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 2 (HYB) 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. Setting to work is a priority topic in the strategy. This was one of the key topics of focus during the intervention, along with examination of compliance with the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR), following an incident at site in December 2016.
The key regulatory activities undertaken during the three day inspection were based around:
Regulatory judgement was based on determining compliance Sections 2 & 3 of the Health & Safety at Work etc. Act 1974 and the relevant statutory provisions/Approved Code of Practice (ACOP) made under the Act, namely: Management of Health & Safety at Work Regulations 1999, Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) 2002, Control of Substance Hazardous to Health Regulations 2002 (COSHH) and Work at Height Regulations 2005.
The main issue of concern was the lack of DSEAR risk assessments for the dangerous substances on site. This is a legal requirement under Regulation 5 of DSEAR 2002. 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 site requesting the production of suitable and sufficient DSEAR risk assessments by 30th September 2018.
Also related to duties under DSEAR, it was clear that that the explosive atmosphere zoning audit, although only completed in February, was out of date. The layout, amounts and use of dangerous substances had changed in the dirty paint store and the hydrogen storage area. ONR advised these areas should be re-audited once the risk assessments had been completed. ONR also advised that ONR remained vigilant in monitoring their contractors in several areas; including the inappropriate use of fall arrest lanyards, key control on fork lift trucks and ensuring those using RPE are suitably clean shaven to align with the face-fit tests. ONR also asked NGL to investigate whether the eye-wash station in battery room 7 is suitable and sufficient and aligns with the COSHH requirements of the substances within the batteries.
ONR also looked at Setting to Work and the role of work specifiers. Although the system of planning jobs is complex, the work specifiers that ONR spoke to knew their roles well and ably negotiated the scenarios that ONR put to them. The pre-job briefs that ONR attended were of high quality. More generally, ONR was impressed with how the site collates the information from CRs and uses it to the data to inform health and safety plans and priorities. The TU Reps described a positive, no-blame safety culture. Also, it is clear that a lot a good work has been done to produce the roof register and it looks fit for purpose.
A number of areas of concern where improvements are required in addition to examples of good standards were seen during the visit. These were summarised during feedback provided at the conclusion of the visit, as were the visit outcomes/actions required by NGL. The Technical and Safety Manager was present at the feedback session and a number of safety personnel were present at all times of the inspection and all were clearly engaged in the inspection process.
Because Heysham 2 is not meeting the legal requirements with regards to producing DSEAR risk assessments as required by regulation 5 of Dangerous Substances and Explosive Atmosphere Regulations 2002, the DSEAR section of the inspection is rated as ‘Amber - Below Standard’. For the other element of the inspection that focused on Setting to Work, health and safety management standards in this area were good in general. Therefore, an inspection rating of ‘Green - Acceptable’ should be applied to this part of the intervention. These ratings and the reasons for them were shared with site staff at the feedback session. An enforcement letter will be sent to station regarding the areas identified as requiring action and/or clarification. Response will be requested 30/9/18.
A regulatory issue has been raised in the ONR Regulatory database, related to DSEAR risk assessments and is subject to ONR’s governance processes.