the LLWR site, and LLWR ownership of asbestos surveying and monitoring for reassurance purposes.
The overall impression gained from the inspection was a positive one. The LLWR senior managers met appear to have a good attitude towards managing CHS on site and were receptive to the regulatory advice provided. The on-site CHS team are suitably qualified and experienced and are further developing CHS management arrangements to include assurance processes. It was evident that a significant amount of time and effort had been invested in managing CHS hazards present as a result of the core activities undertaken on the site, namely the grouting of isofreight containers, storage of the containers in the vaults, and localised decommissioning activities. However, priority actions were identified during the inspection, such that compliance with legislative requirements is not currently being met. The site provided a written commitment to take prompt action to rectify the deficiencies identified.
As a result, confidence was obtained in LLWR’s intent to act on the priority observations made. Therefore, an e-mail will be sent to LLWR regarding the required actions and requesting a response. Progress against the areas for improvement will be monitored via discussion/correspondence with the site. A CHS rating of ‘4 – below standard’ is applied to the safety aspect of the visit and a regulatory issue will be added to the ONR Regulatory Issues database for tracking purposes. However, a CHS rating of ‘2 – good standard’ is applied to the health and safety management aspect of the visit.