To obtain an overview of the Sizewell B arrangements for managing conventional health and safety and undertake site familiarisation, including the inspection of selected activities underway during the 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. In line with HSE’s national priorities and intelligence collated by CHS Team the EDF corporate intervention relate to the Control of Substances Hazardous to Health (COSHH).
On the 15th April 2016 the Pressurised Water Reactor entered the first phase of a refuelling outage which is scheduled to last for 6 weeks. In addition to 520 permanent EDF employees and 250 full time contract partners the site will engage additional 1200 contractors for the time of the outage. This was recognised by both the EDF and ONR as an additional challenge in respect of control and supervision of contractors and management of health & safety during the outage.
The visit took place over the period of preparation for the outage therefore actual outage activities did not form a part of this intervention. At present the main activities taking place on the site relate to isolation of electrical systems, removal of walls, maintenance works on steam generators, lifting operations, organisation of site for the arrival of contractors, marking of traffic routes, scaffold erecting and preparation of areas where confined space work will be carried out. This intervention sampled key activities proceeding during the visit.
The key regulatory activities undertaken during the two day inspection were based around:
During the introductory meeting with site personnel the role of the ONR Conventional Health & Safety Team and the purpose of the visit were explained. Sizewell B provided a company overview, an overview of outage preparations & a summary of arrangements for managing conventional H&S.
A walkdown of a number of non-RCA locations was undertaken to learn more about the site layout and key activities undertaken by EDF, sample control of risks of 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 conventional health & safety management rather than being a detailed inspection of one particular topic, nonetheless the focus of the intervention was on the control of contractors and COSHH.
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:
Management of Health and Safety at Work Regulations 1999, Work at Height Regulations 2005 (as amended), Lifting Operations and Lifting Equipment Regulations 1998, Provision and Use of Work Equipment Regulations 1998, and the Control of Substances Hazardous to Health Regulations 2002.
The visit concluded with the provision of regulatory feedback to the duty holder.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
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 Sizewell B.
Areas of best or good practice seen during the visit included:
Areas requiring improvement included:
The overall impression gained from the inspection was generally positive. The Sizewell B senior managers appear to have a very enthusiastic and engaging attitude towards managing conventional health and safety on site and they were highly receptive to the regulatory advice provided. The system for the management of conventional health & safety appear to facilitate a large number of tools aiming to promote, advocate and implement safe working attitudes across the site.
There are some gaps in the management of specific H&S risks and hazards and priority actions were identified during the inspection. Solutions to the issues were proposed and assurances were provided by the site management to rectify matters identified. Review of risk assessments concerning COSHH (such as the control of Legionella, painting activities, welding of stainless steel) must be carried out and any improved risk control measures identified must be implemented. Workplace transport arrangements will be reviewed and gaps in risk control addressed. There was a positive recognition by the management that matters raised during the intervention merited their attention and action. It is expected by the ONR that EDF Sizewell B maintains a commitment towards improvements taking into account SMART actions that will be communicated to the site following this intervention.
As a result of this regulatory interaction, confidence was obtained in EDF’s 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.