The Intervention was carried out at the Bradwell Nuclear Licensed site as part of the ONR strategic intervention examining the arrangements Magnox Ltd. has in place to manage the risks presented by its asbestos inventory during decommissioning works, and during preparations for entry into Care & Maintenance (C&M). There are approximately 5000 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 Asbestos Containing Materials (ACMs) is a priority nuclear site conventional health topic.
Bradwell site have completed the bulk removal of asbestos, project which has been highly complex and that have cost many millions to complete. Despite this work, a significant amount of ACMs remain on the sites and Magnox are not planning to remove all ACMs prior to site's entering C&M currently scheduled for 2019.
Sampling of other conventional health & safety activities was carried out during site familiarisation walkabout. Findings were addressed according to their significance.
The key regulatory activities undertaken during the two day inspection were based around:
The visit took place over the 22nd and 23rd June 2016. On the 22nd June (Day 1) introductory meeting with relevant site personnel and site Closure Director took place. ONR Inspectors explained the role of the Conventional Health & Safety Team and the purpose of the visit which was to explore current and long-term asbestos management arrangements in the light of the site's asbestos inventory and forthcoming entry into C&M. ONR Inspectors advised all present that any additional matters arising from the site familiarisation visit will be addressed according to the significance of the findings.
Site Management provided an overview of the current and forthcoming activities on the site scheduled for the next 3 years and an overview of site asbestos profile. The site is in a final decommissioning stage moving towards C&M currently scheduled for 2019. There is a significant amount of ACMs throughout the site that still need to be managed in line with regulatory expectations. The site holds an asbestos register with approximately 800 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 (AMP) underpinned by the Company Standard S-267.
ONR carried out visits to a number of specific areas within the site to review the effectiveness of the asbestos management arrangements against the requirements of Control of Asbestos Regulations (CAR) 2012, associated Approved Code of Practice (ACOP), and the relevant parts of the Management of Health and Safety at Work Regulations 1999 (MHSWR 99).
At Bradwell many buildings are planned to be demolished therefore it was imperative to find out what challenges will be associated with the presence of ACMs and demolition works. Some buildings will be left in situ hence it was of a great importance to find out what Magnox plans are for long-term management and monitoring of ACMs. ONR met site Lead Asbestos Competent Person who is the first source of information/advice in regard to asbestos management and assists and advises the site on all aspects of asbestos management.
During the visit discussions were held to explore Magnox Bradwell understanding of timely and effective management of asbestos. ONR sampled several entries on the asbestos register in order to learn how information is stored and used. Discussions were held to understand how information about asbestos risks is communicated to workforce and how it is applied into work planning. Enquiries concerning the management of asbestos waste were also made.
During the visit individual meetings with site Closure Director and Infrastructure Manager took place. Their roles and responsibilities were explored and asbestos management arrangements and procedures discussed. A meeting with site Safety Representatives to sample their experiences of the site asbestos management arrangements also took place. ONR also met with the site Internal Regulator to discuss the asbestos management auditing function. A short meeting was held with the Magnox Bradwell Waste Manager to obtain an overview of the site's arrangements for managing asbestos waste arising from the removal works that have been undertaken at the site and were underway at the time of the ONR visit.
ONR visited the following key locations to get an appreciation of the extent of ACMs present on site: Bypass Filter Rooms - Reactors 1 and 2, Circulator Hall, Building 83 - Old Training Room, Building 68 - EHS&Q, Asbestos Waste Storage Area and Engineering Workshop.
Day 2 concluded with the provision of regulatory feedback to the duty holder. During this meeting ONR gave an overview of visit findings and informed the duty holder of the outcome of the visit.
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 Bradwell site to have health and safety arrangements that are appropriate for the nature of the activities and the size of the undertaking.
Magnox Bradwell carried out revision of their approach to managing asbestos within an Asbestos Management Plan (AMP) doc ref: BRAD/AMP/001. 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.
Upon reviewing site asbestos management arrangements it has been identified that these are inadequate and the Magnox approach does not satisfy the requirements of CAR 2012. AMP does not reflect long-term arrangements for the management and monitoring of ACMs that will be left in-situ and those that are destined for removal.
In terms of other areas of ONR intervention, there was evidence that the assessment of risks associated with the use of engineering workshop machinery has been insufficient as guarding arrangements on Colchester lathes, milling machines, guillotine and bandsaw was sub-standard.
Action was found to be required by Bradwell in a number of areas in order to improve their management and work with ACMs and satisfy compliance with health & safety legislation:
In addition areas for improvement were identified; Magnox need to ensure that the asbestos register is checked prior to work starting on the fabric of the building or where ACMs could be disturbed. Efforts should be made to improve the navigation within the register to maximise ease of use and the quality of information stored on the asbestos register should be reviewed
The overall impression gained from the inspection was that Bradwell management appear to 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 long-term approach to the management of asbestos.
A number of priority actions were identified during the inspection, as in a number of cases compliance with legislative requirements is not currently being met. In such cases, 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 company were provided with feedback on the 23rd June 2016 during which the issues set out within this report were discussed and were accepted by the management team who were positive both in relation to their desire to complete the necessary improvements and to reflect on the issues raised. The extent and content of assurances provided by the site Closure Director during the feedback session were welcomed by ONR CHS Inspectors.
After considering the ONR Inspection Rating Guide the site were rated Amber - below standard for the following reasons: