- Site: Sizewell B
- IR number: 19-032
- Date: June 2019
- LC numbers: N/A
Executive summary
Purpose of Intervention
The purpose of this inspection was to provide regulatory confidence in the management of Conventional Health and Safety (CHS) hazards present during the Sizewell B (SZB) statutory/refuelling outage, including monitoring of work at height activities and management of risks associated with the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR). This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2019-20.
ONR has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Work at height risk is a priority topic in the strategy. This was one of the key topics of focus during the intervention, along with examination of Sizewell B’s compliance with DSEAR, following the discovery of issues with compliance with these regulations on other NGL sites.
Interventions Carried Out by ONR
As a specialist inspector in conventional safety, accompanied by a colleague of the same specialism, I undertook a three day inspection. This included discussions with key staff, including management and safety representatives, observations of work at height, and examinations of arrangements for compliance with DSEAR, following issues found at other NGL sites. A further purpose was site familiarisation for Conventional Health & Safety Inspectors new to SZB.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Work at Height
Overall it was a positive exercise and much of the work at height examined was well controlled. I looked in detail at examples of rope access work and scaffolding work. I also observed whether workers were abiding by rules with regards to dropped objects and found no discrepancies. However there was some Work at Height issues:
- We looked at the work being done to lift trench covers and the risks of falls into the open trenches. There is an over-reliance on the use of harnesses for this work, often when they have no viable anchor point to clip onto. Harnesses are at the bottom of the hierarchy of controls and alternatives were discussed using collective means of protection. I have requested that the Industrial Safety Engineers (ISEs) revisit their planning and risk assessments/method statements for this work and get back to ONR with more suitable arrangements.
- While in the basement of the Reactor Building, we witnessed a confined space worker emerging from a sump pit and having to wait in a small space at the top of the open pit for a health physics assessment, with no controls preventing a fall back into the void. Again, at ONR’s request, the ISEs are going to look at this work to reassess planning on subsequent similar jobs.
Dangerous Substances and Explosive Atmospheres
I met with station DSEAR co-ordinators to discuss progress with the new NGL DSEAR risk assessment process that had been introduced fleet wide. They were able to show the new document to the Inspector and how they had arrived at their conclusions. They also explained the current status of the programme for removal of equipment that does not have the correct protection rating (and are therefore potential sources of ignition) from within zones designated to have the potential for an explosive atmosphere. They were able to give me a satisfactory breakdown of their priorities, what was being removed in this outage, what would remain and how this was to be monitored.
Trade Union Safety Representatives Meeting
TU representatives were positive about their engagement with management over safety, but they did share some issues. They felt that there was an overreliance on some work teams to almost rewrite risks assessments in their ‘Time Off for Personal Safety’ assessment (TOPS assessment). Related to this, we discussed whether jobs were walked down during the planning risk/assessment stage and Inspectors were told that this was not always the case. Finally, they told us that some workers do not have the confidence to challenge supervisors or managers when they perceive a safety issue. We shared these concerns with the Technical & Safety Support Manager.
Conclusion of Intervention
Many of examples of good standards were seen during the visit in addition to the areas for improvement. NGL Sizewell B industrial safety personnel have clearly put a significant amount of effort into managing CHS hazards present during the outage.
These conclusions were summarised during feedback I provided at the conclusion of the visit, and we agreed improvement actions for the station, particularly in relation to management of work at heights. A regulatory issue (7923) has been added to the ONR Regulatory database, related to the improved planning and risk assessment of the work at height. This will be subject to follow-up and ONR’s governance processes.
These issues aside, health and safety management standards were good in general. Therefore, an inspection rating of ‘Green – no formal action’ was applied to this intervention.