The purpose of this intervention was to provide regulatory confidence in the management of conventional health and safety (CHS) hazards present at EDF Energy Nuclear Generation Limited’s (NGL) Dungeness B (DNB) power station during its reactor 21 outage. This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2017-18.
The ONR CHS strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Asbestos management, work at height, and LPG management are three of the priority topics referred to in the strategy. These topics were the key topics of focus during the intervention.
The key regulatory activities undertaken during the two day inspection were based around:
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: the Work at Height Regulations 2005 (as amended), the Dangerous Substances and Explosive Atmospheres Regulations 2002 and the Control of Asbestos Regulations 2012.
Asbestos management – Asbestos containing materials seen during the intervention were clearly identified and in good condition. However, a number of observations were made that indicate that the licensee is not taking a sufficiently proactive role in managing ACMs to the extent required given the nature and extent of ACMs located on the site. In addition, observations made during the intervention suggest that the current arrangements for the provision of information to workers do not fully reflect the requirement that NGL should proactively provide clear information to workers and check understanding prior to work commencing.
Management of the LPG installation – A number of physical control measures are in place that meet relevant good practice or best practice standards. However, improvements are required to some aspects of the organisational control measures for the LPG installation. In particular, NGL did not demonstrate that risks arising from the presence of several drains/gullies in close proximity to the installation/pipework (where LPG gas could accumulate in the event of a leak) had been assessed; and the presence of building/s that may be within established separation distances for LPG installations. The liquid phase LPG pipework present within the installation increases the risk level.
Management of work at height activities – Examples of good control of work locations involving work at height activities were seen. In addition, the licensee has identified work at height activities as a ‘significant risk’ in the company work planning process and as such additional hold points are introduced during work planning involving work at height activities including the requirement for a significant risk permit to be completed before work activities commence. However, this part of the intervention identified that further regulatory assessment of NGL’s arrangements for planning work activities is required – to determine the effectiveness of NGL’s arrangements, including the competence of Work Specifiers (key personnel in the work planning process) to identify actions required to comply with relevant legislative requirements. Further regulatory contact is also required regarding roof area risk assessments. Further contact with NGL at both site and corporate level is planned. Decisions regarding the need for capturing these observations as ONR regulatory issues will be determined following these contacts.
A number of examples of good standards were seen during the visit in addition to a number of areas for improvement. These were summarised during feedback provided at the conclusion of the visit, as were the visit outcomes/actions required by NGL. The Station Director was not present at the feedback. However, a number of safety personnel were present at all times of the inspection and all were clearly engaged in the inspection process.
It was evident that Dungeness B industrial safety personnel have put a significant amount of effort into managing CHS hazards present as a result of the various outage activities underway. Notwithstanding this effort, a number of regulatory actions were identified during the inspection; these will be followed up by ONR.
Two regulatory issues have been raised in relation to the site wide asbestos management arrangements and LPG installation. This element of the intervention is therefore rated as ‘amber – below standard’.
The ONR Enforcement Management Model and associated guidance has been considered in relation to the actions identified. The indicated enforcement outcome for matters relating to asbestos management and management of the LPG installation is an enforcement letter.