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Conventional Health and Safety (CHS) compliance inspection, management of asbestos and construction health and safety

  • Site: Hinkley Point B
  • IR number: 21-163
  • Date: March 2022
  • LC numbers: N/A

Executive summary

Purpose of Intervention

This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Hinkley Point B (HPB) 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 HPB Integrated Intervention Strategy (IIS) for 2021/22.

The inspection was conducted to provide regulatory confidence in HPB’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 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 the NIHSS inspector for Operating Reactors, the HPB site inspector and a NIHSS nuclear associate 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, via sampling of arrangements, 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’s response to the fleet wide 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 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 HPB.

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:

  • HPB has a formally appointed, suitably qualified, station asbestos coordinator (AC).
  • The station is recording building numbers, as well as building names, for the asbestos register entries to ensure locations are tracked over time as building names change.  
  • The station is using a detailed CDM 2015 pre-construction review document for construction projects. 

HPB staff spoken to during the intervention presented a knowledgeable and professional approach to the key topic areas covered.

Based on the samples inspected, the ONR inspectors judged that HPB 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 resilience around the AC role and the asbestos improvement plan. A level 4 regulatory issue will be raised to monitor progress.

Based on the samples inspected, the ONR inspectors judged that HPB 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 aspects of CDM 2015 training and construction health and safety resource.

ONR inspectors were satisfied with the station’s progress with fixed plant machinery guarding improvements.  

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

ONR discussed findings with HPB as the inspection progressed, at the closing meeting of the inspection and during two follow up meetings. These were acknowledged and accepted by HPB.

Conclusion of Intervention

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