The purpose of this intervention was to provide regulatory confidence in the management of conventional health and safety (CHS) hazards present at EDF Energy Nuclear Generation Limited’s (NGL) Heysham 1 (HYA) power station during its outage. This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2018-19.
The ONR CHS strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Workplace Transport Risk is a priority topic in the strategy. This was one of the key topics of focus during the intervention, along with examination of Heysham 1’s compliance with the Danger Substances and Explosive Atmosphere Regulations 2002 (DSEAR), following the discovery of issues with compliance with these regulations on other NGL sites. ONR also sought an update on managing legionella risks from the cooling towers after issues were raised during a previous ONR CHS inspection.
The key regulatory activities undertaken during the three day inspection were:
The inspection findings identified a lack of DSEAR risk assessments for the dangerous substances on site. This is a legal requirement under Regulation 5 of DSEAR 2002. As stated above, without these initial assessments, it is difficult to gauge whether the controls in place to manage these risks are suitable and sufficient and whether the explosive atmospheres zoning audit is fit for purpose. ONR said it would write to the Heysham 1 and requested it to produce suitable and sufficient DSEAR risk assessments by 30th November 2018.
Also related to the licensee’s duties under DSEAR, was the number of outstanding ‘non-conformances’ (at risk equipment remaining in Explosive Atmosphere Zones) and the lack of a prioritised plan to deal with them. It is likely that there are multiple cases of non-compliance with Regulation 6 of DSEAR, but the scale of this non-compliance and the level risk is unclear, because of the complex system used to deal with these issues. ONR requested that NGL produces a gap analysis of exactly where Heysham 1 is in terms of overall compliance with Regulation 6 of DSEAR and provide this to ONR (also by 30th November), the next stage being a programme to address these issues.
ONR also looked at Workplace Transport and shared the issues found on the site walk down, including the key found in the cab of a parked and unoccupied telehandler and the scaffold laydown areas being sited next to roads. ONR also described the lifting operation with multiple signallers witnessed in the Cooling Water Pump House. ONR were satisfied with the actions that NGL took on these issues. The inspection findings for the licensee’s management of legionella risks identified that the risks were being well managed. ONR provided NGL advice on improving its written schemes of control by including a schematic diagram and assessments required under the Control of Substances Hazardous to Heath Regulations 2002, as well as a clearer description of the lines of communication and specific instructions on how to inspect and clean the cooling towers.
From ONR’s sampled inspection, several areas were identified where improvements are required, However, good standards were seen during the inspection in two focus areas.
The licensee’s shortfalls in meeting the duties under DSEAR to producing DSEAR risk assessments as required by regulation 5 and apply effective risk control measures as required by regulation 6 of Danger Substances and Explosive Atmosphere Regulations 2002 the DSEAR part of the inspection is rated as ‘Amber – Below Standard’.
For the other elements of the inspection that focused on Workplace Transport and Management of Legionella Risks, health and safety management standards in this area the licensee was considered to meet its legal duties. Therefore, an inspection rating of ‘Green – Acceptable’ should be applied to this part of the intervention.
An ONR regulatory issue has been added to the ONR Regulatory database, related to DSEAR risk assessments and ‘non-conformances’ and is subject to ONR’s governance processes.