Office for Nuclear Regulation

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Remote readiness inspection of BEPPS/DIF Phase 1 re-start of construction

Executive summary

Purpose of Intervention

In response to COVID-19 lockdown, Sellafield Ltd (SL) shut-down operations the week commencing 23 March 2020 and placed the site into a quiescent state with only key operational and maintenance activities being carried out.  SL Project Delivery Directorate (PDD) has developed guidance to support projects developing plans for re-starting construction activities on site which identify control measures required to minimise the spread of COVID-19.  Taking into account site priorities, Box Encapsulation Plant Product Store and Direct Import Facility (BEPPS-DIF) will be the first construction project to restart. 

To support the restart, the BEPPS-DIF project team have undertaken re-mobilisation activities to enable a limited scope of construction activities to re-commence from 11 May 2020.  It is planned that the scope of activities and number of people working on the construction site will be gradually increased.

This intervention is part of series of interventions being undertaken by the Office for Nuclear Regulation to gain confidence in SL’s re-start arrangements.  The intervention was undertaken remotely from site due to the restrictions in place during the current COVID-19 (Coronavirus) pandemic.

Interventions Carried Out by ONR

This readiness inspection was carried out against a range of health and safety legislation, and in particular government guidelines on social distancing on construction work, Construction (Design and Management) (CDM) Regulations 2015, management of Temporary Works and statutory examinations.

The intervention commenced with a question and answer teleconference at which supporting evidence was requested.  A desktop review of the evidence was undertaken and, where necessary, further clarification requested.  Judgements were made based on the adequacy of the assurances provided and supporting documentary evidence.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since this was not a safety system based inspection.

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

In relation to Government guidance on COVID-19, from the evidence provided we were satisfied that SL has adequately implemented the site COVID-19 risk assessment, developing a project specific risk assessment and comprehensive checklists.  SL has had positive engagement with the workforce, including the development of an induction pack and regular workforce briefings. We considered that SL had taken a cautious approach to re-starting work on site and embedding the guidance on COVID-19.    

Based on the evidence provided and discussions with SL, we were provided with adequate assurance that Principal Contactor duties were being adhered to. There appeared to be good engagement with the contractors, and update of contractor risk assessments was being adequately managed.  We considered that while the team had implemented adequate control measures on COVID-19 and communicated it through the site induction, the updated Construction Phase Plan (CPP) did not adequately reflect all the control measures in place.  SL agreed to consider referencing the site induction in the revised CPP. 

We considered the arrangements for management of Temporary Works and legionella.  Based on the evidence provided and discussions with SL, we were assured that adequate arrangements in place.  We identified that the legionella risk assessment was due to be reviewed.  SL confirmed that the independent contractor was due on site 3 June 2020 to complete this review and agreed to send ONR the completed report.

Conclusion of Intervention

Assurance was provided regarding how BEPPS-DIF construction site activities comply with SL’s restart arrangements, including social distancing on construction work, Construction (Design and Management) (CDM) Regulations 2015, management of Temporary Works and statutory examinations.  The assurance was sufficient to judge that there were no matters identified that would warrant formal follow-up.