Office for Nuclear Regulation

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Planned Conventional Health and Safety Inspection during statutory outage

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake an inspection at EDF Energy Nuclear Generation Limited (NGL) Hinkley Point B (HPB), Power Station to provide regulatory confidence in the management of conventional health and safety (CHS) hazards present during the licensee’s periodic shutdown for setting to work.

The intervention was undertaken in accordance with ONR’s CHST Operational Delivery Plan 2018/19 for the Operating Facilities Division.

The findings from this intervention will be followed up in a CHS EDF corporate intervention planned for this work year and informed by the findings in quarter one and two.

Interventions Carried Out by ONR

The key regulatory activities undertaken during the visit were based upon an agenda previously agreed with HPB.   Site visits were undertaken to ascertain the arrangements in place for setting to work.  Information was sought from staff and contractors and appointed Health and Safety representatives.

HPB documentation was seen in advance of and during the intervention.

The key regulatory activities undertaken during the two day inspection were based around:

Key performance indicators used to assess the adequacy of organisational and physical control measures were based on the requirements of Section 2 and 3 of the Health and Safety at Work etc Act 1974 and relevant statutory provisions made under the Act including, The Management of Health and Safety at Work Regulations 1999 which sets out the framework for health and safety arrangements that are appropriate to the nature of the activities and size of the undertaking, The Control of Asbestos Regulations 2012: Approved Code of Practice and Guidance (L143) and the Confined Spaces Regulations 1997: Approved Code of Practice and Guidance (L101).

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Setting to Work - EDF have established procedures in place for work planning and setting to work.  Evidence was seen that the procedures were followed in the work that was sampled.  Work supervisors were able to produce the work packs and key tasks had been identified.

Work specifiers have a key role in the planning process, including the correct identification of the risks involved in the work.  The work specifier role can be undertaken by EDF employees as well as contractor supervisors on the site. HPB had recognised that they had too many work specifiers and underwent a recalibration of the system approximately 5 years ago, reducing the numbers of specifiers on site. Work specifiers receive training and mentoring for the role.   

EDF has identified certain work activities such work at height and confined space work as being “significant risks” in the work planning / risk assessment process and advice is sought from specialists (if required) to produce a significant risk permit.  This requires the work specifiers to identify the significant risks.  HPB were able to demonstrate a robust system to ensure that work specifiers were trained and peer reviewed.  However, the setting to work system was considered complex and advice was given to review and simplify where possible. 

When being set to work, workers are instructed to use Time Out for Personal Safety (TOPS) to check for any new or un-mitigated significant hazards.  There was a variation in the use of the TOPS procedure by different contractors with some contractors using their own similar procedures whereas other contractors did use the EDF TOPS system.  EDF should ensure that systems used by other contractors are consistent with their own.

The arrangements for setting to work and work specifier competence will be followed up in a Conventional Health and Safety EDF corporate engagement, planned later for the year and informed by the findings from ONR interventions in quarter 1 and 2 of the work year.

Confined Spaces - A Rapid Trending Review (RTR) was undertaken at HPB on 3-6th April 2018 by the INA (Independent Nuclear Assurance), this identified shortfalls in the control of hot work and confined space activities.  Following the RTR, HPB immediately stopped all confined space work and reviewed their systems. Of the confined space work sampled during the inspection appropriate control measures were in place.  HPB have specified areas as confined spaces irrespective of the work being carried out in the space.  HPB are aware that they have an overly conservative approach to identifying confined spaces and are proposing to review this approach.   It was advised that in treating areas that were not confined spaces as defined in the Confined Spaces Regulations 1997 and associated ACoP this could undermine the permit system which should be used for high hazards and unusual jobs.  There could also be a potential for moving away from sustainable compliance due to number of permits issued and this is demonstrated by the findings of the RTR.

Workplace Transport - Some areas were observed on site where there was poor segregation between vehicles and pedestrians, particularly by building 522, CW Pump House. However, good practices were noted on site, particularly that workers used the clearly marked pedestrian walkways where provided.  HPB were advised to review their transport management plan and identify areas where segregation could be improved. 

Conclusion of Intervention

A number of examples of good practices were seen during the visit. In particular, safety is given priority at the morning outage briefing with relevant safety messages. In addition, an integrated safety team meeting consisting of EDF and contractor safety professionals and occupational health meet daily to identify key safety issues and share relevant information.  The station manager showed visible leadership by speaking at the outage meeting and attending the feedback session.  The HPB industrial safety personnel are clearly committed to the management of the CHS risks on site demonstrated by their pre-outage safety training of supervisors and their general approach and commitment to safety on site.    

HPB have reviewed their setting to work procedures.  This has resulted in a reduction in the number of work specifiers on site. They are also improving the process and a good example was the introduction of photographs in the work-pack so that operatives are clear on what piece of equipment they should be working on.  Operatives spoken to where aware of the process and their roles and responsibilities and work-packs were completed as required. It was commented on that the work specification process stops and the setting to work process is undertaken by the work supervisor and that information may not be fed back to the work specifier. ONR identified this as a potential weakness in the system. The complexity of the present risk assessment process has been recognised at a corporate level and EDF have commissioned the Health and Safety Laboratory (HSL) to review the risk assessment process.

In light of the observations made regarding confined spaces a single ONR issue has been raised to manage oversight of EDF’s review of their arrangements for confined space working.  This dovetails with ONR’s observations following an inspection at EDF Hartlepool.

Based on the evidence obtained as part of the work detailed in paragraph 1.2, an inspection rating of “green”; relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks is appropriate for EDF’s arrangements for setting to work and confined space working.   

There are no findings from this inspection that would prevent restarting of the plant.