Executive summary
Date(s) of inspection:
Aim of inspection
This was a targeted inspection of the adequacy of the fire safety and emergency arrangements at Hinkley Point C (HPC) 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 HPC project. The intention of this inspection, amongst other things, was to focus on the implementation of the fire safety arrangements on a number of support facilities and a series of randomly chosen areas under construction.
The inspection focused on the following aspects of fire safety:
- the application of the physical arrangements of the general fire precautions within a number of support facilities and areas of construction;
- the management of fire safety within those areas of the project visited on the day;
- the management and application of the fire risk assessment process across varied areas of the construction project;
- to carry out a walk through of areas of the construction project determined on the day;
discuss with the internal regulator progress against the recent level 2 advice issued regarding fire risk assessments; and
- provide an opportunity to meet with Bylor supervisors to discuss progress against the current fire safety education / upskilling initiative.
Subject(s) of inspection
- Construction Fire Safety - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
Day one of this two day inspection focused on inspecting the support areas / platforms outside of the main construction environment. The second day included a walkdown of the external areas of the unit 1 reactor building (HR) followed by a series of meetings with the internal regulator and the NNB GenCo Fire Safety Manager.
A significant aspect of this inspection was aimed at assessing the implementation and subsequent outcomes of the improvement actions identified as a result of a previous inspection.
As a result of this latest fire safety inspection, including my observations and conversations, particularly with blue and black hat supervisors, I do not believe that there has been sufficient improvement in the management of fire safety and the application of the general fire precautions across the Bylor estate. I do not believe it is being implemented adequately. A number of potentially serious conditions relating to the control and management of combustible materials and ignition sources, challenging means of escape conditions, a lack of planning to consider the impact on fire safety arrangements as a result of construction activities and the failure of supervisors to demonstrate that the recent fire safety induction initiative had improved their focus on fire safety within their areas of responsibility provide evidence that further improvement is still required. The areas visited during this inspection were not the same as previous inspections which suggests that the challenges to managing fire safety is across the entire Bylor working estate.
The most significant matters, particularly the storage of defective lithium ion batteries and the blocking of an escape route, were addressed by the licensee before I left site.
I have articulated to senior Bylor managers my concerns that the initiatives designed to address the concerns identified and recorded as a result of the previous inspection have not produced the required improvements.
Conclusion
Given a number of shortfalls were identified during the inspection of a wide selection of Bylor work platforms, which have been identified at previous inspections, the inspection has been rated as amber and regulatory issues have been raised against Bylor and NNB GenCo. The issue raised against NNB GenCo will focus on its Principal Contractor role including its intelligent customer role, especially with regard to audit and oversight arrangements. The findings will also be taken through ONR's Enforcement Management Model to determine if any enforcement action is appropriate.