- Site: Hinkley Point C
- IR number: 22-007
- Date: June 2022
- LC numbers: N/A
Purpose of Intervention
In accordance with the ONR strategy for the regulation of HPC from 2022 – 2027 and ONR guidance for inspection, strategy planning and resourcing (ONR-INSP-GD-059), ONR undertook a unannounced inspection to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo), is meeting its legal requirements in respect to the Health and Safety at Work etc Act 1974 and the Regulatory Reform (Fire Order) 2005. Information gained from this visit will be used to inform future interventions.
Interventions Carried Out by ONR
The intervention was led by ONR Nuclear Internal Hazards and Site Safety (NIHSS) who were accompanied by two Health and Safety Executive inspectors, warranted to act on ONR’s behalf. An ONR Life Fire Safety inspector was also present. The inspectors split into two teams and undertook inspections at the turbine hall, conventional island and nuclear island. The intervention took place on 7 June 2022 and feedback was provided on 8 June 2022. As this was an unannounced inspection no intervention scope was provided. The intervention addressed matters of evident concern identified on site.
Regulatory advice and judgements were based on determining compliance with:
- The Regulatory Reform (Fire Safety) Order 2005; and
- The Health and Safety at Work etc Act 1974, Section 2 and 3, and relevant statutory provisions made under this Act, including:
- Management of Health and Safety at Work Regulations 1999 (MHSWR);
- Construction (Design and Management) Regulations 2015
Noise at Work Regulations 2005;
- Control of Vibration at Work Regulations 2005;
- Control of Substances Hazardous to Health 2002 (COSHH);
- Work at Height Regulations 2005; and
- Confined Spaces Regulations 1997.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A, this was not a safety systems inspection.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
Overall, good practices and understanding of health and safety risks were observed, which is particularly noteworthy given this was an unannounced inspection. However, some shortfalls were identified.
Information available in risk assessments and method statements for the use of tools causing hand arm vibration in the turbine hall was not clear. The assessment and management of noise within the turbine hall and the nuclear island is an issue that was raised with NNB GenCo as the principal contractor.
NNB GenCo needs to provide adequate oversight of its contractors to ensure that hand arm vibration and risks from noise at work are adequately addressed as required by the Control of Vibration at Work Regulations 2005 and the Control of Noise at Work Regulations 2005.
It was found that there were inadequate procedures for controlling hot works in the HGE gallery (the raw water supply and storage liaison gallery). These centred around inadequate control of hot works, including the absence of a task specific hot works permit and fire watch arrangements. Failing to have adequate procedures for the implementation and control of hot works was the most significant shortfall.
Several areas were found to be lacking in adequate provision of emergency lighting, fire points (fire alarm activation) and directional emergency exit signage. A lack of consideration of fire safety during the planning of some pipework installation has resulted in compromising an emergency escape staircase. Confirmation has been received that this was rectified within 24 hours.
Conclusion of Intervention
From the evidence that was sampled during the intervention we are satisfied that NNB GenCo is managing most health and safety risks in line with relevant legislation, and good practices were observed, notwithstanding the identified shortfalls.
However, some notable shortfalls were identified. The intervention has therefore been rated Amber, which particularly reflects the shortfalls identified regarding the permit to work arrangements in the HGE gallery. The resolution of this will be tracked by a regulatory issue.