Executive summary
Date(s) of inspection:
- January 2023
Aim of inspection
The aim of the inspection was to gain confidence in NNB Generation Company (HPC) Ltd's (NNB GenCo) and its tier 1 Contractors' life fire safety and emergency arrangements during the construction phase of the Hinkley Point C (HPC) project. The intention of the inspection was to focus on implementation of the arrangements at the work face.The primary purpose was to assess compliance with the Regulatory Reform (Fire Safety) Order 2005 (RRO). This inspection focused on the following aspects of fire safety:
- the application of the physical and management arrangements of the General Fire Precautions;
- the application of the management and control of fire safety within Bylor;
- the control, management and application of the fire alarm systems across the nuclear island work areas - design, testing, and maintenance records;
- the control and management of laydown areas within enclosed areas of construction, including both permanent and temporary arrangements; and
- progress against the recommendations of a recent fire investigation report and the short and long-term actions identified in the root cause analysis report.
Subject(s) of inspection
- Fire (Life Safety) compliance inspection
Key findings, inspector's opinions and reasons for judgement made
As a result of my fire safety inspection, and in particular the walk down of the conventional island and nuclear island areas, and conversations with Fire Safety Monitors (FSM) and supervisors, I do not believe that the management of fire safety and the general fire precautions across the Bylor estate is being implemented adequately. A number of potentially serious conditions relating to the control and management of combustible materials and ignition sources, and the failure to adequately manage and monitor fire alarm systems required my immediate intervention during my walk down. In particular, the FSMs are, in my opinion, under developed for the role that is expected of them, and the geographic areas that they are responsible for are too large and complex for one person. I do not believe that the 'black' and 'blue hats' are being used adequately to support the role of the FSM. I believe that the lack of a robust and well developed fire safety management system is contributing to the issues identified during my inspection.Conclusion
A number of shortfalls were identified during the inspection, with the most significant matters addressed by the licensee before I left site. The inspection has been rated as amber and a level 3 regulatory issue has been raised to track the necessary improvements.