Executive summary
Date(s) of inspection:
- February 2025
Aim of inspection
This will be 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 inspection will assess progress against previously identified challenges to the management and application of the fire safety arrangements across a wide area of different locations and occupancy.
The intention will be to gain confidence in NNB Generation Company (HPC) Ltd (NNB GenCo) and its Tier 1 contractors' life fire safety and emergency procedures during the construction phase of the HPC project. The focus of this inspection will be 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. The inspection will also be aimed at assessing the improvements made against recent enforcement action and the continued implementation to comply with the RRO.
The inspection will include meetings with specific duty holders and a significant walkdown of a variety of high risk areas of the project. Some of these areas will be determined at the time of the intervention but as a minimum will include the Turbine Hall area (HM), Heat Sink and F4.1 (Balfour Beatty Area). A randomly chosen number of other buildings / Galleries are also likely to be chosen as areas of interest.
Subject(s) of inspection
- Construction Fire Safety - Rating: GREEN
- Control of Work (PTW) - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This three day inspection (4 to 6 February 2025) was carried out at Hinkley Point C (HPC) nuclear licensed site. The purpose of this inspection was to assess a selection of different areas of the construction project to assess compliance against the Regulatory Reform (Fire Safety) Order 2005, including the simultaneous consideration of the emergency arrangements.
This fire safety inspection involved an inspection and walk down of several work areas across the HPC construction project. These included HR1, HM1, F4.1 and a selection of Galleries. I also conducted a series of meetings with personnel from the Principal Contractor and other Tier 1 contractors across the timeframe of this inspection. My time on site involved engagements with the Principal Contractor, Bylor, the MEHA, Balfour Beatty, Framatome, Arabelle Solutions and William Hare.
This inspection continued to demonstrate the on-going and increasing complexity of the construction environment as the build continues. Evidence of on-going commissioning activities, and the introduction of plant and equipment in some buildings, continues to increase the overall risk profile of both the site as a whole as well as individual buildings / platforms. This continues to add to the challenges in maintaining a fire safe environment. In particular, those areas where multiple contractors are working in and around each other in the same building / platform continue to offer challenges relating to the ownership, responsibilities and accountabilities for the fire safety arrangements in these areas. I am encouraged by the on-going review of the Work Authorisation and Setting to Work process. I consider that this is an opportunity to provide a greater degree of the understanding and subsequent control that these arrangements are expected to offer to those issuing the authorisation, as well as those requesting and implementing them.
I identified challenges within the HM1 building relating to the travel distances involved in escaping from the roof in the event of a fire. The distances involved are excessive but following discussions with the Head of Construction for CI/BOP I am satisfied that there is an optioneering exercise being carried out to address the issue. This will be followed up post inspection.
Several positive initiatives are currently being considered by the Principal Contractor which I consider to be good practice within the nuclear industry fire safety environment. The potential to produce a construction project version of HSG 168 and separately, to develop a Fire Safety Apprenticeship are both initiatives to be encouraged.
Conclusion
This intervention sampled broad areas of fire safety and emergency arrangements challenges that exist within the overall project. Meetings were held with various persons, the PC, Tier 1 Contractors, Emergency Preparedness Specialists, Fire Safety Specialists and the Internal Regulator. Many of the outcomes relating to these subject areas were of a positive nature and discussions, particularly around the future risk profile and the need to continually understand the resource implications, offered a clear direction of travel which is being driven by the Head of Site Environment and Business Resilience.
I identified clear evidence of improvements in the overall management and application of the fire safety arrangements. I consider that some contractors are at differing stages of maturity with regard to their fire safety arrangements and resource levels, which will require a continued and developing focus. Previous interventions (2024) have identified significant regulatory concerns relating to co-operation and co-ordination between contractors which has been directly related to the work authorisation arrangements. I believe that the outcome of the site wide review of these arrangements will be of significant importance to the continued progress beginning to be seen.
Each of the Principal Contractor (RI-11853) and Bylor (RI-11855) have Regulatory Issues appertaining to required improvements on their cooperation and coordination arrangements and the ability of the PC to assure adequate oversight of these arrangements. I will review these issues following this inspection. The MEH Alliance also has a Regulatory Issue ( RI-12324) which relates to the conditions on the roof of HF1 as found in October 2024. Progress has also been made against this issue and due consideration to its potential for closure will also be given. The RAG rating for each of the issues is currently green and good progress has been made in the implementation of the required improvements.