- Site: Hinkley Point C
- IR number: 21-005
- Date: May 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office of Nuclear Regulation (ONR) Strategy, ONR undertakes a series of planned interventions at nuclear licensed sites. This intervention forms part of ONR’s 2020/21 Integrated Intervention Strategy for New Reactors.
The purpose of the intervention was to gain continued assurance of the effectiveness of safety management system arrangements at Hinkley Point C (HPC) for the elimination or control of safety and health related risks in the construction phase. Information gained from the visit will be used to inform future interventions.
Interventions Carried Out by ONR
The intervention was led by two Health and Safety Executive (HSE) Inspectors, accompanied by two ONR Nuclear Internal Hazards and Site Safety (NIHSS) Conventional Health and Safety Inspectors.
The intervention comprised of teams of two inspectors inspecting specific activities on areas of the site via site walk downs, accompanied by NNB Generation Company (HPC) Limited (NNB GenCo) and Tier 1 contractors.
The activities that were proposed to be inspected included welding, lifting operations, formwork erection and dismantling and above ground tunnelling activities. The inspection also provided an opportunity to explore the permit to work system and integrated safety management. Regulatory advice and judgement were based on determining compliance with the Health and Safety at Work etc Act 1974, Section 2 and 3 and the relevant statutory provisions made under the Act. This included the Construction (Design and Management) Regulations 2015, Work at Height Regulations 2005, Confined Space Regulations 1997, Control of Substances Hazardous to Health Regulations 2002, Management of Health and Safety at Work Regulations 1999 and the Provision and Use of Work Equipment Regulations 1998.
The intervention was rated in line with the ONR General Inspection Guidance (ONR-INSP-GD-064).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Due to adverse weather conditions all lifting operations on site were stopped and no inspection of lifting operations was carried out. As the inspection was undertaken on the day following a Bank Holiday, the number of workers on site was reduced, limiting opportunities to observe working practices. The inspection therefore did not cover all the proposed activities.
NNB GenCo demonstrated that they have a good understanding of the health and safety risks across the site and are applying appropriate control measures. Good safety standards were observed across the site.
There were some shortfalls identified during the inspection:
Conventional Island – it was observed that tube and fitting boards were present at height on the system scaffold. It was observed that a number of loose wooden scaffold boards had been used to board out areas. NNB GenCo were asked to check if their use was covered in the method statement as they were not part of the system scaffold and to check with the contractor whether they were supported at appropriate spacings. It was observed that the wooden boards were not clipped into position and as the site had experienced high winds (with no lifting being undertaken on the day of the visit), there was a risk of boards being blown off the scaffold.
Tunnelling Area – it was observed that there was a 400mm gap at the base of the conveyor storage magazine on W11, allowing whole body access. In addition, fixed guarding panels had not been securely fixed along the length of the conveyor allowing them to be lifted off.
Workshop (Tunnelling Area) – there was no maintenance system in place for the band saw metal working fluid. HSE has previously given advice regarding coolant fluids control in the main workshop.
HGE Gallery – No work was being undertaken in the gallery at the time of the visit but welding of supports onto plates fitted into the gallery walls had started. A general ventilation system was present in the HGE Gallery that forces air from the midway point of the gallery. Further information, including calculations, was requested about the current general ventilation system and whether improvements could be made to ensure effective ventilation is being provided to remove airborne fume taking into account the dog-leg in the gallery and how the constructed structures and screening would affect air-flow. An HSE Occupational Specialist Inspector has been asked to provide advice regarding the adequacy of the general ventilation system, local exhaust ventilation (LEV) and respiratory protective equipment (RPE), and this will be tracked by a Level 4 Regulatory Issue.
Whilst on site, HSE /ONR observed and followed the COVID-19 workplace control measures that NNB GenCo had put in place, including the testing regime, hand-sanitising stations at the entrance of workplace and buildings and social distancing. Whilst the overall arrangements on COVID-19 was not part of the agenda for this intervention, based on observations, the measures put in place were considered adequate.
Conclusion of Intervention
From the evidence that was sampled during the intervention ONR are satisfied that NNB GenCo are managing health and safety risks in line with relevant legislation.
The intervention has been rated Green (no formal action) with a level 4 issue to track that the control of welding fume in the HGE Gallery is suitable and sufficient.