This intervention is a planned compliance inspection in line with the Conventional Health and Safety (CHS) operational delivery plan for DFW Sub-Division in 2018/19. The purpose of this inspection was to evaluate the effectiveness of Urenco UK’s (UUK) arrangements for managing the risks to health from legionella bacteria.
Prior to the site based intervention, UUK provided ONR with a range of documentation associated with the company’s legionella management arrangements.
The key regulatory activities undertaken during the two-day inspection were based around:
UUK gave ONR a brief overview of how they managed CHS on site which was followed by a familiarisation tour of the site. ONR then examined the overall system that UUK employed to manage legionella risks and the outcome of the recent Independent Assurance (IA) review into legionella management on site, which had identified areas of non-compliance. Two cooling towers were physically inspected and other site locations were visited to view other cooling towers. ONR spoke to the Operations Department to establish what checks they were doing on the towers and what training they had to underpin these duties. The ONR Inspector judged that UUK have made significant progress in improving their management of legionella, following the IA review, but further progress is required. The UUK team responsible for legionella management are relatively new in post and are still developing their knowledge of how to manage the systems. Risk assessments carried out by external consultants had identified a number of high priority actions needed to ensure the safe operation of the systems as had an IA review carried out earlier in 2018.
Feedback was provided at close out meetings with UUK staff;ONR acknowledged the considerable work done by the legionella management team to act on the outcome of the risk assessments and IA review but further work is necessary to ensure compliance with COSHH and L8.
ONR sought confirmation of timescales for the outstanding actions on the hot and cold water systems: removal of cold water storage tanks, replacement of calorifiers, review of schematic drawings and identification and removal of dead-legs. ONR also requested that UUK ensure that they are undertaking all of the periodic checks on the system, as set out in the written scheme and that documents referred to in the written scheme are ‘live’. In addition, UUK should effectively manage their water treatment contractors to ensure they are working in accordance with their method statement.
The issues identified relating to the management of legionella on site are such that there are inconsistent standards for managing risks, with some key relevant statutory provisions not being met. Following this inspection ONR will write formally to UUK requiring the licensee to take the action to address the shortfalls identified during the inspection this matter will be followed up in routine regulatory engagement.