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) Hunterston B (HNB) power station during 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 inspections. Work at height is a priority topic in the strategy. This topic, along with management of risks arising from dangerous substances and explosive atmospheres, were the key topics of focus during this intervention.
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 Practices (ACOP) made under the Act, namely: Management of Health & Safety at Work Regulations 1999, Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR) and the Work at Height Regulations 2005.
Work at Height – NGL have had several Work at Height issues over the past year, hence the focus of the Conventional Health and Safety inspection. There were discussions between ONR and Industrial Safety Staff on how these issues have been investigated and learned from, and how NGL should be proactive in dealing with these issues. Whilst NGL have not had time to respond to the Enforcement Letter that ONR sent concerning the breaches of health and safety legislation related to a Falling Louvres Incident, there is some evidence (the proactive inspection of contractor glazing works using temporary suspended access equipment) that monitoring can ensure that correct controls are in place. The site walk downs revealed some good practice and innovative controls, however the walk down of the R3 gas circulators revealed several minor work at height issues, all involving contractors. NGL need to maintain a robust monitoring regime during the outage period to ensure that workers, and especially contract partners, are employing the correct work at height risk control measures.
Dangerous Substances and Explosive Atmospheres - The introduction of a new NGL DSEAR Risk Assessment template has almost been completed. At HNB non-compliances (non-rated electrical equipment within Explosive Atmosphere zones) have been all been assessed and the programme of removal is ongoing. The DSEAR Coordinator assured the ONR Inspector that whenever a non-compliance item can be reached by maintenance engineers (for example in an outage) it is removed. Although the lack of a DSEAR risk assessment means that they are behind in compliance (like the rest of the fleet), HNB are on course to achieve to what the law requires.
Management of Contractors – As well as the Work at Height issues seen at the Circulator Hall, there were several issues found where contractors were breaching health and safety rules, with the most concerning being grinding work within a Doosan hot works enclosure where sparks were coming over the top and the Workplace Solutions fire-watchers taking no action. The hot work was stood down and staff re-briefed, but the controls in this case were ineffective. Again, NGL should step up the monitoring of the contactors during the outage to ensure controls are being employed and they are robust enough to deal with the risks.
Workplace Transport - The road behind the Turbine Hall has some blind bends and no segregation for pedestrians – there are mirrors, but these are inadequate. NGL should review their Workplace Transport Risk Assessment for this area and install appropriate controls.
Many of examples of good standards were seen during the visit in addition to a number of areas where issues were found or improvements required. These were summarised during feedback provided at the conclusion of the visit, as were the visit outcomes/actions required by NGL. The Station Director and the Technical and Safety Support Manager were 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.
Despite the issues raised, the overall impression gained from the inspection was generally a satisfactory one. NGL Hunterston 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. However, as previously stated, a number of issues were identified during the inspection, such that controls not always being achieved and compliance with legislative requirements is not currently being met. Issues identified included poor hot work safety controls, minor work at height violations, monitoring the performance of contractors to maintain health and safety standards and some workplace transport risks.
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.
Two Issues will be added to the ONR Regulatory database, one related to the health and safety monitoring of contractors and the other on improving workplace transport controls on the road behind the turbine hall. These will be subject to ONR’s governance processes. An email will be sent to Industrial Safety Engineers at HNB confirming the actions required and deadlines will be agreed for these actions.