Office for Nuclear Regulation

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Site Inspection to ensure compliance with the Regulatory Reform (Fire Safety) Order 2005

Executive summary

Purpose of Intervention

The purpose of the inspection was to ensure that the Licensee was achieving compliance with the requirements of the Regulatory Reform (Fire Safety) Order 2005. The inspection focused on both the management of fire safety and the practical fire safety provision within the Tails Management Facility (TMF) construction site. The legislation focuses on life safety not nuclear fire safety issues.

Interventions Carried Out by ONR

This Intervention forms part of a series of on-going inspections forming a key element of the assessment of fire safety across the TMF site. My inspection assessed the duty holders’ compliance with the requirements of the Regulatory Reform (Fire Safety) Order 2005. Of particular interest during this inspection was the outcome of the assessment of the locking mechanisms that had been fitted to the internal fire doors across the project buildings. I also had detailed discussions relating to the approach to the on-going provision of a SQEP fire safety resource within the project.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable

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

Since my last inspection construction and the introduction of plant and equipment has continued apace. The number of workers on the construction site has decreased significantly and the overall picture is one of a site that is in its final stages of construction. The process plant and equipment and supporting systems have commenced inactive commissioning. The emergency lighting system in the B building has been fully commissioned but remains under the control and management of the main contractor Jacobs.

A significant number of fire-rated doors across the project have previously been identified as having locking mechanisms which will require an assessment as to their suitability in relation to means of escape. This assessment has now been completed and an action plan is being developed to address the issues that have been identified.

Since December 2017the site has lost all of its dedicated fire safety resource. The last of the Fire Safety Coordinators departed the site for the last time on the day of my inspection. I have challenged the Principal Contractor and the Licensee to demonstrate how they intend to maintain the fire safety focus on what is still a busy and complex site.

Conclusion of Intervention

I am satisfied that at the time of my inspection the level of focus on fire safety was appropriate. I am expecting to be provided with the outcome of the discussions between the door lock manufacturers and site which will determine the outcome in relation to the means of escape strategy for all the buildings. I have reiterated the need to maintain the current standards as commissioning progresses. I will continue to complete on-going review inspections at regular intervals, particularly as the project moves towards and through its active commissioning phase.