Office for Nuclear Regulation

Dungeness A - Planned compliance inspection - management of asbestos and CDM arrangements

Executive summary

Purpose of Intervention

This inspection was planned in line with the Conventional Health and Safety (CHS) operational delivery plan for DFW Sub-division 2018/19.  The purpose of this inspection was to evaluate the effectiveness of ML’s asbestos management arrangements on the site and to discuss their processes for complying with their client duties under Construction (Design and Management) (CDM) regulations. 

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

 Interventions Carried Out by ONR

The key regulatory activities undertaken during the two day inspection 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 its Asbestos Containing Materials (ACM).  The provision of information was judged to be adequate, and there were sufficient numbers of competent personnel to undertake asbestos management duties.  The arrangements for asbestos management at Dungeness A comply with the requirements of Regulation 4 of Control of Asbestos Regulations 2012 (CAR).

Construction (Design and Management) Regulations 2015:  the main objective of this part of the inspection was to gather information on Magnox Ltd’s arrangements for complying with its client duties under CDM.  Magnox Ltd is the client for construction projects on its sites and has standard procedures in place, setting out the arrangements for compliance.  The procedures include other CDM appointments:  Principal Designer and Principal Contractor:  roles that Magnox Ltd may also undertake.  A number of construction projects on site were examined and the CDM arrangements in place appeared to be effective.  There was effective flow of information and good liaison between all parties.    

Conclusion of Intervention

Feedback was provided at a close out meeting attended by senior managers and those involved in the inspection.  The arrangements for asbestos management are adequate and the site demonstrated effective management control of their asbestos.  A number of construction projects, at various stages, were sampled on site and, in relation to these projects, the CDM arrangements appeared effective.  

Additional observations were made to Magnox Ltd, following the site walk-down, in relation to management of voids and work at height in the pile cap area.  Site agreed to address these issues immediately and to investigate the underlying causes. 

The overall impression left by the inspection was positive.  Where comments were made by ONR, in relation to some of the observations made during the inspection, these were accepted by Site and immediate action taken where required