Office for Nuclear Regulation

Management and compliance with confined spaces regulations

Executive summary

Purpose of Intervention

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) Hinkley Point B (HPB) power station during its outage. This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2018-19.

Previous interventions had identified a need to examine arrangements in place for the management of the risks posed by confined space work, encompassing categorisation of confined spaces and the control of contractors conducting confined space work in line with the Confined Spaces Regulations 1997

Interventions Carried Out by ONR

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

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

Confined Spaces – NGL have a procedure in place as detailed in BEG/SPEC/SHE/COP/039. HPB has assessed all the confined spaces on their site and categorised them from 1a to 3. They are then managed appropriately by the confined spaces team. Having reviewed a number of the confined spaces we found a significant representative number to be too high a category and some not meeting the definition for confined space at all. HPB are aware of this and are working to re-categorise the confined spaces appropriately. Changes to methods of work are not being recorded. If work orders are not being adhered to for a specific reason the changes should be recorded and if this is a permanent change the work order should be amended on the system.

Machinery Guarding – There are a number of pumps and other machinery around the site which are not adequately guarded or do not meet current legislation. HPB have identified these, the majority are tagged and they have temporary guards on. The guarding requires upgrading from the temporary and easily removable type to a more robust secure guard which meets legislation.

HESAC Meeting – The ONR inspector took time to attend the HESAC meeting the group comprising of station management, industrial safety staff, union safety reps and contract partners, chaired by the station TSSM. The meeting started with a slide show of recent issues and problems that had been resolved since the last HESAC meeting, with the person who took responsibility for the issue describing hoe the actions were closed out. There was then a section on emerging issues during the outage and then a review of the OpEx alerts issued from around the ONR Fleet.

Workplace Transport – The contractor village during the outage was busy with both vehicles and pedestrians. Work had been undertaken to improve segregation. Outside the GE compound was a container that obscured visibility, resulting in any exiting pedestrians or vehicles, stepping into the road without being able to see oncoming traffic. HPB agreed to move container, ASAP.

Lifting Operations – The turbine rotor was undergoing replacement and required lifting. This was being undertaken by a single overhead travelling crane. The crane was operating outside of its safe working load to perform this lift. Calculations to ensure safety had been done. The lift took place without incident. Copies of the calculations and justification are to be forwarded to the ONR CHS team.

Conclusion of Intervention

A small 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 Quality Management Group Head, Industrial Safety Engineer and the Technical and Safety Support Manager (Acting Station Director) were present at the feedback session.

Despite the minor issues raised, the overall impression gained from the inspection was a satisfactory one. NGL Hinkley Point B industrial safety personnel have clearly put a significant amount of effort into managing CHS hazards present as a result of the various outage activities underway. Work is still required to raise guarding standards to meet current legislation; increased planning and vigilance when siting containers in contractor village; recording of changes to methods of work and changes of work orders in the system; review of current confined space categorisation.

These shortcomings aside, health and safety management standards were good in general. Therefore, an inspection rating of ‘green – acceptable’ should be applied to all parts of the intervention.