Asbestos containing materials (ACMs) inspection at Hinkley Point A
- Site: Hinkley Point A
- IR number: 16-076
- Date: February 2017
- LC numbers: N/A
Purpose of intervention
To review the adequacy of Magnox Ltd.’s arrangements for managing asbestos containing materials (ACMs) at their Hinkley Point A (HPA) site during decommissioning activities.
This inspection is one of a series of planned visits to selected sites across the Magnox fleet and includes separate, corporate engagement with Magnox Ltd. Collectively, the visits make up the intervention.
Interventions Carried Out by ONR
The key regulatory activities undertaken during this 1.5 day inspection were based around an agenda previously agreed with Magnox HPA. Plant visits were chosen without prior notice to HPA; and undertaken to ascertain whether existing asbestos management arrangements are such that: risk presented by asbestos containing materials (ACMs) is being controlled; and that those controls are adequate for the size of the organisation, and appropriate for the nature of Magnox Ltd.’s undertaking.
Locations visited during the intervention were selected using regulatory intelligence gained from information received from site, discussions with the site during the opening meeting, and a review of the site’s inventory of suspected or confirmed asbestos.
Key performance indicators used to assess the adequacy of organisational and physical control measures were broadly based on the requirements of sections 2 & 3 of the Health & Safety at Work etc. Act 1974 and relevant statutory provisions made under the Act. These include: Management of Health & Safety at Work Regulations 1999 (regulation 5), and the Control of Asbestos Regulations 2012 (CAR 2012) and the associated Approved Code of Practice, in particular regulation 4 and paragraphs 81-147.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
A programme of asbestos stripping was commenced by site some years ago, but stalled due to relocation of the funding required to complete the work by Magnox Ltd. This has left site in a vulnerable position for some years.
Efforts to remedy (i) have recently been reinvigorated, since which, progress at HPA has been made in a number of areas of asbestos management, including reviewing action plans, setting to work and the verification of data inputting and migration into the (relatively new) Elocate system.
Notwithstanding (ii) Magnox and ONR both agreed that whilst the use of Elocate afforded asbestos management-benefits; fluent use of it as a reliable system is still some way off.
Acknowledgement was made by site of the need to implement more robust decision-making when a) implementing control measures (e.g. protection/enclosure of ACMs to a good standard); b) managing those control measures (dealing with ACMs rather than relying mid-long term on interim arrangements) and c) balancing the risks from nuclear safety against those from asbestos.
Competent site based resource (with corporate support) is developing and embedding well for proactive asbestos management, following a number of staff (role) changes. Site is fully aware of the required, sustained long term focus in this area.
There was recognition by site that, despite a lot of effort having being undertaken to improve site-specific arrangements for managing ACMs, there was still “some way to go”. The Site Closure Director commented on how helpful the inspection had been in helping him re-calibrate where site is on its management of ACMs and how far short they are from where they want to be.
Conclusion of Inspection
ONR reported that whilst the inspection had not been a full and thorough inspection of the entire arrangements and implementation across site, observations made had evidenced the following positive aspects:
- Clear commitment of current site LACP and ACPs; with ongoing commitment from site to train 12 further ACMs in March 2017.
- Engaged leadership.
- Thorough verification programme of information on Elocate being, and continuing to be undertaken on Elocate.
- Setting to work, incorporating HPA’s new streamlined process, was thoroughly employed and competently managed for the work package chosen at random.
Site was made aware that in the Inspectors’ opinions, the following aspects still require attention:
- Work being undertaken to protect ACMs needs reviewing.
- The site’s reliance on restricting access to asbestos areas needs reviewing.
- Elocate requires an ongoing plan for improved-use, which should include reviewing who has access; and improving the user-fluency of the system.
- Where there is a presumption of asbestos presence, this should be investigated and clarified.
- Sheeting standards in use across site; and the negotiation of the balance between the effort of protection of (and from) ACMs verses the effort of removal – particularly when Radiological and Industrial safety hazards are both present.
- Use of the new corporately-provided POWSA book needs refresher training as it contains an error-trap in its design.
ONR confirmed that the rating being given following this intervention was Amber. ONR concluded with an expectation on site to respond to the inspection by letter to ONR – an action agreed by site with an agreed timescale of three weeks (letter due 10th March 2017). An e-mail will be sent to site summarising the key actions arising from the intervention – to assist the site in preparation of their response.
ONR has a regulatory issue relating to Magnox Ltd. and asbestos management at an organisational level (issue number 4789). However, it is also proposed that a Level 3 regulatory issue is created for asbestos management at the Hinkley A site, subject to ONR’s internal governance procedures.