Office for Nuclear Regulation CONTACT RECORD [Unique Document ID and Revision No: JONR-COP-CR-16-317 [Trim }2016/504480 Purpose of visit: [Asbestos management progress update and further enquiries into work at height concerns. Date of Contact: 14" December 2016 128" December 2016 1. Compiled By: smme} Type of Contact (tote not apaicabie) Piant visitimeetings at the Magnox Wyifa site IContact with: (names, postion, organisation) 1. Introductions/overview of asbestos management progress made since January 2016 and strategic plans for Turbine Hall. . Discussion of work at height arrangements on the flask handling crane and associated area. |. Meeting safoty representatives |. Plant visit - Turbine Hall (various levels).Report oNR-coP-cR-317 ‘Taner forest 5. Feedback. JONR st (eames , ol, programm Introduction: The purpose of the visit was to establish the progress Magnox Ltd. had made at the Wyifa site since the last ONR visit undertaken in January 2016 regarding asbestos management and establish whether action taken following two asbeslos management related Jevents in September 2016 met the requirements of the Controi of Asbestos Regulations 2016. [The asbestos management aspect of the visit comprised of a meeting, plant visit to the Turbine| Hall and feedback session. The visit was not a full re-inspection of the site's arrangements for managing asbestos containing materials (ACMSs). |The visit was broadly undertaken as per the agenda saved as TRIM document 2016/504017 | Key observations from meetings/plant visit: 1. Introductions/overview of asbestos management progress made since January 2016 and ‘strategic plans for Turbine Hall [The discussion comprised of a presentation delivered by Wylfa personnel and the Plant & Structures Programme Manager summarising progress update discussion and overview of strategic actions, followed by general discussion around asbestos management. The discussions lwere informed by documenis provided by Magnox Lid. before and during the visi, see betow for references. The topics covered (in varying degrees of detal) and Key points arising included: ‘= Changes to key personnel, roles/responsibilties since January 2016 - The Lead Asbestos ‘Competent Person has had some contractor responsibilities removed from him in order to free| up much needed resource for his asbestos management responsibilities. Additional analysts| have been temporarily transferred from Trawsfynydd to assist with clearing the backiog of| condition monitoring assessments, now reported to be reduced to 40, versus 500 in January| 2016. Additional asbestos remover resource (provided by Hertel) has also been secured for the site ‘© Update regarding the Wyifa asbestos profile, including progress against the action plan and works planned over the next 3-4 months - 20 of the 28 previously identified high priority asbestos materials have been removed, repaired or encapsulated. The remaining work is to be completed by the end of March 2017. ‘+ Update on any changes made to the Magnox/site asbestos management arrangements {including provision of information for those involved in removalirepair and operations not Gitectly related to asbestos) since January 2016 — ONR was informed that work has been| undertaken to improve the provision of asbestos related information to workers in the form of] briefings and the inclusion of asbestos references in a work pack document Work Identification| Hazard Assessment (WIHA) form. '* Status of programme to remove ACMSs in the Turbine Hall and how recent events involving asbestos containing materials (ACMss) or work where ACMs may be encountered and actions| taken or planned to prevent a recurrence — The presentation provided during the visit provided an overview of the bulk asbestos removal project that is currently being developed for the| Turbine Hall - to commence by the end of April 2017. In the meantime, acoess is restricted to| some jocations within the Turbine Hall although Magnox Ltd. have not identified any elevated fie fo Nace Reguatn Page otasbestos fibre results in the extensive air monitoring currently being undertaken. = Overview of Magnox Wyifa monitoring, audit and review activities (including any related assurance activities) for asbestos management ~ examples of recent assurance work Undertaken were provided prior to the visit Once the plant visit had been undertaken, it was evident that the assurance work carried out by Magnox site inspectors was not sufficiently| rigorous. The assurance work seen was based on compliance with the company standard rather than compliance against the relevant legislation. As a result, the assurance work did not ‘identify some of the observations made during the plant visit. Documents provided pro-visi: |. E:mail correspondence and photographs sent and received in September and October| 2016, TRIM refs. 2016/363614, 2016/363617, 2016/388371, 20161412930, 2016/412934, 2016/412937, 2016/412940, 20161413944. |i, E-mail with updated asbestos improvement schedule and management plan (version 9) - received 9th December, TRIM ref. 2016.2016/483946. iii, Wylfa asbestos management pian (version 8), improvement plan and assurance reports - received 2nd December 2016, TRIM ref. 2016/501154. [Documents provided during the visit: i Copy of presentation tilled ‘ONR Conventional H&S Inspection, Wyifa asbestos| management’, TRIM ref. 2016/501080. 2. Safety representative's discussion. |A short meeting was held with available safety representatives to explain the purpose of the visit land answer any questions/concems raised. Questions asked related to arrangements, recently introduced in the Turbine Hall to restrict access to certain parts of the Turbine Hall basement due. land whether this meant that employees were being exposed to asbestos fibres. The reassurance that is currently provided by the extensive air monitoring was explained to the safety representatives and the bulk removal work currently being planned. There were no safety| representatives present at the feedback session so the concems expressed after the plant visit regarding the degraded conditions were not communicated during this meeting (fice for Nucla Raguaon Page 3.08enema” 4. Plant visit to various parts of the Turbine Hall number of locations were visited in and by the Turbine Hall to show asbestos containing| lmaterials (ACMs) that had been repaired or encapsulated, but also ACMs that were in a degraded| state. JPart of the plant visit included accessing the Turbine Hall basement and seeing the locations| lwhere access is restricted at present. It was explained that additional precautions such as| IPPE/RPE are not required for these areas, but that Magnox had taken the conservative decision to restrict access to all but those that had a reason to access the basement areas. Air monitoring} results were seen (fibre count below limits of detection) prior to accessing the basement to ensure lthe personal health of the ONR personnel during the visit and a risk assessment for general laccess into the basement was briefed to all present. There was limited opportunity to speak to| plant personnel, but those spoken to appeared to have a good awareness of what asbestos| Imaterials may be present in their work locations and how to find out where asbestos materials are| located on the Wyifa site. However, the site's arrangements for provision of asbestos related information were not sufficiently tested during this visit to confirm whether they are sufficientl| robust. [The locations visited were: North & South Pipebridges, T. Hall basement areas Column 9-11, and columns 20-21; T1 Column 7, T2 Column 10, Separator Pressure Vessel no. 3; Deaerator floor. Recently repaired ACMs were seen in the locations where asbestos events had occurred in| ISeptember 2016 and the lead ACP described the difficulties in accessing these ACMs and many| others that are present in the Turbine Hall. It was evident from the plant visit that there is lextensive degradation of pipe insulation and associated coatings in the Turbine Hall since power| |generation has ceased on the Wyifa site. It was acknowledged that some of the examples seen of degraded pipe insulation were not lasbestos containing, However, the Wylfa ACP has previously stated that residual asbestos| lcontaining material has been found in a number of locations underneath the non-ACM (from| historic asbestos removal work no executed to modem day standards), to the extent that Magnox| Lid. cannot assume that pipes currently identified as asbestos free are in fact free of residual JACM. As @ result, the decision has been correctly made to assume all pipe insulation and| pipework underneath is asbestos containing or contaminated with ACMs unless proven otherwise. IConcern was expressed regarding the nature and extent of the various examples of degraded pipe insulation seen during the plant visit, Concem was also expressed that some of the ldegraded conditions appeared to be long standing as it was evident from the physical condition of| Isome of the pipe insulation seen that the degradation was gradual deterioration and not as a result of changes to the ambient or plant temperatures. Lastly, work regarding insulation on Separator pressure vessel TA no.3 was discussed. From Iseeing the pressure vessel it was evident the condition of the insulation was poor and that it Ineeded to be removed. However, work on the vessel is currently programmed in the improvement} lplan to commence at the start of February 2017 and take two weeks to complete. The| lcombination of the complex nature of the pressure vessel, diiculties in accessing it, the insulation Jcondition, building an asbestos enclosure and then removing the insulation to the relevant| (sco Nuc Raguston Page ote[standard meant that the nature of the works planned was questioned. If removal work Is planned the time to complete the works has been significantly underestimated, As a result, doubt was cast} lon the accuracy of the remainder of the improvement plan provided to ONR prior to the visit. 5. Feedback Feedback was provided after a short 1:1 discussion with the Magnox site inspector to obtain her} perspective on the plant visit. It was conveyed that it was evident that progress had been made by the site to improve the} lasbestos management arrangements, particularly resourcing of key asbestos personnel, clearing} the backlog of condition monitoring and removal, repair or encapsulation of the majority of high| priority ACMs with plans to address the remainder by end of March 2017. However, the concerns raised during the plant visit were communicated, particularly the nature] land extent of degraded conditions seen in the Turbine Hall. It was highlighted that whilst some of| the degraded conditions seen had clearly occurred since the site had ceased power generation, al number of examples of long-standing degraded conditions were also observed. As such, it was| stated that ONR needed to consider what the appropriate visit outcome should be. [Two key messages were conveyed in the feedback: i. The Improvement pian timescales need to be reviewed as the plant visit shed some} doubt regarding the accuracy of the resources assigned to completing some of the| asbestos removal works identified. It was emphasised that the plan needed to be| accurate as Magnox Ltd. will be measured against the timescales by ONR on an| ‘ongoing basis. ji, Magnox Ltd. needed to learn the lessons from the Turbine Hall conditions when| ‘considering the asbestos pipe insulation remaining in the reactor building and start planning now what arrangements need to be considered to avoid the same degraded| conditions occurring in the reactor building once temperatures in the building start decreasing. ere was broad acceptance of the feedback provided by ONR and commitment to complete] Jaction 1 below. ONR committed to providing more considered feedback and a visit outcome in| january 2017. However, it was stated that the existing ONR regulatory issue relating to asbestos| management at Wylfa could not be considered completed, and that the priority assigned to the| issue needed increasing to ensure corporate oversight by both ONR and Magnox Lid. JActions arising from visit: 41. Magnox Wyifa to review the timescales for delivery of the Asbestos Improvement Plan for the site and send the revised plan to ONR - by 13" January 2017. 2, Magnox Ltd. to provide copies of the conditional surveys undertaken by the Magnox| Asbestos SME and Asbestos Manager at Wylfa in April and September 2016 - by 13” January 2017. 3. ONR to consider the Enforcement Management Model, determine the appropriate enforcement action for the observations seen and inform the site — by 13" January 2017. 4. Regulatory issue 4168 to be updated and priority rating increased from Lé to L2 issue, subject to endorsement — by end of January 2017. 5. ONR to plan a further revisit to Wylfa by Q1 2017/18, subject to appropriate resource and other work priorities. (fos or Nace Region Posts1 ISSUES 414 Issue Title Nia. No. Issues Raised eMC car Issue ie] eed ‘Owner tc) Coe eer co ero ene Cg ec) Circulation List Organisation [Ot for Nuclear Regulation (cee 128" December 2016