Office for Nuclear Regulation

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Urenco UK Ltd - Inspection of arrangements for managing asbestos containing materials (ACM's)

Executive summary

Purpose of Intervention

This intervention is a continuation of a 'setting to work'/ Control & Supervision intervention that was carried out by ONR at the Urenco UK Ltd. Capenhurst site in March 2017. Asbestos related concerns were identified during the March 2017 intervention such that it was determined a follow up intervention focussing specifically on asbestos management was required to review the adequacy of Urenco UK Ltd.'s arrangements for managing asbestos containing materials (ACMs) at the Capenhurst site.

Interventions Carried Out by ONR

The key regulatory activities undertaken during the visit were used to ascertain whether existing asbestos management arrangements:

The locations were selected using regulatory intelligence gained from previous interventions, review of the site's asbestos inventory and UUK asbestos related event reports.

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

UUK acknowledged the shortfalls identified in early March 2017 and explained how the findings had prompted a programme of work to address the findings. The UUK Head of Technical Services also explained that an investigation was running in parallel to establish why the shortfalls were in place and address the root causes.

Progress has been made in a number of areas of asbestos management, including reviewing documented arrangements, and providing asbestos awareness training to UUK workers. UUK personnel met or spoken to showed an evident increase in awareness of asbestos related matters.

Whilst the UUK site asbestos management plan has been recently reviewed and revised, the plan requires further review and revision to meet legal/ACOP requirements.

Priority - Permit issuers spoken to were not able to find requested ACM information within the UUK inventory or articulate a consistent approach to identify the presence (or otherwise) of ACMs that would ensure workers that may disturb asbestos were appropriately informed prior to starting work.

Priority - Work on an air conditioning system was temporarily stopped after it became apparent that the presence (or otherwise) of ACMs had not been considered during work planning. The relevant parts of the asbestos register and survey were subsequently reviewed and ACMs were confirmed to not be present in the work location. However, it was emphasised that this information should have been obtained during UUK's work planning processes.

Priority - The Site Evacuation Centre has numerous examples of asbestos insulation board located within the centre. Some of the ACMs in the centre are damaged or cracked such that they are not in a state of good repair. Access has since been restricted to the centre and discussions underway between UUK and their nominated asbestos removal contractor regarding removal, repair or enclosure of the damaged ACMs in this building. Air monitoring was also undertaken which confirmed that asbestos fibre sampling results were below the limits of detection.

UUK encountered some difficulties in identifying ACMs recorded on the asbestos register, including in offices in B267 where asbestos insulation board had been identified in a survey. This led to questions being asked of the accuracy of the information within the asbestos register and the associated asbestos surveys.

Priority - UUK disclosed that the tenancy agreement between UUK and Urenco Chemplants (UCP) is not clear in terms of who has responsibility for the maintenance and upkeep of the buildings occupied by UCP, an important aspect of asbestos management which UUK is in the process of addressing.

Priority - UUK uses an electronic database as a register to manage its asbestos inventory across the site. The register has been populated using both historic and more recent asbestos survey information provided by UUK's current asbestos surveyors. From the items reviewed within the register it was evident that information as to whether asbestos is present in work areas is not readily available or accessible.

Conclusion of Intervention

Feedback was provided at the end of the site visit. The UUK Head of Technical Services committed to act on the inspection findings and prompt action was taken by the Site Operations Manager to restrict access to the site evacuation centre. UUK also committed to reflect on and understand their current position with respect to conventional health and safety more generally (confirmed in letter received 13th April 2017).

ONR stated that it was evident that UUK has made a significant amount of progress in the last month to review and revise existing asbestos management arrangements. However, while the prompt review by UUK is positive, ONR established via the discussions with UUK personnel, review of relevant documentation prior to the inspection and plant visits that significant gaps remain in UUK's arrangements.

It was explained that the priority matters identified were such that the visit outcome was identified to meet ONR's inspection rating of 'inconsistent standards for managing risks to workers; with some key relevant statutory provisions not met'. This in turn indicates that an inspection rating of below standard to be appropriate.

An enforcement letter will be sent to UUK Ltd. for the priority actions identified. Action progress will be monitored via discussions and site revisits as appropriate. An ONR issue will be raised to track progress with the matters identified.