Office for Nuclear Regulation

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Ancillary asbestos licence inspection, planned compliance inspection: CDM, SGHWR project

Executive summary

Purpose of Intervention

This inspection was a planned compliance inspection in line with the Conventional Health and Safety (CHS) operational delivery plan for Decommissioning Fuel and Waste (DFW) sub-division 2019/20.  The purpose of this inspection was to carry out a licence asbestos inspection for ML’s ancillary licence and to evaluate CDM compliance for the SGHWR construction activities taking place on site.  There was also a meeting with members of the Dragon project team to gain an overview of the Dragon decommissioning project CDM arrangements. 

Interventions Carried Out by ONR

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

Control of Asbestos Regulations (inspection of licenced asbestos work):

Magnox Ltd has an ancillary licence for entry into asbestos enclosures for de-planting work at SGHWR Winfrith. The licence was granted for eighteen months and the licence holder has been identified as a priority visit by HSE’s Asbestos Licensing Unit (ALU) who issue licences for work with asbestos.

Overall the standards of control were good and there were some examples of best practice, for example appropriately positioned CCTV to facilitate supervision of the asbestos work inside the enclosure.  With regards to the plans of work, I advised ML to review their current overarching and job specific plans of work against ALG memo 04/12 and the CAR ACOP and guidance to Regulation 7.  I also advised that the plans of works should include diagrams and photographs where possible.  This advice was accepted by ML staff. 

Construction (Design and Management) Regulations 2015 (SGHWR):

ONR inspected the construction work taking place at the SGHWR site for which James Fisher Nuclear Ltd (JFN) is the Principal Contractor (PC).  Work underway at the time of the visit was the construction of the ICF.  The main structure is steel frame and a fabric ‘cladding’ and roof.  The system of work for roofing included rope access.  ONR questioned this as a risk control measure as, in terms of the work at height hierarchy, rope access was towards the lower end. JFN and ML confirmed that there had been discussions about the use of rope access, but it had been decided that this was the most appropriate method of work.  ONR requested that JFN review the sub-contractor risk assessment and method statement to satisfy themselves as to the safety of the proposed system of work and the competence of the operatives.

Discussions took place regarding the appointment of ML employees to the Principal Designer (PD) role and their skills, knowledge and experience.  Industry guidance suggests competences for PDs should include construction chartership (engineer), relevant site experience, understanding of what CDM sets out to achieve, an understanding of safe by design principles and NEBOSH construction certificate or equivalent.  The PD appointed to the SGHWR project is a chartered Structural Engineer and fulfils most of the other criteria, apart from a NEBOSH construction experience.  ONR will follow up with ML to ensure that there is a job specification for the PD role and associated competences.  In addition, ML should also consider whether PD’s should undertake a NEBOSH certificate in construction or an equivalent construction safety management qualification.

Conclusion of Intervention

With regards to the inspection of licenced asbestos work, the standards of control were good and there were some examples of best practice.  ONR advised ML to review their current overarching plan of work, and the specific plans of work, against ALG memo 04/12 and the CAR ACOP and guidance to Regulation 7.  ONR also advised that the plans of works should include diagrams and photographs where possible. This advice was accepted by ML staff.  

A discussion took place about design decisions in relation to the ICF building.  ML stated that there had been challenge around the use of rope access and the positioning of the building and that evidence for this could be provided if required.  ONR advised that any learning from the project should be captured and used to inform future projects.  ML confirmed that there is a mechanism in place for doing this.

Based on the information available, the PD role as undertaken by ML for SGHWR appears to have been discharged effectively.  ONR will follow up with ML to ensure that there is a job specification for the PD role and associated competences.  In addition, ML should also consider whether PD’s should undertake a NEBOSH certificate in construction or an equivalent construction safety management qualification.