Executive summary
Date(s) of inspection: June 2024
Aim of inspection
The purpose of the inspection is to determine whether Nuclear Restoration Services (NRS) are suitably controlling and supervising decommissioning activities on the site to reduce risk.
Subject(s) of inspection
- CDM 15 - Rating: Green
- MHSWR - Rating: Green
- Workplace Transport - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
I led a planned compliance inspection on the Construction (Design and Management) (CDM) Regulations 2015 and the Management of Health and Safety at Work Regulations (MHSWR) 1999 targeting Workplace Transport. The inspection team comprised the nominated site inspector and two nuclear site health and safety inspectors.
For CDM, the licensee as CDM Client, provided adequate evidence to demonstrate the appointment of the roles under the Construction (Design and Management) Regulations 2015. However there were shortfalls in the licensee’ delivery of its role as CDM Principal Designer. There was evidence that the Design Risk Assessment process had not achieved hazard elimination and risk reduction in design in the areas of working at height and control of substances hazardous to health. The CDM Principal Contractor for the Hunterston A Reactor Building Roof Repairs demonstrated adequate arrangements for risk assessment. Its arrangements for on-site management and supervisory arrangements were not fully effective to ensure that the control measures identified in risk assessment and method statements were implemented. It is the nuclear site health and safety inspector’s opinion that a Green rating is appropriate for this inspection, with matters to be taken forward separately with the site, NRS Corporate, and the Principal Contractor in future projects.
For MHSWR 1999 I targeted the Workplace Transport arrangements. The licensee provided suitable evidence to demonstrate that NRS are managing and controlling workplace transport appropriately. They were able to demonstrate implementation of several workplace transport improvements and had identified future improvements. It is the nuclear site health and safety inspector's opinion that NRS were able to demonstrate adequate compliance with relevant good practice of MHSWR 1999 with a few minor improvements and I award a rating of Green.
During this inspection I also held an engagement with the safety representatives. The representatives identified that the contamination control facilities in the Ponds building did not meet recommended good practice. I subsequently raised a Level 4 regulatory issue regarding the provision of adequate contamination control facilities in the Ponds building.
Conclusion
I consider that the licensee is adequately implementing the requirements of the Construction (Design and Management) Regulations 2015, based upon my sampling and the evidence presented by the licensee. I therefore judge that, an ONR inspection rating of adequate (GREEN) is appropriate for this intervention. There are matters, for example application of principles of prevention in relation to risk management, and hazard identification and assessment at the project planning stage, that will be taken forward for further review with NRS by engagement at corporate level.
Based on the evidence that I sampled, I judged that site has demonstrated adequate compliance with relevant good practice of the Management of Health and Safety Regulations targeted at the Workplace Transport with a few minor improvements required. However, they have already been identified by the workplace transport assessment and included in the action plan. As the result, I rated this part of the inspection Green.