Wylfa - Review the adequacy of Magnox Ltd.'s arrangements for managing asbestos
- Site: Wylfa
- IR number: 16-071
- Date: February 2017
- LC numbers: N/A
Purpose of intervention
The intervention was a continuation of a visit undertaken in December 2016 to assess the condition of asbestos containing materials (ACMs) in the Turbine Hall & Reactor buildings & establish actions being taken by Magnox Ltd. to manage the possible degradation of ACMs. More specifically, the purpose of the intervention was:
- To review the adequacy of Magnox Ltd.’s arrangements for managing asbestos containing materials at the Wylfa site in light of potential changes to the condition of asbestos materials after power generation at the site ceased.
The intervention also follows on from an asbestos management intervention that was carried out at the Wylfa site in January 2016.
Interventions Carried Out by ONR
The key regulatory activities undertaken during the one day visit were based around an agenda previously agreed with Magnox Wylfa. Plant visits were undertaken to ascertain whether existing asbestos management arrangements:
are such that risk presented by asbestos containing materials (ACMs) is being controlled, and
- are such that they 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 previous interventions, recent interactions with the site, and review of the site’s inventory of materials assessed to be ‘high risk’.
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, particularly regulation 4 and paragraphs 81-147.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
A good level of competent site based resource (with corporate support) now appears to be developing for proactive asbestos management. The Wylfa Site Director is stating his commitment to addressing the known issues on the site. It was emphasised by ONR, and acknowledged by the site personnel met, that the remedial actions require sustained long term focus.
Progress has been made in a number of areas of asbestos management, including reviewing action plans, briefing site workers and condition monitoring of known or presumed asbestos materials.
Compromises to Magnox’s ability to undertake accurate risk profiling were identified, examples are summarised below. The compromises impact on Magnox’s ability to; accurately identify the full nature and extent of risk presented by asbestos containing materials at the Wylfa site, and; concentrate resource to where it is most required.
- The Wylfa site has a large inventory of materials known or presumed to be asbestos containing. Approximately 75% of the items identified are presumed to contain asbestos as they haven’t been sampled, but (in accordance with CAR 2012) are designated suspected ACMs.
- The Wylfa lead asbestos competent person has previously explained that he does not have confidence in the standard of ACM stripping carried out prior to 2005. Therefore, there are numerous presumed ACMs where asbestos residues may be present beneath more recently applied non-asbestos pipe lagging. This approach is in accordance with the legislative requirements and is supported by ONR. However, the site’s risk assessment methodology does not appear to differentiate between possible asbestos residues under non-asbestos pipe insulation and asbestos pipe insulation. This in turn impacts inventory risk profiling.
- Examples of materials were seen that did not reflect the designated risk score applied by analysts working on behalf of Magnox. In addition, validation of the risk scores did not appear to be routinely undertaken by Magnox. Magnox Wylfa cannot currently place full confidence on the scoring system used within asbestos risk assessments to inform risk profiling and prioritisation of actions.
Known or presumed ACMs classed by Magnox as ‘high risk’ were seen in a number of locations around the Turbine Hall and Reactor Building. A variety of ACMs were seen ranging from debris to pipe insulation in both accessible and inaccessible areas. Magnox Wylfa has an extensive air monitoring programme underway to provide reassurance that airborne asbestos fibres are not present in these locations. In addition, work is underway or planned to remove, repair or enclose presumed ACMs in the Turbine Hall. However, Magnox was not in a position to articulate similar action for ACMs within the Reactor Building. Concern was expressed that Magnox is not taking appropriate action to manage asbestos materials such that they are in a good state of repair.
NB. Findings iii. and iv. have implications for Magnox Ltd. at a corporate level, and this is being taken forward by ONR as part of an ongoing corporate intervention.
Conclusion of Intervention
There was recognition by both the site and corporate asbestos management team members present (including the Wylfa Site Director) 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.
However, it was explained that the extent of the degraded asbestos materials identified at the Wylfa site and lack of supporting arrangements to manage the material according to risk were such that the visit outcome was identified to meet ONR’s inspection rating of ‘shortfalls in health requirements resulting in significant avoidable risks to workers, with at least one contravention that gives rise to a discernible risk gap under the ONR EMM’. This in turn indicates that an inspection rating of ‘red - significantly below standard/unacceptable’ should be applied to the visit.
The ONR Enforcement Management Model (EMM) has also been considered in relation to the other priority actions identified and the enforcement outcome is being considered in line with established ONR procedures. However, an enforcement letter will be sent to Magnox Ltd. for the other priority actions identified, regardless of any enforcement outcome decisions currently being determined for asbestos management at the Wylfa site.
In addition, consideration will be given regarding whether regulatory action needs to be taken at a corporate level. A meeting is planned with Magnox corporate personnel on the 28th March 2017. This meeting will inform any actions taken at an organisational level.
Related issues on the ONR Regulatory Issues database (4168 and 4789, both level 2) will be reviewed and amended as required to reflect the visit findings.