Executive summary
Date(s) of inspection:
- November 2023
Aim of inspection
This was a targeted inspection of the adequacy of the fire safety and emergency arrangements at Hinkley Point C (HPC) with the aim of assessing compliance with the Regulatory Reform (Fire Safety) Order 2005 (RRO) during construction activities.
The aim of this inspection was to gain confidence in NNB Generation Company (HPC) Ltd's (NNB GenCo) and its Tier 1 contractors' life fire safety and emergency arrangements during the construction phase of the HPC project. The intention of this inspection, amongst other things, was to focus on the implementation of the fire safety arrangements on a wide ranging type of facilities at different stages of construction, relating to more than one Tier 1 and Tier 2 contractor.
In addition to a wide variety of meetings with various dutyholders the inspection involved a significant walkdown of a variety of areas of the project. These areas included the following buildings: multiple levels of the unit 1 reactor building (HR), the fuel building (HK), conventional island electrical building (HF), raw water supply and storage building (HOR), HOR liaison gallery (HGE), and divisions 1 and 4 of the safeguard buildings (HL).
A significant aspect of this inspection was aimed at assessing the application of suitable co-operation and co-ordination arrangements between various dutyholders working in close proximity to each other. It also focused on assessing the progress of improvements expected in relation to on-going regulatory issues as a result of the findings of previous inspections.
Subject(s) of inspection
- Construction Fire Safety - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
Based on observations and discussions, particularly across areas of the project which can be considered substantially built, there has not been sufficient improvement in the management of fire safety and the application of the general fire precautions across the project in general since the previous inspection. I found inadequate co-operation or co-ordination between relevant dutyholders such that an understanding of the risk profile is sufficiently understood. This includes the Principal Contractor and some Tier 1 contractors.
During this inspection I identified a number of shortfalls relating to the lack of a suitable and sufficient fire risk assessment having been carried out in areas where more than one dutyholder was carrying out high risk work activities. This resulted in failing to control and manage combustible materials and pressurised cylinders, the control of ignition sources, challenging means of escape conditions, a lack of planning to consider the impact on fire safety arrangements as a result of construction activities and the failure of supervisors to demonstrate their understanding of the fire related risks that exist on the project. The areas visited during this inspection were not the same as previous inspections which suggests that the challenges to managing fire safety are not relevant to only one dutyholder.
I articulated to senior Principal Contractor managers, along with senior contractor personnel, my concerns that the increase in the number of areas which should be classified as areas of multiple occupancy are lacking adequate controls and management of fire safety, primarily due to a lack of co-operation and co-ordination between relevant parties.
Conclusion
Given a number of shortfalls which were identified during the inspection were of a repeat nature from previous inspections, the inspection has been rated as amber and Enforcement Notices have been served against NNB GenCo, Bylor JV (Bouygues and Laing O'Rourke) and REEL UK.