Executive summary
Date(s) of inspection:
- February 2025
Aim of inspection
The aim of the inspection was to understand how the licensee manages risks associated with asbestos at Dungeness B. Part of the inspection focused on the wider management of asbestos on site. The inspection also sampled work that has taken place or will be taking place at site that has the potential to disturb asbestos and how this is managed.
Relevant good practise that will be used to benchmark the site will be L143 Managing and working with asbestos - Control of Asbestos Regulations 2012 Approved Code of Practise and guidance.
Subject(s) of inspection
- Asbestos - Rating: Green
- Health & Safety at Work Act - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
This inspection focussed on the Control of Asbestos Regulations 2012 and how EDF Energy Nuclear Generation Limited (EDF NGL) was ensuring their compliance with the regulations. The topic was chosen as the station is currently defueling and are sufficiently near to the start of dismantling and deconstruction work for it to be proportionate to target these regulations as an area of potentially increasing safety risk.
The inspection involved two days on site consisting of office based discussions and a site walk-down.
The office based discussions focussed on a number of key areas including: stations asbestos register, their asbestos management plan, baseline risk assessments for non-notifiable non-licensable work carried out by EDF NGL staff, and discussions with the licensed asbestos contractor on station (Altrad Services).
At the time of the inspection there was no removal work taking place as such the walk-down focussed on areas EDF NGL had identified within their improvement plan. The walkdown also sampled items of plant where EDF NGL are presuming asbestos is contained within as they are unable to demonstrate that they do not. An example of this includes pipework lagging within the turbine hall.
The station were able to demonstrate good practice in relation to asbestos removal. It was particularly clear that maintenance staff had a good understanding of how to approach work likely to disturb asbestos for example compressed asbestos fibre (CAF) gasket removal.
At the time of the inspection stations asbestos register did not make reference to fixed plant. The register is to be updated to reflect sites positions that they are to presume until proven otherwise that this equipment contains asbestos. Despite this assumption areas on plant were identified, such as dump condenser 21 which had some damaged lagging. No protective measures were in place and site were unable to confirm that asbestos was not present within this, therefore stations assertion that items were presumed to contain asbestos until it could be proved otherwise was not verified from the areas sampled at inspection. A level four regulatory issue has been raised on the back of this inspection to address this point.
Conclusion
EDF NGL Dungeness B were able to demonstrate that they were compliant with the majority of the Control of Asbestos Regulations 2012. They have an asbestos management plan in place and their asbestos register is kept up to date. They had self-identified that further resource was necessary in order to assist the asbestos co-ordinator and they are in a position where they have some resilience in this role.
There were knowledgeable individuals at station in relation the process for non-licensable work. There are also clear procedures for identifying notifiable non-licensed work and processes in place to deal with this when it was identified. Altrad Services have a permanent presence on station and they were able to demonstrate a good working knowledge of asbestos containing material on site and the strategy for dealing with it.
The station explained that the management plan did not consider fixed items of plant (for example lagging on pipework). As such they are working on the assumption that this contains asbestos until proven otherwise. They were unable to demonstrate that there was evidence that pipework lagging did not contain asbestos beyond individuals on station believing that they were asbestos free. As such a regulatory issue will be raised to ensure that station have arrangements in place to ensure there is strong evidence that plant does not have ACM present within it. An example of this may be initial plant design, historical maintenance records.