Executive summary
Date(s) of inspection:
- March 2025
Aim of inspection
This planned inspection has two parts that may have overlapping areas depending on the work activities sampled whilst on site:
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The first part is aimed to sample construction work activities on site, and evaluate those against requirements of The Construction (Design and Management) Regulations 2015 (CDM). We are seeking to gain confidence that construction work is managed adequately in accordance with CDM requirements and relevant good practices.
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The second part is aimed to sample the local implementation of NRS's Culture, Risk Assessment and Work Flow improvement plan in response to ONR's Enforcement Letter in 3 March 2023. There is an outstanding Level 3 Regulatory Issue (RI-11260) tracking the progress of the plan. We are seeking to gain confidence that NRS has made the progress as reported. Outcomes of this inspection will form evidence to support the closure of the Regulatory Issue.
There is also an unrated part of this inspection which is aimed to obtain the latest progress on the Boiler's Down Project as part of the Project Inspector hand-over.
Subject(s) of inspection
- CDM 15 - Rating: AMBER
- MHSWR - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
A team of ONR Nuclear Site Health and Safety (NSHS) inspectors (here within referred as ‘I’) carried out the two-part planned inspection on compliance with CDM and Enforcement Letter follow-up on Risk Assessment.
The CDM compliance part sampled the Turbine Hall Infill project managed by an external company appointed as the Principal Contractor (PC). I considered the projects pre-construction information, construction arrangement & procedures, project staff’s knowledge of the work, and the suitability and sufficiency of their health & safety arrangements. I spoke with the PC and walked down the site to observe work activities. I had concerns about the effective management of pedestrian/vehicle interaction risks based on my observation, which resulted in an Amber rating for this part of the inspection and I have followed the ONR Enforcement Management Model to recommend appropriate enforcement actions.
The Enforcement Letter follow-up part of the inspection sampled four different types of work activities, carried out by various dutyholders including agency workers treated as NRS employees. For each work activity, I discussed with workers to evaluate their knowledge and awareness of the risks associated with the work being undertaken and control measures in place to protect their health and safety. I also reviewed relevant documentation, for example risk assessments and method statements, pre-job briefing etc. Although I only observed limited work activities being carried out due to issues with RCA access, I was content with the evidence seen and rated this part of the inspection as Green. In addition, NRS site personnel provided detailed updates on site specific actions to implement the corporate improvement plan on Culture, Risk Assessment and Work Flow. I was satisfied that there were sufficient evidence to support the closure of the actions outlined in the Enforcement Letter (tracked via RI-11260).
The unrated part for the project inspector hand-over and update on the Boilers Down Project is captured in a Contact Record (ONR-SDFW-CR-24-948).
Conclusion
For ‘Part 1 - Compliance with CDM’, based on the samples seen, I judged that IDC has applied inconsistent standards for managing risks to workers, with some key relevant statutory provisions not met, which means an Amber rating (Seek improvement) is appropriate. I have completed an Enforcement Decision Record (EDR) (ONR-EDR-25-02) and recommended serving IDC with an Enforcement Letter to seek targeted improvements. The actions required for IDC to comply with legal requirements will be tracked via an ONR Level 3 Regulatory Issue (RI-12502). All correspondence for this enforcement decision are saved in CM9 folder 4.7.19849.
For 'Part 2 - NRS EL follow-up and local implementation of NRS's Culture, Risk Assessment and Work Flow Improvement Plan', based on the sample seen, I judged that no significant shortfalls identified in the delivery of safety function, hence a Green rating (No further action) is appropriate. The inspection supports closure of the Level 3 Regulatory Issue (RI-11260), in addition to the written submission provided by NRS Corporate.