This inspection was one of a planned series of compliance inspections in line with the Conventional Health and Safety (CHS) operational delivery plan for DFW Sub-Division 2018. The purpose of this inspection was to evaluate the effectiveness of ML’s asbestos management arrangements on the site.
Prior to the site based intervention, Magnox Ltd (ML) provided ONR with documents that set out their arrangements for complying with their duties under the Control of Asbestos Regulations 2012 (CAR). The key regulatory activities undertaken during the one day inspection were based around:
Discussion of site management arrangements for managing asbestos containing materials, including provision of information to persons liable to disturb fabric of building;
Harwell has established arrangements in place for the management of asbestos containing materials on site. The local arrangements for Harwell (and Winfrith) have historically differed from the rest of the ML reactor fleet but they are currently in the process of being aligned with S-267, ML standard procedure for asbestos management. The site asbestos management plan has recently been re-issued and now aligns with the S-267 template and the site asbestos advisor role is to become Lead Asbestos Competent Person with two further Asbestos Competent Persons roles to be created. The recent gap analysis has highlighted the need to validate data on the current site asbestos register (SAR), prior to migration over to E-locate (Magnox group SAR). ML has recently devised a site asbestos improvement plan. A number of the improvements are complete and the remainder have a completion date of end of March 2019. The improvements relate to the site asbestos register and abatement works.
Abatements works are underway by a licenced asbestos removal contractor (LARC) which, once complete, will reduce the asbestos risk on site. ML has appointed a project manager to oversee the work of the LARC.
The arrangements for provision of information to persons who may disturb asbestos are set out in the site asbestos management plan. Harwell does not have a central construction office through which all work is managed, so it is the responsibility of the task supervisor or permissioner of the work to consult the SAR and the SAA for guidance. ML confirmed that they had reviewed this approach (as it differs from ML sites that have moved over to the decommissioning model) and concluded that it is effective.
Feedback was provided at a closeout meeting on site with those involved in the intervention. It was recognised that Harwell has established arrangements in place for the management of ACMs across the site and were making good progress in migrating site arrangements over to S-267 and improving the quality of information on the SAR. Harwell has developed a site asbestos improvement plan which has measurable targets for achieving improvements identified by the site review and gap analysis and the overall date for completing the work is end of March 2019 which ONR considers a reasonable timescale.