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Conventional Health and Safety (CHS) compliance inspection

  • Site: Hunterston B
  • IR number: 21-149
  • Date: February 2022
  • LC numbers: N/A

Executive summary

Purpose of Intervention

This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Hunterston B (HNB) power station, undertaken as part of the intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR). The work was carried out in accordance with the planned inspection programme contained in the HNB Integrated Intervention Strategy (IIS) for 2021/22.

The inspection was conducted to provide regulatory confidence in HNB’s arrangements against two high risk industrial safety areas, the management of asbestos containing materials (ACMs) and the health and safety management of construction work. These are both relevant to the station’s recent transition into end of generation (EOG). The inspection also sought an update from the station on progress with their fixed plant machinery guarding improvement work.

Interventions Carried Out by ONR

The inspection was conducted on site by a team of ONR industrial safety inspectors over two days. An inspection brief was prepared and shared with the station prior to the inspection. The key regulatory activities undertaken during the inspection focussed on determining station compliance in the following areas:

  • arrangements for the management of ACM as required by regulation 4 of the Control of Asbestos Regulations 2012, including ACM identification and assessment, monitoring and management and provision of information.  
  • arrangements for the health and safety management of construction work including key duties and roles as required by the Construction (Design and Management) regulations 2015 (CDM 2015).
  • Progress with the station fixed plant machinery guarding improvement work. 

The inspection involved discussions with NGL staff, contractors working on site and Trade Union Safety Representatives. The inspector team conducted site walk-downs accompanied by relevant station personnel and sampled associated records, followed by further remote correspondence reviewing additional documents provided by the station after the site visit.

The station also provided an overview of its asset management work.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

ONR inspectors adhered with control measures outlined within ONR-GEN-GD-022 (Visit to licensee and other duty-holder premises and other relevant locations during the COVID-19 pandemic) and the local COVID-secure control measures at HNB.

Regulatory advice and judgement were based on determining compliance with Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and the relevant statutory provisions made under the Act, including:

  • Control of Asbestos Regulations 2012 (CAR)
  • Construction (Design and Management) Regulations 2015 (CDM 2015)
  • Provision and Use of Work Equipment Regulations 1998 (PUWER)

The inspectors also consulted the following relevant good practice, including:

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

During the inspection ONR inspectors identified areas of good practice including:

  • HNB has a formally appointed, suitably qualified, station asbestos coordinator.
  • HNB is reviewing where EOG may impact on ACM locations and is planning appropriately.    
  • HNB has an industrial safety advisor embedded within the construction project delivery team.
  • HNB staff spoken to during the intervention, presented a knowledgeable and professional approach, and provided open and honest responses to questions.

Based on the samples inspected, the ONR inspectors judged that HNB demonstrated adequate ACM management arrangements against relevant good practice. As a result, an intervention rating of Green (no formal action) was allocated. Verbal advice was given in some areas including in relation to refresher training.

Based on the samples inspected, the ONR inspectors judged that HNB demonstrated adequate health and safety management arrangements for construction work. As a result, an intervention rating of Green (no formal action) was allocated. Verbal advice was given in some areas including in relation to training.

ONR inspectors were satisfied with the station’s progress with fixed plant machinery guarding improvements and were content to close the existing regulatory issue.  

We were content that HNB were adequately implementing measures to reduce the risks associated with COVID-19 transmission. 

We discussed findings with HNB as the inspection progressed and at the closing meeting of the inspection. These were acknowledged and accepted by HNB.

Conclusion of Intervention

Based on the samples observed and examined, ONR inspectors were satisfied that HNB demonstrated adequate arrangements for the management of asbestos containing materials (ACMs) and the health and safety management of construction work against relevant good practice. An inspection rating of Green was allocated to each of those topics.