Executive summary
Date(s) of inspection: October 2024
Aim of inspection
The aim of the inspection is to undertake a regulatory compliance inspection against all duties imposed by the Fire (Scotland) Act 2005 to ensure that the licensee is compliant in respect of the premises: Specifically, to provide assurance that the Licensee’s arrangements associated with all applicable articles are suitable and adequate, and that the licensee is working to those arrangements.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: Green
- Fire (Scotland) Act 2005 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This inspection assessed Nuclear Restoration Services (Chapelcross’s) arrangements to support Life Fire Safety (LFS) and sampled the implementation of those measures on site. Compliance was assessed using relevant Office for Nuclear Regulation (ONR) inspection guidance, specifically Technical Inspection Guide (TIG) NS-INSP-GD-073 Issue 2 – The Regulation of Life Fire Safety Provision on GB Nuclear Sites. The inspection consisted of examination of the licensee’s arrangements regarding LFS covering the Reactor 3 complex, building B141 and the Interim Storage Facility (ISF) (walkdowns) as well as meetings to assess the implementation of and management of LFS at a site level. This intervention was undertaken by two inspectors from the Office for Nuclear Regulation’s (ONR) Nuclear Internal Hazards & Site Safety (NIHSS) specialism.
It was noted that the Fire Risk Assessments (FRA) sampled as part of the inspection were of an adequate quality and level of rigor with a clear focus on driving improvements. The maintenance process for fire systems was inspected and found to be adequate. Maintenance records for a variety of systems were sampled and found to be complete. Training records for fire safety staff (responsible person and fire wardens) were sampled and found to correct.
No significant shortfalls were identified during the facility walkdowns and each area was found to be in an adequate condition. Regulatory advice was provided on some minor points related to provision of building information around combustible cladding, the siting of electric vehicle charging location and the provision of temporary vs permanent fire alarm and detection systems (FADS).
The sites compliance with the Dangerous Substances & Explosive Atmospheres Regulations were discussed in the context of Regulations 6, 11 and 15 of the Fire Safety (Scotland) Regulations 2006. ONR requested an example assessment which will be considered as part of normal regulatory business.
No regulatory issues were raised as a result of this inspection.
Conclusion
Based on the evidence provided by NRS (Chapelcross (CPX)) and observed during the inspection, I consider that generally CPX have an adequate process in place for most aspects of the control and management of fire safety with respect to life safety. I judge that the FRAs received and other processes observed are of an adequate quality and level of rigour and demonstrate a desire to drive continuous improvement through the raising of recommendations. This is supported by evidence of recommendations being closed out or otherwise actioned.
Additionally, the process for the maintenance of fire systems on site appears to be robust with the condition and approach to asset management understood by the system engineers. Records sampled during the inspection were readily available and generally of an adequate quality. Evidence was also provided of oversight and assurance of contractor activities including fire risk assessments and the hot works process. All activities on site are supported and overseen by the fire safety management group. I judge that this demonstrates adequate fire safety management.
In line with ONR inspection guidance I judge that a rating of Green ‘No Formal Action’ is appropriate.