Executive summary
Date(s) of inspection:
May 2023
Aim of inspection
This was a targeted inspection of the adequacy of the fire safety and emergency arrangements with the aim of assessing compliance with the Regulatory Reform (Fire Safety) Order 2005 (RRO) during construction activities.
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 this inspection was to focus on implementation of the arrangements on a number of support facilities.
The 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 a number of support facilities;
- the control, management and application of the fire alarm systems across varied areas of the construction project (to be determined on the day) - design, testing, and maintenance records; and
- provided an opportunity to meet with Bylor safety managers to discuss progress against current regulatory issues.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: AMBER
Key findings, inspector's opinions and reasons for judgement made
Part of this inspection was due to focus on the application and management of fire safety in several wide ranging support facilities carrying out a variety of activities involving a number of different dutyholders. I had intended to inspect up to six different locations. Due to several issues being identified at the first location (simulator building), the time taken to complete my inspection of this facility did not allow for any of the other intended locations to be seen; these will be followed-up as part of a future inspection.
Within the simulator building the management of fire safety (general fire precautions) was not found to be being managed effectively. Ambiguity exists as to who is the dutyholder and the fire responsible person. Those that I met on the day did not have the required knowledge or understanding of either role to carry it out effectively. The fire safety design for this building has adopted a fire engineered approach (BS7974), and as such it is essential that the person/s responsible for managing fire safety in this building has at least a basic knowledge and understanding of the principles of fire engineering. The fire risk assessment has identified a number of significant findings which require to be addressed. Furthermore, evidence was not provided relating to the satisfactory commissioning of all of the fire safety systems for this building.
Separately, I took an opportunity to revisit the areas of unit 1 (nuclear island) which, during my previous inspection in January 2023, had identified a number of significant shortfalls. Although these areas had changed in size and configuration considerably due to on-going construction work, the fire safety arrangements were much improved.
The Bylor Fire Safety Manager provided me with an update on the current progress relating to Regulatory Issue 11209. I noted that, after three months, insufficient progress had been made for developing and increasing the resources for the management and application of fire safety across the construction arena.
I held a meeting during the afternoon with the Project Manager from Bull Fire who provide the fire alarm system for the entire construction areas across this project. This provided a useful opportunity to understand the challenges and complexity of providing these systems.
I held a one to one meeting with a representative from the NNB GenCo internal regulator. A useful conversation was had relating to the ever increasing use and risk posed by lithium ion batteries across the site.
Conclusion
Given the shortfalls identified regarding the simulator building, the inspection has been rated as amber and a level 3 regulatory issue has been raised to track the necessary improvements.