The purpose of the intervention was to carry out an inspection of the EDF Energy Nuclear Generation Limited (NGL) arrangements for managing conventional health and safety risks during the 2016 Hartlepool Power Station Reactor 2 maintenance outage. This is in line with the ONR conventional health and safety strategy for 2016/17.
The inspection involved involved examination of documentation, meetings with NGL personnel and physical plant inspections in order to evaluate the following aspects of outage health and safety management:
In addition, we met with the Station's safety representatives and contractor safety advisors to discuss our work and other health, safety and welfare matters.
The intervention was performed on the basis of a sample inspection in line with ONR's inspection guidance. ONR Inspectors judge adequacy against the following relevant good practice:
A summary of the findings for each of the topics covered are described below.
NGL have established procedures in place for contractor control including that for tendering, appointment, information exchange, control while on site, audit and communication.
Communication is maintained between the licensee and its contractors through various means, including safety contractor meetings. Contractor's activities are subject to a system of field supervision with the licensee formally appointing personnel undertaking these duties following a competency assessment which was judged to an effective and robust process. The Station have developed a programme to provide on going assessment of field supervisor effectiveness during the course of the outage.
A minor issue was identified during the inspection involving hot work which was addressed to our satisfaction during the period of the inspection. We provided advice to NGL in relation to its Outage Induction Training which NGL agreed to consider during the Outage's Learning from Experience Review.
We reviewed NGL's processes for the managing risks arising from working in confined spaces and judged that they are broadly consistent with relevant good practice. We held discussions with a sample of personnel involved in confined spaces working during our visit. All were able to articulate clearly site procedures and the controls in place were generally to the expected levels. The arrangements for atmospheric testing and the provision and maintenance of equipment used for this were sampled. We concluded that these too were of good standard.
During the intervention we noted that the Station had not fully implemented NGL's own arrangements regarding involvement of the Station's incident response team (IRT) leader in development plans for emergency recovery of personnel working in confined spaces and for communications with the IRT leader regarding certain types of confined space working. NGL committed to review these findings and implement reasonably practicable improvements.
The process for isolating plant before commencing work was discussed. Several NGL procedures and accompanying safety rules are in place that broadly aligns with HSE guidance, Safe Isolation of Plant and Equipment (HSG 253) and they appear robust in nature.
Selection and types of isolations were discussed, as well as the vital role that the Senior Authorised Persons (SAP) have in the process. Roles and responsibilities are clearly defined with robust competency and authorisation processes.
A site walk down was completed with a SAP who was able to clearly explain the isolation process. It was demonstrated that the site plan for reinstatement and not just isolation. All the SAP's spoken too had a clear understanding of the requirements and their role.
A major isolation was selected for sampling. The associated isolation documentation was examined as well as several isolations points being tested. All were completed to a good standard with no issues identified. Several other types of isolations were sampled i.e. positive, proven, all were too a good standard.
Based on the intervention undertaken against the requirements of the applicable legislation and guidance it is considered that the licensee had adequate arrangements in place. There are no findings from this inspection that could significantly undermine safety or would prevent restarting of plant.
I have raised an ONR Issue to manage our findings in relation to development of emergency recovery plans development plans and communications with the IRT leader prior to certain types of confined space working.
Health and Safety Committee. The site inspector will monitor progress during normal business.
A feedback session was held and attended by the TSSM, site industrial safety engineers, the internal regulator and the NGL corporate safety advisor.
It was stated that overall the intervention was positive with a number of areas of good practice highlighted. The issues identified during the walk down were rectified swiftly and to a satisfactory level. All advice offered was accepted by site with no issues.
There are no findings from this inspection that could significantly undermine safety or would prevent restarting of plant. I have raised an ONR Issue to manage our findings in relation to development of emergency recovery plans development plans and communications with the IRT leader prior to certain types of confined space working.