Executive summary
Date(s) of inspection: August 2024
Aim of inspection
B220 on the Harwell site is a large disused facility previously dedicated to radiochemistry and other works with a wide range of radioactive substance including Pu.
B220 characterisation is due to last for up to four years and it is at present the single large scale project ongoing on the Harwell site. It will be of sufficient size and complexity to require adequate control and management to be in place as required by the Construction (Design and Management) Regulations 2015 as well as other applicable health and safety regulations and nuclear site licence conditions.
The project aims to characterise radiologically all accessible areas of the facility which has undertaken a wide range of work with bate-gamma and alpha radioisotopes in order to subsequently enable remediation wherever required and safe demolition as a ‘clean building’. Asbestos is present in many areas of the facility and its removal will be required in difficult locations e.g., roof void and ventilation system. In addition, the work will entail a broad range of conventional hazard such as work at height, confined space and lifting together with the radiological hazard. The facility has been operational for over fifty years and during its long history a number of events have occurred. It is recognised that some of the records will be incomplete and therefore essential that the work is undertaken with appropriate controls particularly in areas where limited information and knowledge remain.
The B220 building is currently operational and the project will require to maintain the safety of the occupants, the security of the facility and manage the services across the building (e.g. ventilation).
The work will be carried out by the Principal Contractor, Westinghouse Environmental Services supported by several sub-contractors e.g., Health Physic, asbestos removal. The project is due to start its delivery phase having completed the commercial tendering and the Principal Contractor, Westinghouse Environmental Services, is due to mobilise on site imminently.
This intervention will aim to ensure that the project is initiated on sound foundation and will focus on the following:
- adequate appointment of the right people and organisation at the right time and the duties of key CDM 2015 roles (client, principal designer, principal contractor, designer and contractor) are adequately discharged.
- demonstration of good working relationship between all key roles.
- adequate management of risks by applying the general principles of prevention.
- adequate management and provision of key information and/or instruction.
- adequate management of key stakeholders.
- evidence of effective communication, collaboration and coordination.
- adequate management of a construction site and its associated construction work activities so that work is carried out, so far as is reasonably practicable, without risk to health, safety and welfare of the persons working or affected by the construction project and construction work activities.
Subject(s) of inspection
- CDM 15 - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The ONR purpose for this inspection was to overview the B220 characterisation project and to judge compliance with CDM 2015.
NRS Project Team and their subcontractor, Westinghouse, presented their CDM management arrangements for the B220 Characterisation project.
This was complemented with a plant walkdown of B220 facility highlighting the different phases of the work and their associated hazards.
The familiarisation with the B220 facility enabled ONR to understand the project timeline, the work and associated hazards present within the facility and to see evidence of CDM control associated with those.
At present the project is undertaking low risk activities with more intrusive radiological characterisation and asbestos survey to be carried out as the project progresses.
ONR held meetings separately with NRS and Westinghouse to gauge their understanding of their role and duties under the CDM regulation and how this will be articulated in compliance with the requirements of the regulation throughout the project lifecycle.
ONR provided feedback and a number of findings which will need to be addressed by the site prior to the project progressing further.
ONR rated the inspection Green because we were satisfied that the work undertaken at present is low risk and de facto adequately controlled. ONR requested in writing form the site that the corrective actions be addressed to bring the site in full compliance with the requirements of CDM 2015 regulations. Satisfactory closure of the actions will be monitored via a Level 4 Regulatory Issue.
Conclusion
ONR’s provisionally rated the inspection Green. This is because we were generally satisfied that currently, the risks are adequately controlled. However, there are some actions that should be completed to address the shortcomings in CDM compliance that will be tracked through a Level 4 Regulatory Issue, following a letter sent to the site director highlighting these shortcomings.