Office for Nuclear Regulation

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Chapelcross - Planned compliance inspection - Management of asbestos and CDM arrangements

Executive summary

Purpose of Intervention

This inspection was one of a series of planned inspection in line with the Conventional Health and Safety (CHS) operational delivery plan for DFW Sub-Division in 2019/20.  The purpose of this inspection was threefold:

Interventions Carried Out by ONR

The key regulatory activities undertaken during the two day inspection at CHX were based around:

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

Asbestos Management:

The arrangements for asbestos management are comprehensive and the site demonstrated a good level of management control of their asbestos containing materials (ACMs).  There are sufficient numbers of competent personnel to undertake asbestos management duties and the asbestos seen out on plant was easy to locate from the information in the site asbestos register (SAR). The quality of information on the asbestos register is comprehensive.  Advice was given to ML on the intelligent customer role in respect of their licenced asbestos removal contractors (LARCs) and development of an ALARP position in terms of precautions required for removal of residues from the exterior of buildings.  The arrangements for asbestos management at CHX comply with the requirements of Regulation 4 of Control of Asbestos Regulations (CAR) (duty to manage).

Construction (Design and Management) Regulations 2015:

ONR examined the site’s arrangements for compliance with CDM in respect of the ISF project.  The construction phase plan is comprehensive and in accordance with HSE’s CDM Guidance L153 (appendix 3).  ML is the Principal Contractor for the project which was being managed by the construction manager for CHX.  The site is managed by a CHX Site Engineer.  Both role holders had received suitable training for their role and the project manager had suitable skills, knowledge and experience.  Although very little work was taking place on the construction site at the time of the intervention, safety standards appeared adequate. 

Workplace Transport Risks – Low Level Waste Yard:

At the CHS intervention in March 2018, ONR requested that ML implement all of the identified control measures from their workplace transport risk assessment.  These included improving the pedestrian/vehicle segregation in the yard, through the provision of suitable barriers, improvements to signage, marking of traffic routes and delineation of the trailer loading area.  These had not been implemented and the current arrangements are, therefore, not deemed adequate. This matter will remain open and ONR will follow this up with ML in due course.

Conclusion of Intervention

The overall impression left by the inspection was positive.  The arrangements for asbestos management are adequate and the site demonstrated effective management control of their asbestos.  The construction project on site was sampled and, in relation to this project, the CDM arrangements were adequate. 

ONR informed ML that the LLW yard requires attention and the control measures previously discussed should be implemented.  The Site management agreed to action this.  ONR will follow this up in a future visit.