The Intervention was carried out at the Wylfa Nuclear Licensed site and was undertaken to review the arrangements in place to manage site asbestos containing materials (ACMs) as required by the Control of Asbestos Regulations 2012, Regulation 4. There are approximately 4000 deaths from asbestos related diseases in the UK each year. Of these people dying, 25% are tradesman such as builders, plumbers, carpenters and electricians. This equates to 20 tradesmen each week. Hence managing and working with ACMs is a priority nuclear site conventional health topic.
The Control of Asbestos Regulations 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 and requires duty holders to identify the location and condition of asbestos and to manage the risk to prevent harm to anyone who works on buildings or to building occupants. 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 Wylfa site to have health and safety arrangements that are appropriate for the nature of the activities and the size of the undertaking.
I visited the Wylfa licensed site for the two days of the 5th and 6th January 2016. I was accompanied on the first day by [redacted] (ONR Principal Conventional Health and Safety Inspector).
On the 5th January we had an introductory meeting during which the sites EHSS&Q manager and LACP provided an overview of the key personnel involved with asbestos management on the site and of the asbestos management arrangements. There was also an explanation of the new phase of site operations with the ending of power generation on the 30th December 2015. The Magnox Corporate asbestos programme manager gave background on a new company wide asbestos management database and of the longer term company aims in relation to asbestos management. We carried out visits to a number of specific areas within the licensed site to review the effectiveness of the asbestos management procedures and arrangements against the requirements of CAR ACOP 2012 and MHSWR 1999. Discussion took place with a range of relevant staff in relation to the workings of the asbestos management procedures and arrangements for dealing with ACMs.
On the 6th January 2016, I held a meeting with a number of the site safety representatives to explore their experiences of the site asbestos management arrangements. I then visited other areas within the licensed site to observe the asbestos management arrangements taking the opportunity to speak with staff where possible. The asbestos analyst provided an overview of the current asbestos database which holds site asbestos survey records. Finally, I took part in a feedback meeting attended by key staff who had taken part in the intervention along with a number of the safety representatives. During this meeting I gave an overview of my findings.
Wylfa have recently revised their approach to managing asbestos within a draft asbestos management plan document reference WAY-AMP-MCP/014/009 (Form F-866620). This document is the site implementation of a new company asbestos management standard which was launched in September 2015 – Document S-267. The document sets out the procedures and associated roles and responsibilities to be followed when working with ACMs and has been updated to better reflect the requirements of the Control of Asbestos Regulations 2012. Prior to the production of a site based S-267 document Wylfa set out its management control procedures for asbestos management within document NO. 014 Part 009 Safe handling of asbestos products. The site is therefore currently in a transition phase between these two documents.
The site maintains and updates a ACMs register database (ACE PSI) which is held electronically and which is divided into relevant buildings and specific locations. Asbestos surveys are carried out by site based analyst staff who also carry out on site analysis of suspect asbestos materials via their UKAS accredited site laboratory. Staff spoken to during the intervention all had a good knowledge of who on site could provide specific advice and guidance in the event of a concern over an actual or suspected ACM.
A new company database (E-Locate) is in the process of group roll out but was not currently operational at Wylfa.
Action was found to be required by Wylfa in number of areas in order to improve their management and work with ACMs. These requirements are set out below:
Priority: Turbine Hall Unit 1 (Deaerator floor: [redacted] to [redacted] location) – the site needed to deal appropriately with three small areas of asbestos pipe lagging where encapsulation was seen to have degraded. These were located on a redundant steam pipe. It was agreed that the LACP would make urgent arrangements to deal with this matter.
Priority: Reactor 2 (External Pipe Bridge area) – significant cracking was visible in two areas of redundant steam pipe cladding while water ingress had damaged a separate section of metal cladding exposing lagging material. These areas required further investigation work to check for the potential presence of ACM and agree any remedial work. This was agreed with the LACP.
Priority: The site asbestos management plan requires the re-inspection of all ACM’s on a minimum 12 monthly basis. The site is currently significantly behind in this requirement and a second analyst has been employed on a temporary basis to help achieve this aim. This matter requires continued senior site management oversight.
Priority: The site asbestos register database contains the details of ACM locations along with material and priority risk information. This database risk information should be reviewed urgently and a site asbestos action plan produced. This plan should provide a suitable level of clarity that there are appropriate management arrangements in place for the sites high and medium risk ACM locations. The immediate focus of the database review should be on those areas currently identified in the database as high risk.
Priority: the asbestos register should be checked prior to work starting on the fabric of the building. Efforts should be made to improve the use of the register by key staff such as site engineers and SPT’s. There should not be an over reliance on the ACP function to provide ACM information and additional training may be prudent for SPT and other staff who are required to access the register and co-ordinate work.
Provision of information to workers prior to work commencing: ACM information contained within the asbestos register should be enhanced via the use of ACM photographs and drawings. Drawings should include the main features of the rooms along with the locations of the ACM’s.
Inspection frequency of ACM locations: Some of the ACM materials observed during the visit had been inspected within the previous 12 months but had subsequently deteriorated to a point where remedial work was necessary. Locations that are exposed to potentially accelerated deterioration will need to be inspected more frequently than every 12 months.
Corporate oversight and learning: A corporate asbestos intervention with Magnox is being planned with an expected start date in April 2016. The intervention will explore a number of the learning issues discovered during the Wylfa visit.
There was a positive recognition by both the site and corporate asbestos management team that the matters raised during the intervention merited their attention and action. The site was keen to complete the required improvements and also intended to reflect on and understand their current position.
The EMM was considered and a letter to Wylfa was identified as the appropriate mechanism to progress these matters. A follow up visit will be made in Q3-Q4 of 2016 to determine if the required action has been taken.
The site were required to provide written confirmation that the priority issue identified in the Turbine Hall had been actioned as a matter of urgency.