This inspection was carried out at the Bradwell nuclear licensed site as part of a wider ONR assessment of Magnox Ltd’s preparations to transition the Bradwell site into long term care and maintenance (C&M). It follows on from an Inspection undertaken in October 2017.
ONR undertakes regulatory interactions with Magnox Ltd in line with a strategy defined by the Decommissioning Fuel and Waste (DFW) 2017-2020 which contains a number of strategic objectives and milestones relating to key pieces of regulatory work. One of the milestones within the DFW strategy relates to the permissioning of the Bradwell site into long-term C&M.
The key regulatory activities undertaken during the inspection were based around meetings and plant walkdowns to:
Key performance indicators used to assess the adequacy of organisational and physical control measures were based on the requirements of Section 2 and 3 of the Health and Safety at Work etc Act 1974 and relevant statutory provisions made under the Act including the Control of Asbestos Regulations 2012: Approved code of practice and guidance (L143).
Sizewell’s readiness to remotely manage asbestos at Bradwell:
A number of asbestos containing materials (ACMs) will remain in-situ at Bradwell during the C&M quiescent stage. Adequate arrangements have been made for the management of this asbestos from Sizewell. Sizewell’s nominated Lead Asbestos Competent Person (LACP) will take over the day to day management of asbestos and the current Bradwell LACP will stay in post beyond C&M to assist with the transition. Additional asbestos competent personnel are in the process of being authorised. It was evident from discussions and site walkdowns, that Sizewell’s LACP has knowledge of the Bradwell site, the location and nature of the ACMs, and demonstrated knowledge of the process for providing information to employees and contractors about the location of ACMs.
Asbestos management – setting to work:
ML have revised their setting to work processes to apply to safestore entry. The process uses the current ML procedures with new C&M specific documents to address mobilisation and guide project managers. The C&M safe store entry process is also described in the asbestos management plan (AMP) and the arrangements set out in the AMP are, in my opinion adequate to enable compliance with Regulation 4 of the Control of Asbestos Regulations.
It is noted that some of the documents, such as the AMP, are still in development, pending commissioning tests, audits and review. ONR accepts that work on the documents and related processes will continue beyond C&M as the systems are put into practice.
Asbestos management – site asbestos register:
The site asbestos register for C&M entry currently list 411 items, a reduction from the 500+ noted in October 2017. A considerable amount of work has been done to consolidate and remove ACMs and improve the quality of information in the site asbestos register for items that will remain in-situ during C&M. This work is still on-going and ML expects it to be completed in 7-8 weeks.
Asbestos management – periodic inspection of ACMs and air monitoring:
ML’s intention is to inspect the ACMs on a twelve monthly basis. Less frequent inspection intervals may be specified if the underpinning data supports this. There is recognition from ML that they will need to build up this knowledge. This approach is in accordance with the Control of Asbestos Regulations 2012, approved code of practice. Air sampling will be carried out at initial safe store re-entry and, once conditions have been verified, further sampling will take place in areas where access is needed.
Asbestos management – SQEP requirements:
The AMP does not set out the SQEP criteria for asbestos competent personnel, although ML’s asbestos action plan states that this is to be included in the AMP. ML should capture the SQEP criteria in relevant site documentation. Additional SQEP criteria for the C&M inspection team, such as tower scaffold or MEWP training should also be documented.
ONR acknowledges the considerable amount of work done by ML to address the issues arising from the October intervention and is pleased with the progress made. The following actions were agreed: