- Site: Hinkley Point C
- IR number: 21-016
- Date: August 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This intervention is part of an on-going series of engagements with the Hinkley Point C construction site (HPC) and forms part of ONR’s 2020/21 Integrated Intervention Strategy for New Reactors
This intervention was carried out by two ONR inspectors with specialist knowledge relating to Fire Safety (Life) and Conventional Health and Safety.
The primary purpose of the engagement was to assess compliance with the Regulatory Reform (Fire Safety) Order 2005 (RRO) and to review arrangements across the site in relation to permit to work arrangements, specifically hot work permits. Progress against previous inspection findings in relation to the management and application of fire safety was also considered. This intervention had a specific focus on the provision of Fire Risk Assessments by a Tier 1 contractor (Bylor). This information is used to assess the need for future interventions based on the continued build progress across the site.
Regulatory advice and judgement were based on determining compliance with the RRO, the Health and Safety at Work etc Act 1974, Section 2 and 3 and the relevant statutory provisions made under the Act including the Construction (Design and Management) Regulations 2015 and the Management of Health and Safety at Work Regulations 1999. Standards were also judged against the Health and Safety Executive guidance document Fire in Construction (HSG168).
Aspects relating to emergency arrangements as would be expected to satisfy Licence Condition 11 were also considered and addressed as part of this intervention. This primarily relates to the arrangements of both NNB Generation Company (HPC) Ltd and Tier 1 contractors to undertake rescue and emergency response on the construction site during the life span of the project. The intervention does not consider emergencies of a radiological nature.
Interventions carried out by ONR
The intervention focused on the management of fire safety, the practical fire safety provision and permit to work arrangements across the nuclear island for unit 1.
- ONR was provided with a series of documents prior to arrival on site. These were not reviewed in advance of the intervention due to their late receipt.
- Relevant legislation was used to focus on life fire safety, not nuclear fire safety issues.
- ONR undertook a limited walk-through of some of the areas of the nuclear island and paid particular attention to the practical application of the hot work permitting process and the fire risk assessments.
- During the inspection, ONR challenged site personnel about procedures and approaches to the practical application of maintaining adequate fire safety provision and the permit to work arrangements.
- ONR conducted meetings to assess the approach taken to the management of fire safety and in particular the provision of Fire Risk Assessments.
- ONR questioned personnel to test effectiveness and knowledge of arrangements and their implementation.
- The intervention was rated in line with the ONR General Inspection Guidance (ONR-INSP-GD-064).
Explanation of Judgement if Safety System Not judged to be Adequate
Not Applicable
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the walkdown of the nuclear island, and a series of meetings with those responsible for the construction activities (Bylor Tier 1 contractor), ONR identified a specific issue relating to the adequacy of Fire Risk Assessments. Bylor was unable to clearly identify where suitable and sufficient Fire Risk Assessments were recorded, along with the identified general fire precautions for a number of areas sampled throughout the day.
A hot work permit activity was sampled and shortfalls were identified in the permit to work arrangements and their implementation. In particular, the permit was not task specific and covered a number of activities over an extended period.
Conclusion of Intervention
Based on the shortfalls identified during the inspection and their safety significance an Amber rating (seek improvement) was assigned to this intervention. Level 3 regulatory issues have been raised to monitor resolution of the shortfalls.