Office for Nuclear Regulation

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Planned Compliance inspection

Executive summary

Purpose of Intervention

This inspection was one of a series of planned compliance inspections in line with the Conventional Health and Safety (CHS) operational delivery plan for the DFW Sub-Division sites in 2018/19.  The purpose of this inspection was to evaluate the effectiveness of Magnox Ltd’s (ML) asbestos management arrangements on the site and to discuss the processes for complying with their duties under CDM 15 in relation to the SGHWR project. 

The Intervention also presented the opportunity for site familiarisation for conventional health and safety inspectors new to ONR.

Interventions Carried Out by ONR

Prior to the site inspection, ML provided ONR with documents that set out its arrangements for complying with their duties under the Construction (Design and Management) Regulations 2015 (CDM) and Control of Asbestos Regulations 2012 (CAR).  The key regulatory activities undertaken during the two day inspection were based around:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

CDM:

ML is the client and principal designer for the SGHWR project and has appointed a principal contractor under a design and build contract.  ML gave an overview of the arrangements for managing the project, under the client duty, and arrangements in place for planning, managing and monitoring the pre-construction phase as required by the CDM Principal Designer duties. These arrangements appear to be working effectively for this project. The principal designer confirmed that they had received training for this and the client role.

Discussions were held regarding the arrangements for managing the risks from traffic movements around the SGHWR site during the construction phase and subsequent operation of the facility.  The nominated site inspector asked if consideration was being given by the project to use the Dorset Innovation Park gate to reduce congestion around the site and potentially reduce risks to the public offsite during the movement of the concrete boxes to the Harwell site.  The project confirmed this was not currently being considered but would be followed up with the Winfrith Site Integration Manager.

Vehicle/pedestrian segregation during the construction phase was also discussed. The current proposed layout could potentially lead to a significant number of pedestrian and vehicle movements in one location.  ML agreed to discuss with the PC how they proposed to control the risks in this area.

During the site walkdown, contractors were observed undertaking enabling works.  ONR questioned whether ML had applied CDM to this this project.  ML was unable to confirm whether this was the case but agreed to look into this matter.

Asbestos Management:

ML Winfrith has established procedures in place to manage asbestos.  A recent re-issue of the site asbestos management plan reflects some of the corporate improvements to the management of asbestos across the fleet.  The site asbestos inventory will be subject to a gap analysis due to begin in August and is part of ML’s corporate asbestos management improvement plan.  The site SAR will be migrated over to E-Locate, in line with other ML sites.

Deplanting work under the ancillary licence was not seen, but inspection of systems in place and equipment provided to enable this work was to a good standard.

Asbestos seen during the site walkdown was clearly labelled in in good condition.

Conclusion of Intervention

ONR provided feedback to the licensee staff recognising that, in relation to the SGHWR project, ML Winfrith has established arrangements in place and competent staff in post to fulfil the roles.  ONR questioned whether the CDM arrangements had been applied to the enabling works arranged by their facilities management contractors, ML agreed to follow this up.

The arrangements for asbestos management appeared comprehensive and there was a recognition that the site was in the process of moving over their asbestos information to the ML corporate database and that a gap analysis of their asbestos inventory was due to take place in August.  An inspection of the documentation relating to the ancillary licensed work taking place and the equipment demonstrated a good standard of control.