Office for Nuclear Regulation

Planned compliance inspection - Management of asbestos and CDM arrangements

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 the SDFW Division 2019/20.  The purpose of this inspection was to evaluate the effectiveness of Magnox Ltd’s (ML) asbestos management arrangements on the site and to discuss their arrangements for compliance with the Construction (Design and Management) Regulations 2015 (CDM). 

Interventions Carried Out by ONR

The key regulatory activities undertaken during the two day inspection at Hunterston A (HNA) were based around:

Regulatory judgement was based on determining compliance with the Construction (Design and Management) Regulations 2015 (CDM) and the Control of Asbestos Regulations 2012 (CAR).

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 ACMs.  There is sufficient numbers of competent personnel to undertake asbestos management duties and the asbestos.  The quality of information on the asbestos register is good and Material risk assessments reviews are on-going. Advice was given to ML on register entries for asbestos dust, identified through the sampling of settled dust. The arrangements for asbestos management at HNA comply with the requirements of Regulation 4 of CAR (duty to manage).

Construction (Design and Management) Regulations 2015:

The arrangements for planning and managing construction projects are comprehensive but, on examination they appear quite complex, involving a number of procedures and associated documents.  As such, the inspection was limited to what ONR was able to verify through observations on site and specific evidence provided by ML.  In respect of the construction project underway at the time of the intervention, safety standards on site were good and there was good coordination between the principal contractor and the client.  ML as client was exercising oversight of the PC and this was evident is records of site inspections.

Discussions took place regarding the appointment of ML employees to the Principal Contractor (PC) role and their skills, knowledge and experience.  ONR will follow up with ML to discuss a job specification for the PC role and associated competences and formal training. 

Conclusion of Intervention

Feedback was provided at a close out meeting attended by senior managers and those involved in the intervention.  The arrangements for asbestos management are adequate and the site demonstrated effective management control of their asbestos.  Thus, the arrangements are adequate to achieve compliance with Regulation 4 of the Control of Asbestos Regulations.  The construction project on site was sampled and, in relation to this project, the CDM arrangements appeared adequate. 

Additional observations were made to ML in relation to risk based de-planting and the on-going management of asbestos during care and maintenance.  These observations were fed back to the central asbestos management team.     

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 intervention, these were accepted by ML.