This inspection was a continuation of two interventions that were carried out by ONR at the Urenco UK Ltd (UUK Ltd) Capenhurst site in March and April 2017. The regulatory findings from these inspections were such that UUK Ltd was requested by ONR to review and where necessary revise its arrangements for ‘setting personnel to work' and managing asbestos containing materials located on the site. ONR determined a follow up inspection was necessary to establish whether UUK Ltd had completed the required reviews/revisions to an appropriate standard.
The key regulatory activities undertaken during the visit were based upon an agenda previously agreed with UUK Ltd. Site visits were undertaken to ascertain the effectiveness of setting-to-work arrangements for high hazard operational and maintenance activities, with associated competently resourced control procedures. UUK Ltd's arrangements for the management of asbestos were reviewed as part of the setting to work arrangements.
Areas of focus included consideration of the following aspects associated with setting to work:
With respect to asbestos management the key regulatory activities undertaken during the visit were:
ONR explored key roles in the setting-to-work procedure and how this interfaced with asbestos management and high hazard activities on site. ONR explored training and experience; observed a range of UUK Ltd setting to work arrangements; witnessed the completion of a Task Risk Assessment and how the asbestos register was consulted in this process; observed the role of contractors in setting to work arrangements and how relevant site hazards were communicated to the contractors. Information was sought from appointed Health and Safety Representatives, staff and contractors at all levels.
UUK Ltd documentation was seen in advance of and during the intervention. Key performance indicators used to assess the adequacy of organisational and physical control measures were based on the requirements of Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and relevant statutory provisions made under the Act. These include the Management of Health and Safety at Work Regulations 1999, The Control of Asbestos Regulations 2012 (CAR 2012), and the associated Approved Code of Practice (L143), particularly regulation 4 and paragraphs 81-147.
UUK Ltd acknowledged the shortfalls identified in the previous interventions. The Acting Chief Nuclear Officer explained that a programme of work had been undertaken to review the Company's arrangements for risk management of conventional health and safety high hazard activities. An improvement plan which prioritises key areas had been prepared and shared at Board Level. There was recognition, at the conclusion of this intervention, by senior management that further work remains to be done.
Progress has been made in a number of areas and examples of good practice were seen, associated with the development of the UUK Ltd Safe System of Work Manual (UUK-SSOW-MAN-01) during the intervention. From personnel spoken to, it was clear that there had been significant improvement on former setting to work arrangements. The key roles and responsibilities of the Safe System of Work (SSoW) process, the Area Authority (AA) and Permit Issuer (PI) are defined in the SSoW Manual and site personnel seen were clear of their roles.
UUK Ltd has reviewed its Safe System of Work Policy, pursuing a risk based approach, dealing with significant risks. The issue of permits has been restricted. The approach references certain high risk activities including hot work, confined space entry, roof access, excavations and electrical work. UUK Ltd use a Task Risk Assessment (TRA) which identifies that if a residual risk from other activities is classed as higher than 4 then a permit should be issued. The revised system has reduced the number of permits being issued. It is estimated that the risk based approach is resulting in a more proportionate issue of permits, covering approximately 30% of work. However, ONR found that some permit issuers were still issuing for work not covered by the criteria.
ONR recommended to UUK Ltd that it should continue monitoring setting to work arrangements to ensure that permits to work are being issued for the defined activities and deliver the necessary control, with the appropriate updating of the Safe System of Work Manual to reflect any changes arising.
Electrical Safety Rules on site have been revised to reflect recognised UK industry practice. Live working is restricted to phasing and network modification and live working procedures have been introduced. Training for electrical nominated persons has been rolled out and there has been positive feedback regarding this training which is to be extended to other key personnel. It is recognised that there is some overlap between isolation certificates and the general work permit.
ONR recommended that permit issuers who issue the general work permit and nominated persons who issue the isolation certificate should understand the interface between the permits and their individual role and responsibilities when an isolation certificate is required. UUK Ltd should conduct in-use testing of these arrangements and implement any necessary actions arising.
UUK Ltd had produced a task risk assessment for a specific piece of work which was to be undertaken by a contractor on site who in turn had produced a risk assessment. It was unclear how specific workplace risks (with the exception of the risk from asbestos) were communicated to the contractor and incorporated into their risk assessment. A joint assessment should be completed to ensure that on-site risks are fully identified and incorporated into the contractor risk assessment.
ONR recommended that UUK Ltd have a legal responsibility to manage contractors on site and ensure on site risks are communicated to contractors. UUK Ltd should review how site specific risks to contractors are communicated and incorporated into contractor risk assessments and respond accordingly.
UUK Ltd use an electronic database as a register to manage its asbestos inventory on site. The register has been updated following a recent asbestos survey. The Site Operations Manager stated that whilst he had confidence in the updated register, the limitations of the present system are recognised and UUK Ltd are in the process of procuring an on-line version of the asbestos register.
UUK Ltd has produced work instructions for guidance regarding asbestos management. The document "Working on or near Asbestos Materials (ACMs)" (UUK-FAC-INST-ACM-002) provides guidance on the process to follow during the planning stages of a work activity, to ensure that the risks from ACMs are adequately considered. Flowcharts produced in this document described the process for operatives to take depending on the type of work to be undertaken (non-intrusive, intrusive and excavation). Before work is undertaken a Task Risk Assessment (TRA) or Risk Assessed Procedure (RAPs) is produced, the asbestos register is checked and the relevant flowchart is attached with confirmation that a Permit Acceptor has checked that the risk from asbestos has been considered for all work. UUK Ltd personnel and maintenance contractors spoken to showed an awareness of asbestos related matters and were positive about the process.
ONR recommended that the flowcharts in document UUK-FAC-INST-ACM-002 should be reviewed to improve clarity and technical accuracy. It was advised that document owner should conduct in-use testing of the asbestos management arrangements to deliver the necessary control.
Significant progress had been made with asbestos awareness training. Classroom asbestos awareness training to operatives identified as requiring training has been provided. (273 individuals have been identified. Out of these 119 have completed training, 118 are registered to attend and 36 individuals are outstanding). Comments received about awareness training from operatives were positive.
Although it was evident that UUK Ltd had made significant progress in both setting-to-work arrangements and management of asbestos ONR made several recommendations where the licensee should make improvements. These included gaps in key areas including the management of legionella and the effective management of lifting equipment and accessories. UUK Ltd recognised these shortfalls and the Chief Nuclear Officer made commitments to address ONRs findings.