Executive summary
Date(s) of inspection:
May 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. Confirmation that a reasonable and proportionate approach is being taken to the management and application of fire safety by the Principal Contractor and Tier 1 Contractors.
Subject(s) of inspection
- CDM 15 - Rating: Green
- Construction Fire Safety - Rating: Green
- Fire (Life Safety) Compliance Inspection - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This two day inspection (13 to 14 May 2025) was carried out at Hinkley Point C (HPC) nuclear licensed site. Meetings were held on the day before the formal intervention and the day following the intervention. These meeting outcomes are being recorded separately on a Contact Record (ONR-NR-CR-25-106). The purpose of this inspection was to assess a selection of different areas of the construction project to determine compliance against the Regulatory Reform (Fire Safety) Order 2005. The intervention included the simultaneous consideration of the emergency arrangements within the areas of my inspection.
This fire safety inspection involved an inspection and walk down of several work areas across the HPC construction project. These included Heat Sink, HR2, HM1, HW and Bunker LB6. 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, and, Arabelle Solutions.
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, the on-going management and awareness of the temporary fire safety systems remains a challenging aspect of the fire safety strategy. The need to consider the pace of construction and the changes to the layout and risk profile requires constant consideration by those responsible for the work areas / platforms. Those areas where multiple contractors are working in the same building / platform continue to offer challenges relating to the ownership, responsibilities and accountabilities for the fire safety arrangements. The on-going review of the Work Authorisation and Setting to Work process is encouraging and is expected to offer a wide ranging and holistic approach to a continually challenging aspect of the work activities. I consider that these arrangements are expected to offer an opportunity for a greater degree of understanding and subsequent control to those issuing the authorisation, as well as those requesting and implementing them.
I consider the HR2 building to be an excellent example of how fire safety and emergency arrangements can be appropriately controlled and implemented. I believe that this area of the project displays a willingness and ability to learn from both its own and others experiences in relation to fire safety. I did however, identify challenges within the HW platform / building relating to the inadequate provision of emergency lighting, particularly on escape routes. The circumstances required the immediate introduction of additional emergency lighting in order to allow work to continue during the hours of darkness. Additionally, during the course of this inspection, I identified a considerable number of locations where poor or inadequate provision of the fire alarm call points exists. The pace at which the layout of buildings and platforms changes requires a concerted focus on the provision and positioning of these important fire safety systems. I am satisfied that the shortfalls that I identified were being addressed prior to the conclusion of my intervention and will follow them via the two Regulatory Issues I raised as part of business as usual, and as such no further action is necessary. I was comfortable in considering the overall rating for the intervention to be Green.
Improvements are required in relation to the storage and charging arrangements for Lithium Ion batteries, the assurance that all areas are adequately provided with Emergency Lighting, the adequate provision of fire alarm call points and an assurance that the fire alarm evacuation exercises are being carried out regularly and include all relevant shift patterns.
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. The meeting outcomes have been recorded on a separate Contact Record (ONR-NR-CR-25-106).
I believe that two important aspects of the fire risk profile were identified which have an impact across the entire project. Firstly the control and management of the storage and charging of Lithium Ion (Li) batteries. The project has already experienced a number of fire events due to the failure of Li batteries. With the current understanding that there are in the region of 20,000 Li battery units across the project the likelihood of future fire events is very real. The examples of storage and charging that I came across within buildings during the inspection pose a risk to life safety, property and asset protection. The principal contractor has a policy which expects these types of batteries to be stored and charged in positions outside of, and away from buildings. This is something I support and will be making the Li battery control and management a standing agenda item for my inspections.
Secondly I identified many locations across the site where the fire alarm call points for the temporary fire alarm system were either missing, or had been moved to locations not conducive to their safe operation. The ability for people to be able to easily raise the alarm in the event of a fire is an essential aspect of the overall construction phase fire strategy. I have asked for a review of the current location arrangements for the manual call points to be carried out. I am aware of, and supportive of, the Principal Contractors intention to take control of the fire alarm system. I have met with the recently appointed Principal Contractor's Fire System Engineer and am impressed with the work he has already carried out to improve the wireless fire alarm system across the site. I also support his intention to upgrade the system to the latest more technically advanced system. I accept that this is a process that will take time. In the meantime however I expect all the Tier 1 contractors responsible for areas / buildings / platforms to understand the importance of obtaining advice prior to moving any of the fire alarm call points.
Separately to the above, the failure to provide adequate Emergency Lighting on Level 5 of the HW building, which is an area working 24/7 is a basic failure to consider an important aspect of the General Fire Precautions. It took two attempts to put the situation right, which offers additional concern about the standards being applied in this area. I believe that the Blue and Black hats working within their areas of responsibility should be capable of identifying basic shortfalls of this type. Additionally, they have access to Fire Safety Advisors and Monitors who would be capable of assessing any shortfall and instigating improvements. Since "Project Re-Set" there has been a significant increase in the areas that are now working 24/7 with a day shift, back shift, and night shift. I would have expected a review of the respective Fire Risk Assessment (FRA) for any areas which had moved to a night time working pattern as it constitutes a significant change to the working environment. The Emergency Lighting provision would be one of the most obvious aspects of the FRA to consider.
I have raised a Level 4 Regulatory Issue (RI-12573) in relation to the training shortfall for supervisors as I believe that this is essential training for supervisors to provide them with the understanding required to assist them in managing fire safety on their work platforms. I have also raised a regulatory Issue (RI-12572) in relation to the shortfalls relating to the General Fire Precautions in Bylor areas. Both of these issues will be overseen via business as usual.