Office for Nuclear Regulation INTERVENTION RECORD [Unique Document ID and _[ONR-COP-IR-16-071 Revision No: Revision 0 [pe Rets: || 202 7izeAoe. Location and purpose of |Magnox Lid. (Wyifa site) - Inspection of arrangements for Intervention: managing asbestos containing materials (ACM's) Inspector(s) taking part in Intervention: (Introductions and part jedback only} Date(s) of intervention: [9 February 2017 PRINCIPAL STAFF SEEN Name & Role Ce en cu 24.1 Introductions, scope of visit and review of asbestos rsk register IMagnox Ld (unless stated otherwise) 241 Turbine Hall & Reactor building Plant visits - Turbine Hall & Reactor Building] | 2A Meeting safety representatives 25 Initial feedback to site (by phone)hi et aan INTERVENTION RATINGS - (FOR USE ONLY BY CNS & CROSS ONR PROGRAMMES) Complete this section only where applicable for a Security/Transport/Safeguards/Conventional [Safety/Fire Inspection. If not applicable, enter "nla". Complete Part A in respect of System / Structures Based Inspection, if applicable. eer) 7 a Bd ni eran cer CEO aaa et [Sampling of arrangements |Conventional Health and to manage asbestos [containing materials at the Wyifa site *P = planned, RUP = reactive unplannedSeva aisoee TABLE OF CONTENTS 1 EXECUTIVE SUMMARY..... 2 RECORD ° 3 ISSUES. (Ofc Nica Reston Paya1. EXECUTIVE SUMMARY 1.4. Purpose of Intervention ‘The intervention was a continuation of a visit undertaken in December 2016 to assess the condition of asbestos containing materials (ACMs) in the Turbine Hall & Reactor buildings & establish actions being taken by Magnox Lid. to manage the possible degradation of ACMs. More specifically, the purpose of the intervention was: * To review the adequacy of Magnox Ltd's arrangements for managing asbestos containing materials at the Wyifa site in light of potential changes to the condition of asbestos materials after power generation at the site ceased ‘The intervention also follows on from an asbestos management intervention that was carried out at the Wyifa site in January 2016 1.2 Interventions Carried Out by ONR ‘The key regulatory activities undertaken during the one day visit were based around an agenda previously agreed with Magnox Wyifa. Plant visits were undertaken to ascertain whether existing asbestos management arrangements: + are such that risk presented by asbestos containing materials (ACMs) is being controlled, and + are such that they are adequate for the size of the organisation, and appropriate for the nature of Magnox Ltd.'s undertaking, Locations visited during the intervention were selected using regulatory intelligence gained {from previous interventions, recent interactions with the site, and review of the site's inventory of materials assessed to be ‘high risk’. Key performance indicators used to assess the adequacy of organisational and physical control measures were broadly based on the requirements of sections 2 & 3 of the Health & Safety at Work etc Act 1974 and relevant statutory provisions made under the Act. These include: Management of Health & Safety at Work Regulations 1999 (regulation §), and the Control of Asbestos Regulations 2012 (CAR 2012) and the associated Approved Code of Practice, particularly regulation 4 and paragraphs 81-147. 1.3 Key Findings, Inspector's Opinions and Reasons for Judgements Made i. A good level of competent site based resource (with corporate support) now appears to be developing for proactive asbestos management. The site Closure Director is stating his commitment to addressing the known issues on the site. It was emphasised by ONR, and acknowledged by the site personnel met, that the remedial actions require sustained long term focus. li, Progress has been made in a number of areas of asbestos management, including reviewing action plans, briefing site workers and condition monitoring of known or presumed asbestos materials. ii, Compromises to Magnox's ability to undertake accurate risk profiling were identified ‘examples are summarised below. The comipromises impact on Magnox’s ability to; accurately identify the full nature and extent of risk presented by asbestos containing materials at the Wyla site, and; concentrate resource to where it is most required, a. The Wylfa site has a large inventory of materials known or presumed to be asbestos containing. Approximately 75% of the items identified are presumed to contain (feof Nea Reguston orasbestos as they haven't been sampled, but (in accordance with CAR 2012) are designated suspected ACMSs. b. The Wylfa lead asbestos competent person has previousty explained that he does not have confidence in the standard of ACM stripping carried out prior to 2005. Therefore, there are numerous presumed ACMs where asbestos residues may be present beneath more recently applied non-asbestos pipe lagging. This approach is in accordance with the legislative requirements and is supported by ONR. However, the site's risk assessment methodology does not appear to differentiate between possible asbestos residues under non-asbestos pipe insulation and asbestos pipe insulation, This in turn impacts inventory risk profiling, cc. Examples of materials were seen that did not reflect the designated risk score applied by analysts working on behalf of Magnox. In addition, validation of the risk scores did not appear to be routinely undertaken by Magnox. Magnox Wyifa cannot currently Place fll confidence on the scoring system used within asbestos risk assessments to Inform risk profiling and prioritisation of actions. iv. Known or presumed ACMs classed by Magnox as ‘high risk’ were seen in a number of locations around the Turbine Hall and Reactor Building, A variety of ACMs were seen ranging {rom debris to pipe insulation in both accessible and inaccessible areas. Magnox Wyifa has an extensive air monitoring programme underway to provide reassurance that airborne asbestos fibres are not present in these locations. In addition, work is underway or planned to remove, repair or enclose presumed ACMs in the Turbine Hall, However, Magnox was not in a position’ to articulate similar action for ACMs within the Reactor Building. Concer was ‘expressed that Magnox is not taking appropriate action to manage asbestos materials such that they are in a good state of repair. NB. Findings ii. and iv. have implications for Magnox Ltd. at a corporate level, and this is being taken forward by ONR as part of an angoing corporate intervention, 1.4 Conclusion of Intervention ‘There was recognition by both the site and corporate asbestos management team members present (including the Site Closure Director) 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. However, it was explained that the extent of the degraded asbestos materials identified at the \Wyifa site and lack of supporting arrangements to manage the material according to risk were such that the visit outcome was identified to meet ONR's inspection rating of ‘shortfalls in health requirements resulting in significant avoidable risks to workers, with at least one contravention that gives rise to a discemible risk gap under the ONR EMM’. This in tum indicates that an inspection rating of ‘red — significantly below standard/unacceptable’ should be applied to the visit, ‘The ONR Enforcement Management Model (EMM) has also been considered in relation to the other priority actions identified and the enforcement outcome is being considered in line with established ONR procedures. However, an enforcement letter will be sent to Magnox Ltd. for the other priority actions identified, regardless of any enforcement outcome decisions currently being determined for asbestos management at the Wyifa sito, In addition, consideration will be given regarding whether regulatory action needs to be taken at a corporate level. A meeting is planned with Magnox corporate personnel on the 28" March 2017. This meeting will inform any actions taken at an organisational level Related issues on the ONR Regulatory Issues database (4168 and 4789, both level 2) will be reviewed and amended as required to reflect the visit findings.2 RECORD 24 Purpose of the intervention: ‘The intervention was a continuation of a visit undertaken in December 2016 to assess the condition of asbestos containing materials (ACMs) in the Turbine Hall & Reactor buildings & establish actions being taken by Magnox Ltd. to manage the possible degradation of ACMs. ONR Contact Record ONR-COP-CR-16-317 refers, TRIM ref. 2016/504480. More specifically, the purpose of the intervention was: ‘+ To review the adequacy of Magnox Lid.’s arrangements for managing asbestos containing materials at the Wyifa site in light of potential changes to the condition of asbestos materials after power generation at the site ceased. There are approximately 4-5000 deaths from asbestos related diseases in the UK each year Ff these people dying, 25% are tradesmen such as builders, plumbers, carpenters and electricians. Factors that increase the risk presented by the asbestos hazard present on the \Wyifa site and/or support the need for ths intervention include: ‘+The size of the asbestos inventory on the Wylfa site. The Magnox sites were built between the 1940s-1960s, when ACMs were widely used as @ construction material, particularly as lagging materials, ‘+ The main site and regulatory focus is concentrated on ensuring timely defueling of the reactors. However, changes in environmental conditions in 2016 (since power generation ceased) have resulted in deterioration of some of the known or presumed asbestos materials. ‘+ Magnox do not plan to remove all ACMs from their sites prior to entry into C&M plans. ‘As such, long term arrangements for monitoring ACM condition and building/plant integrity become relevant. ‘+ The intervention follows from an asbestos management intervention that was carried out at the Wylfa site in January 2016. Intervention record ONR-COP- IR-15-66 refers, TRIM ref. 2016/18650. Hence, managing and working with ACMs remains a priority nuclear site health topic for ONR. CONR has two current relevant regulatory issues relating to tis op, isue numbers 4168 and 2.2 Key locations visited: i. Turbine Hall - Deaerator floor, Centre loading bay, Basement. li, Reactor Building — various areas, as summarised below. ‘+ Reactor 2: 691 level - SW comer, 41f1 Economiser penetrations, Gas Circulator 7 motor room, Electrical Switchgear 9 cable riser room. ‘+ Reactor 1: 85it level Boiler drum, 56ft Boiler Circulator level, 691t level above Boiler Circulator pumps 1A. (tice for Nie Reguon Page 6 42.3 Key regulatory activities undertaken: 2.3.1 The key regulatory activities undertaken during the one day visit were based around an agenda previously agreed with Magnox Wylfa (TRIM ref. 2017/62411). Plant visits were undertaken in the Turbine Hall and Reactor buildings - to ascertain whether existing asbestos ‘management arrangements + are such that risk presented by asbestos containing materials (ACMs) is being controlled, and * are such that they are adequate for the size of the organisation and appropriate for the ‘nature of Magnox Ltd.'s undertaking, 2.3.2 These locations were selected using regulatory intelligence gained from previous interventions, review of the site's inventory of materials assessed to be ‘high risk’ and interactions with the site. Magnox Ltd. provided ONR with relevant and requested documentation, prior to the site intervention. The documentation is saved in TRIM folders 4.3.485 and 4.3.602. and is outlined in section 2.4. 2.3.3 Key performance indicators used to assess the adequacy of organisational and physical control measures were broadly based on the requirements of: + Sections 2 & 3 of the Health & Safely at Work etc Act 1974 and relevant statutory provisions made under the Act, including: Management of Health & Safety at Work Rogulations 1999 (regulation §), and the Control of Asbestos Regulations 2012 (CAR 2012) and associated Approved Code of Practice, particularly regulation 4 and paragraphs 81-147 2.3.4 Paragraph 112 of the Approved Code of Practice was referred to during the visit to set ‘out the principles of asbestos management. This paragraph states ‘dulyholders are required to ensure that: i, reasonable steps are taken to find materials in premises likely to contain asbestos and to check their condition; |i, materials are presumed to contain asbestos unless there is strong evidence that they do not; lil, a written record of the location and condition of asbestos and/or presumed ACMs is made and that the record is kept up to date; iv. the risk of anyone being exposed to these materials is assessed; v. a written plan to manage that risk is prepared and that the plan is put into effect to make sure that © any material known or presumed to contain asbesios is Kept in a good state of repair, © any material that contains or is presumed to contain asbestos is, because of the risks associated with its location or condition, repaired and adequately protected or, iit isin a vulnerable position and cannot be adequately repaired or protected, itis removed; © information on the location and condition of the material is given fo anyone who is lable to disturb It or is otherwise potentially at sk. 24 Key Findings. 2.4.1 The key findings are structured around the meetings attended and plant visits undertaken, A number of areas of good practice were seen during the visit, in addition to a ‘number of areas for improvement. Nase Regsation Page 7 42.4.2 Documents relevant to the intervention (and TRIM references): [Document summary TRIM reference [E-mail received June 2016 with Magnox Company Standard for asbestos |2016/236650 management re. $-267 attached intervention record ONR-COP- IR-15-66 (Inspection of arrangements for |2016/18650 Imanaging ACMs) ~ January 2016. Letter sent to Magnox Wyifa 25” January 2016, ONR-COP-CHS-16-23. _[2016/32640 [ONR Contact Record ONR-COP-CR-16-317, [2016504480 [E-mail received 11° January 2017 with following attachments: 2017114236 |. Condition survey undertaken by Magnox Asbestos subject matter expert |(SME) in March 2016; i. Condition survey undertaken by Magnox Asbestos subject matter expert |(SME) in September 2016; i. Wyifa Asbestos Management Improvement Plan, v2, 10.01.17 [E-mail sent 30” January 2017 with lst of information requested and 2otriezant lagenda attached for the 9/2/17 visi E-mal received 3° February 2017 with folowing attachments [2017162399 I, Wits Asbestos Management Improvement Pian, vi 4.02.17; i, Wyifa ste asbestos register extract, scores 20 and above; il. Wylfa asbestos management pian, issue 10, iv. Layout of nuclear licensed site, ref. SF003, rev 66, Photographs taken during site visit 9” February 2017 2017162547 & 2017162548 ‘Scanned copy of information obtained from Magnox Wyifa E-locate 2017162248 asbestos register. [Schedule of presumed asbestos materials on the Magnox Wyifa site | 2017/62254 [Air monitoring results provided to ONR 13th February 2017, requested | 2017/62549 after site vist 9th February 2017. 2.41. Introductions, scope of visit and review of asbestos risk register ~ A recap of the ONR Visit to site in December 2016 was provided and the following Identified with a total risk score of 20 or above; ACMs with a material abov' status of asbestos condition monitoring undertaken on site. Key points: topics discussed: ACMs assessment score of 8 or Magnox Ltd.’s arrangements for managing degrading known or suspect ACMs, and a) ONR was informed that the Wyifa site has 1694 items of known or presumed ACMs within its inventory. Approximately 75% of these items (1322) are presumed to contain asbestos as they haven't been sampled but (in accordance with CAR 2012) are suspected ACMs. b) The Wylfa lead asbestos competent person has previously explained that he does not have confidence in the standard of ACM stripping carried out prior to 2005. Therefore, there are numerous presumed ACMs where asbestos residues may be present cafe Nac Rouen° 4) e) D) 9) n) ) fie far naesRepuon beneath more recently applied non-asbestos pipe lagging. This approach is in accordance with the legislative requirements and is supported by ONR. However, the site's risk assessment methodology does not appear to differentiate between possible asbestos residues under non-asbestos pipe insulation and asbestos pipe insulation. This in turn impacts inventory risk profiling Consition monitoring is now up to date (5 items are classed as overdue, but were due for inspection wic 6" February 2017). Al items on the asbestos inventory are currently inspected 12 monthly (including materials classed as ‘high risk’. The inspection frequency is being reviewed. Materials that are deteriorating or are in environments where accelerated deterioration may ‘occur will need to be inspected more frequently. There were 39 ‘high risk/priority’ items on site on the day of the visit. These are classed as ‘high risk’ following a two stage assessment process. The first stago includes consideration of ACM material risk and second stage considers probability of disturbance and exposure to ACMs. The process follows the company standard S-267, which in turn adopts principles published in long-established HSE guidance. The Wylfa personnel present gave a commitment to act to reduce the risk associated with these items, but could not provide dates for action or details of action to be taken for all materials identified to be ‘high risk’ ‘The number of known or presumed ACMs identified as ‘medium risk’ was identified by Magnox to be 1400 (as of 30” January 2017). ‘A good level of competent site based resource (with corporate support) now appears to be developing for proactive asbestos management. The site Closure Director is siating his commitment to addressing the known issues on the site. it was emphasised by ONR and acknowledged by the site personnel met thatthe remedial actions require sustained long term focus. Progress has been made in a number of areas of asbestos management, including i reviewing/progressing action plans, i. providing information to site workers regarding the presence of asbestos and tli, condition monitoring of known or presumed asbestos materials The site has a number of areas where access is restricted to non-essential personnel ‘Arrangements for these areas were described and assessed during the plant walkdowns. However, Magnox were also asked to describe what action was being taken to address the risks that gave rise tothe restricted access areas being required. See later sections of this report fr further details, ‘A short discussion was held regarding the site asbestos management plan, which has recently been reviewed. It was identified that the management plan did not identify speotfic action for high risk ACMs and did not fully capture the air monitoring methodology adopted for the site, both routine and non-routine. The site Lead Asbestos Competent Person provided an explanation of the arrangements adopted by Exova - Magnox asbestos analysis. It was suggested that the site management plan included reference to the arrangements and that Magnox review the arrangements ~ to ensure that they reflect Magnoxllegal requirements. Asbestos register - Several items from the ‘high risk’ list of ACMs were identified and Magnox was asked to provide further detail regarding the information held on each material. Magnox uses an electronic database called E-Locate to manage its asbestos inventories across the sites. The items reviewed were:[Magnox |Kem Intervention findings ONR _observations/comments| tom ref, description arising from review of information Ino, held by Magnox Ltd, '7a09400 [Pine (Material sampled 6/2/17, |See later comments regarding insulation confirmed to be nor-ACM, confidence in information held by’ Magnox. ire1e872 [ACM scored 21 out of a|Two months on Magnox have not yei| possible 24 for risk so ‘high identified whether material is an ACM Fisk’. Inspected 6/12/16 by or acted on asbestos analyst advice [Exova (not sampled) and action identiied: Take immediate faction to cordon off the area i7e15181 JACM scored 20 out of 24 — high|Seven months on Magnox have not| isk. Inspected June ‘16 by|yet identified whether material is an [Exova (not sampled) and action |ACM or acted on asbestos analyst identified: Take immediate |advice, action. '7818796 [ACM scored 20 out of 24 — high risk. Identified as being in a restricted area but routinely Cisturbed. Inspected 6/12/16 by [Exova (not sampled) and action Identified: Reduce risk by [Two months on Magnox have not yet removal. identified whether material is an ACM [7742413 [insulation [ACM scored 20 out of 24 — high | ted on asbestos analyst advice debris risk. Inspected 6/12/16 by, [Exova (not sampled) and action identified: immediate action to contr access. 241i, Plant visits ~ Turbine Hall & Reactor Building - Plant visits were undertaken to see asbestos containing materials and work being carried out on some ACMs. Short visits were undertaken to the locations identified in section 2.2 of this report. A short discussion was also held with two Exova personnel — to establish the site's arrangements for air monitoring. Two live asbestos enclosure and various materials identified as ACMs were seen. It was emphasised to site and Hertel personnel that inspections of the removal work were not Undertaken due to time constraints and as they were not part of the visit purpose. In addition, the plant visits concentrated on evaluating the condition of ACMs and how they were being managed by Magnox. As a result, Magnox arrangements for providing information to workers who may distur ACMs during the course of their work were not tested. ‘Good practice observed: * Good standards of asbestos enclosure construction was seen for the two live asbestos enclosures seen during the visit although Hertel were asked to tape a small tear in one of the enclosures seen (stage work was at during visit and good level of negative pressure observed means that tear presented minimal increase in risk). + A good standard of visibility was seen for each asbestos enclosure. The cameras and vision panels used were to a good standard and showed the majority of the enclosure fice ote Regn Page Toot 18areas although advice was given to reposition cameras in an enclosure for the Steam Pressure Vessel 661 ACM removal works. ‘+ An established programme of air monitoring (for reassurance and detection purposes) is undertaken in a number of locations. Reassurance air monitoring Is carried out on a regular basis and results so far have been satisfactory. The programme needs to be incorporated into the site's documented asbestos management arrangements. + Access is restricted in some locations of the Turbine Hall to those carrying out ‘essential work’. ONR was informed that the lead asbestos competent person monitors. entries into the restricted areas to make sure that any entries made were required. However, see also ‘areas for improvement’ section below. ‘Areas for improvement; ‘+ Priority - Known or presumed ACMSs classed by Magnox as ‘high risk’ were seen in a ‘number of locations around the Turbine Hall and Reactor Building, A variety of ACMs were seen ranging from debris to pipe insulation In both accessible and inaccessible areas. However, Magnox'was rot in 2 position to articulate a similar classification for ‘ACM within the Reactor Building * Priority - Concern was expressed that examples were seen that indicated Magnox are nt taking appropriate action to manage asbestos materials such that they are in a ‘good state of repair in either the Turbine Hall or the Reactor Building. A number of known or presumed ACMs were seen that were in poor condition and not clearly labelled. A number of examples of recently degraded ACMs were seen. The degradation has occurred since the site ceased generating electricity. Work is underway or planned to remove, repair or enclose a number of ACMSs in the Turbine Hall. However, Magnox were not able to explain similar action identified and agreed for ‘ACMMs in the Reactor Building. Concerns were expressed that Magnox has not taken timely or sufficient action to manage the risk of exposure and spread of ACMs and is not proactively managing ACMs in light of foreseeable degradation due to changing environmental conditions. ‘* Priority ~ Reliance on restricted access areas as a means of control. A number of restricted access areas have been established due to site-based concems over ACMs (particularly pipe insulation) falling from higher levels within both the Turbine Hall and Reactor Buildings. As previously mentioned, Magnox Wylfa has an extensive air monitoring programme underway to provide reassurance that airborne asbestos fibres are not present in these locations. However, it was explained that ONR considers this approach does not control the risk of spread of asbestos fibres and does not reduce the risk of worker exposure to as low as reasonably practicable, * Priority - Examples of materials were seen that did not reflect the designated risk ‘score applied by analysts working on behalf of Magnox. Material was seen that was in better condition than the risk score implied. Materials were also seen that were in poor condition, but were not on the site high risk register. In addition, validation of the risk ‘scores did not appear to be routinely undertaken by Magnox. Magnox Wyifa cannot ‘currently place full confidence on the scoring system used within asbestos risk assessments to inform risk profiling and prioritisation of actions, NB. These areas for improvement have implications for Magnox Ltd. asbestos management arrangements at both site and corporate level. (feo Nr Regution Page tof2.4.li, Meeting safety representatives ~ A short meeting was held with available safety representatives to explain the purpose of the visit and answer any questions/concerns raised. | repeated comments made to safety representatives in December 2016, ie. that site personnel can gain reassurance from the air monitoring being carried out around the site. However, | expressed concern regarding the risk assessment and management approach currently’ being taken by Magnox and that | had already identified to site management that formal correspondence would be a minimum outcome from the visit. | invited the safety representatives to accompany me for the aftemoon's plant visitas it appeared they were not aware of my agenda inviting them to be included for both plant visits. 2.5 — Conclusions and initial feedback to site. 2.6.1 Feedback was provided at the end of the site visit to the relevant Magnox Lid. personnel. There was further recognition by both the site and corporate asbestos management team members present (including the Site Closure Director) 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. 2.5.2 However, compromises to Magnox’s ability to undertake accurate asbestos risk profiling were identified, The compromises impact on Magnox’s abilty to accurately identify the full nature and extent of risk presented by asbestos containing materials at the Wylfa site and concentrate resource to where it is most required. It was explained that the extent of the degraded asbestos materials identified at the Wyifa site and lack of supporting arrangements. to manage the material according to risk are such that the visit outcome was identified to meet CONF's inspection rating of ‘shortfalls in health requirements resulting in significant avoidable risks to workers, with at least one contravention that gives rise to a discernible risk gap under the ONR EMM This in tum indicates that an inspection rating of red — significantly below standard/unacceplable’ should be applied to the visit. 2.5.3 Whilst Magnox Ltd, have already committed to address some of the issues identified, there are significant concems as to why more timely action has not been initiated, for example to identify the true extent of the asbestos inventory on the site, or to manage all materials known or presumed to be asbestos containing in a good state of repair. 2.5.4 The ONR Enforcement Management Model (EMM) has also been considered in relation to the priority actions identified, and the enforcement outcome is being considered in line with established ONR procedures. Any EMM considerations need to take into account that Magnox. Lid. has already received an enforcement letter relating to asbestos management at the Wylfa site; ONR-COP.CHS-16-23 refers (TRIM ref. 2016/32640). However, an enforcement letter will be sent to Magnox Ltd. for the priority actions identified regardless of any enforcement ‘outcome decisions currently being determined for asbestos management at the Wyifa site, Action progress will be monitored via discussions and site revisits as appropriate 2.5.5 In addition, consideration will be given regarding whether regulatory action needs to be taken at a corporate level. A meeting is planned with Magnox corporate personnel on the 28th March 2017. This meeting will inform any actions taken at an organisational level. 2.5.6 Related issues on the ONR Regulatory Issues database (4168 and 4789, both level 2) will be reviewed and amended as required to reflect the visit findings and subsequent discussions with Magnox LtdRecord onR.coPsR--071 28 ISSUES a. Issues Raised Where the intervention identies a shortfall in regulatory compliance one or more issues should be raised fo addrass the gap, and brought to tho atfention of the duty holderlicensee. In general, these will be Category 4 issues that can be easily followed up via subsequent interventions. These Issues ‘should be recorded on the ONR Issues Database after the intervention and subsequently tracked and ‘managed. More significant issues should be categorised higher and progressed in the usual manner. Please refer to the Regulatory Issues Management process. ed ed Py ery rg gh sale an ie) b. Issues Closed Completion eo pers ICD yg Or eS) (isc) rey RECORD APPROVAL, SIGN-OFF AND ISSUE RECORD APPROVAL AND SIGN-OFF Note: Documents must be finalised on TRIM when signed-off / approved for issue. eens Coser} A zz | za 22nd February 2017 0 [22nd February 12017 VERSION CONTROL Responsibility Pees 0A 22nd February |1" draft 2017 0 22nd February |1* issue 2017 ca fo Nucla Regen Page 120814CIRCULATION LIST Electronic copy unless stated otherwise, e.g. if enforcement action is being considered hard copy records may be needed rn ey lOttice for Nuclear Regulation |22nd February 12017 Record to be related to TRIM folder 4.3.602. fice for Mile Rguton Page ot