Executive summary
Date(s) of inspection: March 2024
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 this 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 wide ranging type of facilities at different stages of construction, relating to more than one Tier 1 and Tier 2 contractor.
The inspection included a variety of meetings with specific dutyholders and a significant walkdown of a variety of high risk areas of the project. These areas included the unit 1 and 2 reactor buildings and a randomly chosen number of other buildings that are currently covered by an Integrated Fire Risk Assessment.
A significant aspect of the inspection also aimed at assessing the application of suitable co-operation and co-ordination arrangements between various dutyholders working in close proximity to each other. It also focused on assessing the progress of improvements expected in relation to on-going enforcement and regulatory issues as a result of the findings of previous inspections.
Subject(s) of inspection
- Construction Fire Safety - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Taking into account the meetings, discussions and physical walkdown during this inspection involving a number of construction areas across both nuclear islands, I am comfortable that the Principal Contractor and the Tier 1 contractors, whose areas I visited, are making progress in addressing the shortfalls identified during previous inspections. I believe that the recent restructure of the Principal Contractor's fire safety team, which is still on-going, has introduced a refocusing on the overall management and implementation of the required fire safety standards. I have sensed a greater intention to apply a proportionate degree of oversight across the Tier 1 contractors by the Principal Contractor. Conversations with senior managers from the Principal Contractor and both Bylor and the mechanical, electrical and heating, ventilation and air-conditioning (MEH) Alliance, highlighted a common understanding of the importance in assuring that written arrangements, designed to offer a safe working environment in relation to fire safety, are implemented in a joined up and robust manner between all respective parties.
I identified some shortfalls, the majority of which were discussed and in the main addressed at the time. I will follow-up on these matters as part of my business as usual activities.
Meetings were held with each of the recipient organisations with regard to the Enforcement Notices which were served on them in December 2023. Progress is being made by all parties. ONR has received a letter from each of NNB GenGo and Reel UK Ltd requesting an extension of time in order to close out the expectations of the schedule to the Enforcement Notices. ONR has considered these requests and agreed to extend the timeframe to that requested by each organisation.
Conclusion
The Principal Contractor (NNB GenCo), Bylor JV and Reel UK Ltd continue to make adequate progress against the individual Enforcement Notices that were served on them in December 2023. None of the matters identified and discussed during this inspection warrant further regulatory action or the enhancement of existing enforcement. A green rating has therefore been applied to this inspection.