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Hartlepool Outage inspection on industrial safety

  • Site: Hartlepool
  • IR number: 21-110
  • Date: October 2021
  • LC numbers: 30

Executive summary

Purpose of Intervention

This was a planned inspection at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station, undertaken as part of the intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).

The inspection was conducted in support of ONR’s decision to give Consent to restart Hartlepool Reactor 1 following its 2021 periodic shutdown. The inspection aimed to provide ONR with regulatory confidence in the management of industrial safety hazards present during the Hartlepool R1 shutdown period, including planning of outage activities that involved work at height and control of welding fumes. ONR also sought evidence on progress made to address findings from the previous outage inspection on industrial safety and fleet-wide issues.

Interventions Carried Out by ONR

The inspection was conducted by a team of ONR inspectors on site over two days during the Hartlepool Reactor 1 periodic shutdown. An inspection brief (CM9 reference 2021/81383) was prepared and shared with the station prior to the inspection.

The inspection involved discussions with NGL staff, contractors working on site and Trade Union Safety Representatives. The inspector team conducted site walk-downs accompanied by relevant station personnel and sampled associated records, followed by further remote correspondence upon reviewing additional documents provided by the station after the site visit.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Regulatory advice 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
  • Control of Substances Hazardous to Health Regulations 2002 (COSHH)
  • Management of Health and Safety at Work Regulations 1999
  • Provision and Use of Work Equipment Regulations 1998 (PUWER)
  • Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)

The inspectors also consulted the following relevant good practices, including:

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

The inspectors considered NGL made sufficient improvements since the last inspection on work at height. The ONR inspectors observed three examples of work at height activities carried out by contractors and were content that work at height activities were adequately managed during outage.

The inspectors were unable to observe any welding activities during this inspection because none were taking place at the time. Upon reviewing the arrangements and sampling associated records of the main contractor who carries out welding during the outage, as well as holding discussions with relevant personnel including welders, the inspectors were content that hazards and risks associated with welding fumes were adequately managed. The inspectors considered there was a good level of general awareness on welding fumes and controls, although some minor shortfalls around use of appropriate respiratory protective equipment were identified.   

The inspectors also sought evidence of progress made by NGL on a few issues raised in the previous outage inspection and fleet-wide industrial safety issues. Some issues identified in the previous inspection remained work in progress although the inspectors noted that NGL were in process of addressing them.

Two ONR Level 4 Regulatory Issues were raised on the two areas of shortfalls identified, one was the selection and use of respiratory protective equipment by a NGL contractor partner and another was the provision of adequate workplace lighting by NGL, which was observed to be dim in areas during the plant walkdown. An existing ONR Level 4 Regulatory Issue on machinery guarding remains open and has been updated to include the observation made during this inspection that good progress had been made, but some guards remained to be fitted. ONR planned to follow up these Regulatory Issues as part of routine engagements with NGL and relevant contractor partners respectively. The inspectors also provided regulatory advice on a few topics.

ONR discussed these findings with NGL as the inspection had progressed and at the closing meeting of the inspection. They were acknowledged and accepted by NGL and relevant contractor partners.

Conclusion of Intervention

Based on the samples observed and examined, ONR inspectors were satisfied that NGL had demonstrated adequate management of hazards and risks associated with work at height and welding fumes (COSHH) against relevant good practice. As a result, an inspection rating of Green (no formal action) was allocated for each of those topics. 

The inspectors judged that there were no findings from this inspection that would prevent the restarting of plant and would support ONR’s decision to give Consent to restart Hartlepool Reactor 1 following its 2021 periodic shutdown.