Office for Nuclear Regulation INTERVENTION RECORD [Unique Document ID and Revision No: JONR-COP-IR-15-66 TRIM Ref: |2016/18650 Interventio Date(s) of intervention: |5/01/16 & 6/01/16. PRINCIPAL STAFF SEEN Peon |(Magnox) Wyifa site staff [Location and purpose of _|Wyifa (Magnox site) - Inspection of arrangements for managing lasbestos containing materials (ACM's) Inspector(s) taking part in Intervention: =" ‘The roles of principal staff seen, including those from licensees or other government departments (for ‘example, the Environment Agency) seen during the visit Page sereIExova contract staff (based on site) IMagnox Corporate |Asbestos programme Team, (A) _ SYSTEM/ STRUCTURES BASED INSPECTION RATINGS [Condition not applicable, enter “n/a IComplete this section only where a System / Structures Based Inspection takes place. If LicenceRecord System / Structures Based fer ee ee eae Plan Name Condition (uc) Rating P/RUP: w [Overall judgement thatthe System / Structure adequately fulfis the requirements of | YES | NO the safety case, Please delete “Yes” or "No" in the box provided as applicable "B= planned, RU Teacive unplanned [(®) INTERVENTION RATINGS [Complete this section only where applicable, e.9. for a compliance inspection or assessment where the Jduty holder's arrangements are being rated. If not applicable, enter ‘n/a’. Complete Par A in respect of |System / Structures Based Inspection er Section Croc “P= planned, RUP = reacive unplanned [(C) INTERVENTION RATINGS - (FOR USE ONLY BY CNS & CROSS ONR PROGRAMMES) |Complete this section only whore applicable for a Securly/TransporySafeguards/Conventional Sefety/Fire Inspecton. if not applicable, enter °r/a". Complete Part A in respect of System / Structures Based Inspection, if applicable Rating P/ fie fr er RaginInspection of site arrangements for managing ACM's. (Conventional Safety "P= planned, RUP = reacive unplanned ‘TABLE OF CONTENTS, 1. EXECUTIVE SUMMARY 5 2. RECORD 8 3. ISSUES 12 cee Mile Res on onr-coPsm-se8 20188660 Page 6016EXECUTIVE SUMMARY 1.4. Purpose of Intervention ‘The Intervention was carried out at the Wylfa Nuclear Licensed site and was undertaken to review the arrangements in piace to manage site asbestos containing materials (ACMs) as required by the Control of Asbestos Regulations 2012, Regulation 4. There are approximately 4000 deaths from asbestos related diseases in the UK each year. Of these people dying, 25% are tradesman such as builders, plumbers, carpenters and electricians. This equates to 20 tradesmen each week. Hence managing and working with ACMSs is a priority nuclear site conventional health topic. 1.2 Interventions Carried Out by ONR ‘The Control of Asbestos Regulations 2012: Approved Code of Practice and Guidance (CAR ACOP 2012), sets out the requirements for work with asbestos. Regulation 4 sets out the duty to manage asbestos in non -domestic premises and requires duty holders to identify the location and condition of asbestos and to manage the risk to prevent harm to anyone who works on buildings or to building occupants. The Management of Health and Safety at Work Regulations 1999 (MHSWR 1999) sets out the general frame work for health and safety arrangements, risk assessment and management and requires the Wyifa site to have health and safety arrangements that are appropriate for the nature of the activities and the size of the undertaking. | visited the Wylfa licensed site for the two days of the 5” and 6” January 2016. | was ame On, 5” January wo ha an inroductny meatng dung which te and LACP provided an overview of the key personnel involved with asbestos management on the site and ofthe asbestos management arrangements. There was also an explanation ofthe new phase of site operations with the ending of power generation on the 30” December 2015. “The asbestos programme manager gave background on a new company wide asbestos management dalabase and of the loager term company aims in relalon 0 asbestos management, We carried out vsis to a number of specific areas within the licensed site 10 review the effectiveness of the asbestos management procedures and arrangements against the requirements of CAR ACOP 2012 and MHSWR 1999. Discussion took place witha range of relevant sia in relation to the workings of the asbestos management procedures and arrangements for dealing with ACM. On the 6” January 2016, | held a meeting with a number of the site safety representatives to ‘explore their experiences of the site asbestos management arrangements. | then visited other areas within the licensed site to observe the asbestos management arrangements taking the ‘opportunity to speak with staff where possible. The asbestos analyst provided an overview of the current asbestos database which holds site asbestos survey records. Finally, | took part in of 1 Fog ion1 feedback meeting attended by key staff who had taken part in the intervention along with a ‘number of the safety representatives. During this meeting | gave an overview of my findings. 1.3 Explanation of Judgement if Safety System Not Judged to be Adequate NA 1.4 Key Findings, Inspector's Opinions and Reasons for Judgements Made Wylfa have recently revised their approach to managing asbestos within a draft asbestos management plan document reference WAY-AMP-MCP/014/009 (Form F-866620). This document is the site implementation of a new company asbestos management standard which ‘was launched in September 2015 — Document S-267. The document sets out the procedures and associated roles and responsibilities to be followed when working with ACMs and has been updated to better reflect the requirements of the Control of Asbestos Regulations 2012 Prior to the production of a site based S-267 document Wylfa set out its management contro! procedures for asbestos management within document NO. 014 Part 009 Safe handling of asbestos products. The site is therefore currentiy in a transition phase between these two documents. The site, maintains and updates a ACMs register database (ACE PSI) which is held electronically and which is divided into relevant buildings and specific locations. Asbestos surveys are carried out by site based analyst staff who also carry out on site analysis of suspect asbestos materials via their UKAS accredited site laboratory. Staff spoken to during the intervention all had a good knowledge of who on site could provide specific advice and ‘guidance in the event of a concern over an actual or suspected ACM. ‘A new company database (E-Locate) is in the process of group roll out but was not currently ‘operational at Wyifa. Action was found to be required by Wylfa in number of areas in order to improve their management and work with ACMs. These requirements are set out below: Priority: Turbine Hall Unit 1 (Deaerator floor: T1/SA/224 to T1/SA/109 location) ~ the site needed to deal appropriately with three small areas of asbestos pipe lagging where encapsulation was seen‘to have degraded. These were located on a redundant steam pipe. It was agreed that the LACP would make urgent arrangements to deal with this ‘matter. Priority: Reactor 2 (External Pipe Bridge area) ~ significant cracking was visible in two areas of redundant steam pipe cladding while water ingress had damaged a separate section of metal cladding exposing lagging material. These areas required further investigationwork to check for the potential presence of ACM and agree any remedial work. This was agreed with the LACP. Priority: The site asbestos management plan requires the re-inspection of all ACM's on a ‘minimum 12 monthly basis. The site is currently significantly behind in this requirement and a second analyst has been employed on a temporary basis to help achieve this, aim, This matter requires continued senior site management oversight, Priority: The site asbestos register database contains the details of ACM locations along with, ‘material and priority risk information. This database risk information should be reviewed urgently and a site asbestos action plan produced. This plan should provide a suitable level of clarity that there are appropriate management arrangements in place for the sites high and medium risk ACM locations. The immediate focus of the database review should be on those areas currently identified in the database as high risk. Priority: the asbestos register should be checked prior to work starting on the fabric of the bullding. Efforts should be made to improve the use of the register by key staff such as site engineers and SPT's. There should not be an over reliance on the ACP function to provide ACM information and additional training may bé prudent for SPT and other staff who are required to access the register and co-ordinate work. Other matters: Provision of information to workers prior fo work commencing: ACM information contained within the asbestos register should be enhanced via the use of ACM photographs and drawings. Drawings should include the main features of the rooms along with the locations of the ACM's. Inspection frequency of ACM locations: Some of the ACM materials observed during the visit had been inspected within the previous 12 months but had subsequently deteriorated to a point where remedial work was necessary. Locations that are exposed to potentially accelerated deterioration will need to be inspected more frequently than every 12 months. Corporate oversight and learning: A corporate asbestos intervention with Magnox is being planned with an expected start date in April 2016. The intervention will explore a ‘number of the leaming issues discovered during the Wylfa vist. Conclusion of Intervention ‘There was a positive recognition by both the site and corporate asbestos management team that the matters raised during the intervention merited their attention and action. The site was keen to complete the required improvements and also intended to reflect on and understand their current position. fie ar Naar Region (one.CoP-R. 18.6 201818 Page 16‘The EMM was considered and a letter to Wylfa was identified as the appropriate mechanism to progress these matters. A follow up visit will be made in Q3-4 of 2016 to determine if the required action has been taken, The site were required to provide written confirmation that the priority issue identified in the ‘Turbine Hall had been actioned as a matter of urgency. 2. RECORD ‘Arrangements for managing ACMs were inspected at the following locations: Turbine hall, Pile Cap Area, Reactor 2 building. In addition the corporate procedures for managing ACMs were examined both before and during the site visits There was a small amount of time assigned to a review of the site investigation into a non- injury electric shock incident - event reference number WYL/001149. 2.1 Inspection performance indicators ‘The inspection performance indicators were set against the requirements of the CAR ACOP. 2012, and the relevant parts of the Management of Health and Safety at Work Regulations 1999 (MHSWR 1999), Key performance indicators used to assess the adequacy of organisational and physical control measures were broadly based on paragraphs 81-147 of the CAR ACOP 2012 and the basic principles of plan, do, check and act as described in HSE publication HSG 65. However, other requirements of CAR ACOP 2012 were used where relevant. There are some specific. requirements in the aforementioned legislation/ACOP that are key to the successful management of work with ACMs. For example, paragraph 129 of the CAR ACOP 2012 stales @ written (electronic or paper) management plan should set out how the risks identified from asbestos will be managed. Details should include: Identifying the person(s) responsible for managing the asbestos risk; + A.copy ofthe asbestos record or register and how to access it ifis kept electronically; + Instructions that any work on the fabric of the building cannot start without the relevant parts ofthe recordiregister being checked. The plan should include details of how this will be achieved. In particular, the plan should identity the procedures and arrangements to make sure: - the recordiregister is checked in good time before the work starts; - ctiecks wil be made that the information on the presence of asbestos has been understood and will be taken into account; - checks will be made that the fs or Micr esa ioncorrect controls will be used and that competent asbestos-trained contractors will carry ‘out the work; ‘+ Plans for any necessary work identified from the risk assessment, eg repair, protect or remove ACMs; The schedule for monitoring the condition of any ACMs; How to communicate the content of the management pian; Contingency arrangements if the main person for asbestos risk management is not available. Paragraph 130 of CAR ACOP 2012 states the dutyholder should ensure that the plan is implemented to manage the risks. The plan should: + Priontise the actions identified; * Give high prionty to damaged material and materials likely to be disturbed; these will need 10 be repaired, sealed, enclosed protectively or removed using trained and ‘competent personnel. Paragraph 132 of CAR ACOP 2012 states that the plan should include procedures and responsibilties to ensure that the asbestos register is shared with any worker/contractor carrying out maintenance or other work Paragraph 134 of CAR ACOP 2012 states that work should only start once the dutyholder is satisfied that the information on the asbestos record/register is known and understood by the workers who are doing the work on site and easily accessible for anyone who needs to inspect it Paragraph 143 of CAR ACOP 2012 states that as a minimum, the management plan, including records and drawings, should be reviewed every 12 months. it should also be reviewed if thero is a reason to believe that circumstances have changed (eg there is a ‘change of use of building, work being undertaken, ACM's removed or repaired etc) the plan including records and drawing should then be updated accordingly. 23 Inspection findings — (Summary) 2.3.1 Turbine Hall Unit 1 (Deaerator floor: T1/SA/224 to T1/SA/109 location) - the site needed to deal appropriately with three small areas of asbestos pipe lagging where encapsulation wasseen to have degraded. These were located on a redundant steam pipe. It was agreed that the LACP would make urgent arrangements to deal with this matter. This area had been inspected by the asbestos analyst in March 2015 and had been identified as a low damage ‘area with a medium risk priority. The pipe lagging had most likely been affected by 2 valve leak after the last inspection and was a good indicator of the need to review the frequency of some ACM inspections. 2.3.2 Reactor 2 (External Pipe Bridge area) ~ significant cracking was visible in two areas of redundant steam pipe cladding while water ingress had damaged a separate section of metal cladding exposing lagging material. These areas required further investigation work to check for the potential presence of ACM and agree any remedial work. This was agreed with the LACP. It was not possible during the visit to determine when these particular areas had last been inspected, 2.3.3 The site asbestos management plan requires the re-inspection of all ACM's on a ‘minimum 12 monthly basis. The site is currently significantly behind in this requirement and a second analyst has been employed on a temporary basis to help achiove this aim. The site has in the region of 1800 ACM locations on the database with in the region of 500 currently outside the 12 month re-inspection date. This matter requires continued senior site management oversight. Some ACM areas will potentially require inspection at more frequent intervals than 12 months given condition and location (CAR ACOP paragraph 144). Consideration needs to be given to the fact that Wyifa has just ceased power generation and changes in local environmental conditions may affect the ACM's. 2.3.4 The site asbestos register database contains the details of ACM locations along with ‘material and priority risk information scores. The database was explored with the assistance of the asbestos analyst and 151 high risk ACM locations were identified over the last 3 year period. The site was not able to satisfactorily demonstrate that these ACM locations were being suitably managed. It was agreed that the database information should be reviewed urgently and a site asbestos action plan produced in relation to any remedial action required. ‘The immediate focus of the database review would be on those areas currently identified as. high risk but with a subsequent review of those identified as medium risk. The pian should provide suitable clarity that there are appropriate management arrangements in place for the sites high and medium risk ACM locations. 2.3.5 Information about the location and condition of any ACM should be provided to every Person liable to disturb it and the asbestos register should be shared with any worker/contractor carrying out maintenance or other work. Currently the system of information provision is very dependent on the ACP function and efforts should be made to improve the Use of the asbestos register by key staff such as site engineers and SPT's. There should not be an over reliance on the ACP function to provide ACM information and additional training may be prudent for SPT and other staff who are requited to access the asbestos register and co-ordinate work, 2.3.6 ACM information contained within the asbestos register should be enhanced via the use of photographs and drawings. Drawings should include the main features of the rooms along ‘oN. cOPAR-68 201616850 Page 100116with the locations of the ACM's. Photographs are currently in place for approximately 70% of ‘ACM locations and Wyifa are now taking photographs during all reinspections. 2.5 Inspection findings - general 2.3.7 Wylfa ended power generation on the 30” December 2016 and has entered into a 100 day period of statutory outage. This is primarily aimed at getting the station ready for a3 year period of defueling. 2.3.8 Station staffing levels are likely to reduce by approximately 50% (Including contractors) uring 2016. A best fit review is currently taking place to determine the detall of reductions. 2.3.9 The Magnox asbestos programme team intend to carry outa full condition survey of the ‘ACM situation at Wyifa. This is due to start in February 2016 and will inform the longer term Magnox approach to ACM management which will eventually fall under a joint programmefsite management arrangement. Currently no project work is planned for the 3 year period of efueling and ACM management will remain under the site remit for that period 2.4.0 Hertel (licensed asbestos contractors) has staff based permanently on site and also provides scaffold services. Their site team is due to reduce significantiy from the 1" April 2016 a part of the staffing level review due to the reduction of planned project work. This reduction will be from 63 staff to 9. This reduction is intended to reflect the reduced need for scaffolding during the 3 year period of no planed project work. It remains to be seen as to whether the 9 staff will be sufficient to deal with any necessary ACM management work although there will be the opportunity for the site to request additional asbestos related work funding. 2.4.1 Exova has an asbestos analyst permanently based on site carrying out proactive site ‘ACM inspections and reactive ACM work. Funding has been secured for this resource for the next 3 years. Routine reassurance air monitoring is carried out in a number of site locations at regular intervals. The services of an additional analyst have been secured until April 2016 to cach up on the outstanding ACM inspections. 2.4.2. A programme of weekly inspections of electrical cubicle installations is carried out which involves. potential contact with ACM material. Well established asbestos management procedures accompany this work. 2.4.3 The site operates an orange (amber) tag system for those scaffolds that require ACM checks from the analyst, 2.4.4 The LACP deals with the management of project work for Hertel and reviews and signs the work control cards (WCC) produced by the SPT's. ACM information on the WCC is checked by the LACP and hold points are established when required ofc (onr-coPaR-15 8 -20188850 Page 10162.4.5 On the 8" January we visited a number of locations within the Turbine Hall including the Deaerator floor. Observations were made in relation to the current ACM labelling which should. be updated. The use of suitable labelling on lagging that does not contain ACM would also help in relation to ACM management. The LACP explained that he did not have confidence in. the standard of ACM stripping carried out prior to 2005 and a number of areas were identified in the Turbine Hall where he felt that ACM residues could be present beneath later non asbestos lagging, 2.4.8 On the 5” January we visited the joiners shop and spoke with the working foreman in. relation to a joinery job taking place in an office area. The foreman confirmed that he would rot refer directly to the site asbestos register when planning such work but that he would contact the LACP in relation to any potential ACM concerns. 2.4.7 On the 6" January 1 met various union safety representatives. They expressed Confidence in the site ACM management procedures and in the LACP. One of the safety representatives is involved in the project planning process and was aware of the asbestos register database and the requirement to check relevant information. All safety representatives. spoke of a positive culture in relation to ACM management and that if in doubt over a particular substance there was the ability to stop work and check with the ACP function. 2.4.8 On the 6" January | visited the pile cap area and was able to see the large area of asbestos insulating board (AIB) that lines the internal walls of the building. The AIB consists of 1 metre squared boards and appeared in good condition. The site has had problems in the past with sections of AIB panels in this area breaking away from their fixings. These areas have received remedial attention in relation to the provision of additional structural fixings although some areas remain where itis not possible to carry out inspections. The longer term site plans for the AIB in the pile cap area have not yet been decided. 2.4.9 On the 6" January | visited the site asbestos laboratory and had discussion with the Exova asbestos analyst's. The asbestos database (ACE) was explored in’relation to the ‘numbers of high risk ACM locations on site, levels of use of photographs and drawings, frequency of ACM inspections and numbers of outstanding inspections. 151 high risk locations were identified from the database and the site were not able to demonstrate with confidence the current situation for these locations. This matter required urgent action. Photographs are in place for approximately 70% of ACM sites and this will increase as photographs are now being taken as part of re-inspection work. 2.5.0 On the 6" January | visited the Reactor 2 area. This Reactor was shut down a few years ‘ago and observations were made in relation to the condition of ACM material in the reactor ‘and pipe bridge areas. Damage was observed to lagging in the pipe bridge area and the LACP stated that he would have expected for such damage to have been raised on a learning capture report form (LCR) although this had not happened. 2.5.1 On the 6" January | visited the Turbine Hall and observations were made in relation to the amount of ACM lagging and its condition and labelling. In the envelope area a restricted zone has been established due to concerns over ACM pipe lagging falling from higher levels. (tear Nico Rea onReassurance air monitoring is carried out on a regular basis and results so far have been. below control limits. A longer term ACM strategy is required for this area which has operated as a restricted zone since 2011 2.5.2 On the 6" January | spoke with a mechanical maintenance team leader and SPT with, regard to the site asbestos management procedures. The team dealt with planned work on a. 6 week schedule. Work control cards are used with risk assessments recording any potential ‘ACM presence. Engineers contact the LACP if they require clarification of the nature of materials in relation to asbestos. The SPT was aware of the asbestos register on the company intranet but was not accessing the information directly, preferring instead to contact the LACP. 2.5.3 On the 6” January | spoke with electrical engineers to review their internal investigation into an electric shock incident that happened on the 9" November 2015. While this incident did not result in any injury and was not RIDDOR reportable there were nevertheless some important leaming outcomes identified in the report. The report is due to go forward to an internal Opex meeting during the week commencing the 11" January 2016 and | have asked to receive an update on the implementation of the report recommendations. 2.6 Conclusions The company were given feedback on the 6” January 2016 during which time the issues set ‘out within this report were discussed and were accepted by the management team who were positive both in relation to their desire to complete the necessary improvements and to reflect, Cn the issues raised. After considering the EMM a formal letter o the company was decided to be the appropriate mechanism to progress matters. The company were informed that a follow Up visit would be made in Q3-4 of 2016. ‘A corporate asbestos intervention with Magnox is being planned, with an estimated stat date of April 2016, This intervention will explore a number ofthe leaming issues discovered during the Wyifa visit eg general deteriorating condition of some ACM's, how the learning from the ‘AIB problem in the pile cap area has been considered, how funding for asbestos management is being structured to allow for emerging works. During the meeting on the 6” January 2016 I was given verbal confirmation that the priority issue identified in the Turbine Hall would be urgently actioned by a licensed contractor. 3. ISSUES 34 Issues Raised (foo forNaclar Regula onPern ns Level Ri 3 |wyifa ste Coo (inspector) Review Date [August 2016 rs Issue Title en [373 [Managing asbestos ICompliance Je containing materials at Wyte 3.2 Issues Closed Pere rer Cen Level Role Co een ory RECORD APPROVAL, SIGN-OFF AND ISSUE tice con-corsr5é6 20188660 Page 16016RECORD APPROVAL AND SIGN-OFF Note: Documents must be finalised on TRIM when signed-off / approved for issue reer onn) Corny Name ey Inpro 'aiori2016 VERSION CONTROL Pa Sn CIRCULATION LIST records may be needed Cd os lOtice for Nuclear Regulation Electronic copy unless stated otherwise, e.. if enforcement action is being considered hard copy 1410112016 Page 8016[rmtower ae ‘one. coP sR. 088850 Page 6016