- Site: Hinkley Point C
- IR number: 21-030
- Date: December 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 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 an ONR Nuclear Internal Hazards and Site Safety (NIHSS), Conventional Health and Safety Inspector, accompanied by a Health and Safety Executive Inspector.
The intervention comprised of two inspectors working jointly to inspect lifting activities on various areas of the site via a site walk down, accompanied by NNB Generation Company (HPC) Limited (NNB GenCo), and meeting operatives from several contractors on the site.
The activities that were proposed to be inspected were a variety of lifting operations. The inspection also provided an opportunity to explore the site lifting arrangements and integrated safety management. Regulatory advice and judgements 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 Lifting Operations and Lifting Equipment Regulations 1998 (LOLER), Construction (Design and Management) Regulations 2015 (CDM 2015), Work at Height Regulations 2005 (WAHR), Management of Health and Safety at Work Regulations 1999 (MHSWR) and the Provision and Use of Work Equipment Regulations 1998 (PUWER).
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
The inspection took place on a day when there were no restrictions on lifting activities and several lifting activities were sampled during the visit.
A meeting was held with NNB GenCo to discuss their role as Principal Contractor in overseeing lifting operation on the construction site. Through discussions with the NNB GenCo lifting manager it was established that there was a good understanding of the health and safety risks across the site, and the appropriate measures required to control them. ONR was satisfied that the lifting arrangements that were discussed met the requirement of Regulation 13 of CDM 2015 in relation to planning lifting operations.
Several lifting incidents had occurred on site prior to the inspection which ONR had been made aware of. The incidents were discussed with NNB GenCo and it was established that the response following them had been appropriate.
ONR undertook a walk down of the site to inspect the implementation of the lifting arrangements in three separate areas.
There were several shortfalls identified during the inspection:
- Conventional Island, Nuclear Galleries – A lifting operation was inspected, and it was found that the area within which loads were permitted to be lifted had been changed without adequately revising the lifting plan. A copy of the ‘Schedule of common lifts’ available in the crane cab had last been updated in January 2020. There had been numerous subsequent revisions to the schedule, and it was out of date. A set of lifting chains which did not have a current certificate of thorough examination had not been effectively removed from service and quarantined. The temporary works permit for the crane location was not clear. It contained generic information that was not relevant to the area where the crane was positioned.
- H1 Ramp – A lifting operation was inspected where a crawler crane was being disassembled and removed from site. The lift plan had been approved by Bylor Ltd but did not address the hazard of undertaking lifting operations on a live haul road. Traffic banksmen were being used to direct traffic around the lifting operation, without the establishment of fixed barriers to separate live traffic from the lifting operation and associated work. There was no supervisor present from the Tier 1 contractor Bylor Ltd to supervise the work taking place. A crane supervisor was present but had allowed the lifting operation to take place despite it being apparent that the lift plan was not suitable and sufficient. An operative was observed on the rear of a trailer with no precautions in place to prevent the risk of a fall from height. The temporary works permit for the crane location was not clear. It contained generic information that was not relevant to the area where the crane was positioned.
It is ONR’s opinion that the lifting operations inspected in the Conventional Island, Nuclear Galleries, and the H1 Ramp did not meet the requires of LOLER, Regulation 8, in respect to the organisation of lifting operations, or elements of Relevant Good Practice (RGP) contained in BS 7121-1:2016 Code of practice for safe use of cranes – Part 1: General.
Conclusion of Intervention
From the evidence that was sampled during the intervention ONR was not satisfied that NNB GenCo and Bylor Ltd are planning, managing, and monitoring health and safety risks associated with lifting operations in line with relevant legislation and Relevant Good Practice (RGP).ONR obtained agreement from NNB GenCo that the lifting operation on the H1 Ramp would stop immediately, and that the work would not continue until a safe system of work had been established. It was agreed that NNB GenCo would investigate how the lifting operation on the H1 Ramp was allowed to proceed without a suitable and sufficient system of work in place. Details of NNB GenCo’s findings are to be provided to ONR include any remedial actions that are to be established to prevent a similar situation from reoccurring.
ONR obtained agreement from NNB GenCo that the deficiencies identified during the inspection of the lifting operation in the Conventional Island, Nuclear Galleries, including a review of the lifting plan, will to be addressed as soon as practicable.
The intervention has been rated Amber due to specific legal requirements not being met, and significant shortfalls against RGP. ONR will undertake a further inspection to clarify and understand the cause of the deficiencies before considering any proportionate and targeted enforcement action, and raising a regulatory issue.