- Site: Heysham 2
- IR number: 21-029
- Date: June 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This was a planned intervention to provide regulatory confidence in the management of conventional health and safety (CHS) hazards associated with two high risk areas, namely work at height and lifting operations, and their potential impact on nuclear safety, at EDF Energy Nuclear Generation Limited’s (NGL’s) Heysham 2 (HYB) power station during its R7 outage period.
This is in line with the current CHS intervention priorities and reflects the ONR intervention programme contained in ONR’s divisional work plan for Operating Reactors in 21/22.
Interventions Carried Out by ONR
This intervention was carried out by three ONR Nuclear Internal Hazards and Site Safety specialist inspectors on 11 June. An agenda for the intervention was prepared and shared with NGL in advance.
During the site visit, ONR inspectors strictly adhered with control measures outlined within ONR-GEN-GD-022 (visit to licensee and other duty-holder premises and other relevant locations during the COVID-19 pandemic) and the local COVID-19secure control measures at HYB.
The intervention comprised of:
- discussions with NGL HYB staff, contractors, and a Trade Union safety representative;
- site walk-down accompanied by NGL HYB staff;
- sampling of documents and records; and
- further email correspondence after the site visit with NGL HYB seeking clarification on documents and records.
Regulatory advise and judgement were based on determining compliance with Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and the relevant statutory provisions made under the Act including Work at Height Regulations 2005, Management of Health and Safety at Work Regulations 1999, Lifting Operations and Lifting Equipment Regulations 1998. Relevant good practice such as the Approved Code of Practice L113 Safe Use of Lifting Equipment, and British Standards (BS EN 13586:2020 and BS 7121-1:2016) were consulted on crane access and safe use of cranes.
The intervention was conducted in line with the ONR General Intervention Guidance (ONR-INSP-GD-064), which can be found at /media/documents/guidance/onr-insp-gd-064.pdf.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Whilst on site, ONR inspectors observed and followed the COVID-19 workplace control measures that NGL had put in place including testing arrangements before attending site, use of facemasks, hand-sanitising and cleaning regimes in buildings, social distancing. The arrangements put in place at HYB were considered to be adequate.
The inspectors identified the following areas of good practice including:
- the rope access work observed was well planned, especially the application of the work at height hierarchy of control before commencing work. The workers demonstrated sufficient level of competence in managing the hazards and risks associated with the work;
- the routine lift work observed was adequately planned, managed and monitored. The workers demonstrated sufficient level of competence in managing the hazards and risks associated with the work; and
- the use of ‘Load Angels’ as a safe working platform for loading and offloading from heavy goods vehicles demonstrated adequate controls have been put in place to mitigate work at height risks.
One area of improvement was identified in respect to the work at height arrangements for the crane driver access to the 65-tonne overhead crane in the Turbine Hall. Therefore, an intervention rating of Amber (seek improvement) was allocated for work at height arrangements. NGL has acted promptly to put in sufficient temporary measures to mitigate the risk and started to develop an engineering solution as the permeant measure.
Based on the samples observed and examined, ONR inspectors was satisfied that NGL demonstrated adequate management of hazards and risks associated with lifting operations against relevant good practice. As a result, an intervention rating of Green (no formal action) was allocated for this part of the intervention.
Conclusion of Intervention
Whilst NGL’s arrangements in managing lifting operations have met ONR’s regulatory expectations, the work at height arrangements required improvement in respect of crane driver access arrangements. A Level 4 Regulatory Issue has been raised to track NGL’s progress in addressing the shortfall. ONR will continue to monitor NGL’s progress in addressing the shortfall identified in this intervention as part of regular follow-up meetings.