Executive summary
Date(s) of inspection: November 2024
Aim of inspection
This will be 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 inspection will assess progress against previously identified challenges to the management and application of the fire safety arrangements across a wide area of different locations and occupancy.
The intention will be to gain confidence in NNB Generation Company (HPC) Ltd's (NNB GenCo) and its Tier 1 contractors' life fire safety and emergency procedures during the construction phase of the HPC project. The focus of this inspection will be 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 will also be aimed at assessing the continued and on-going application of suitable co-operation and co-ordination arrangements between various duty holders working in close proximity to each other.
The inspection will include meetings with specific duty holders and a significant walkdown of a variety of high risk areas of the project. some of these areas will be determined at the time of the intervention but as a minimum will include the Turbine Hall area (HM), HR Unit 2, Unit 1 HF building and the Heat Sink. A randomly chosen number of other buildings are also likely to be chosen as areas of interest.
The Level 4 exercise involving both on-site and external emergency services will be witnessed and assessed. The aim of this element of the inspection is to observe a site exercise (Exercise Fountain) to gain assurance that there are appropriate arrangements for life fire safety and emergency arrangements. The inspection will focus both on adequacy of implementation of arrangements at the incident scene and on adequacy of Emergency Control Centre arrangements.
Subject(s) of inspection
- Construction Fire Safety - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
This four day inspection (11 to 14 November 2024) was carried out at Hinkley Point C (HPC) nuclear licensed site. The purpose was to assess multiple areas of the construction project in relation to compliance against the Regulatory Reform (Fire Safety) Order 2005 and a Level 4 exercise, prepared and demonstrated by site organisations, against the expectations of Licence Condition 11.
This fire safety intervention involved an inspection and walk down of several work areas across the HPC construction project. These included, amongst others, HF1, HR2, and Heat Sink 1. A planned inspection of HM1 did not take place due to issues that arose elsewhere during the intervention. I also conducted a series of meetings with personnel from the Principal Contractor and other Tier 1 contractors across the four days on site.
The inspection continued to demonstrate the on-going and increased complexity of the construction environment as the build continues. Adding to this, the commencement of certain commissioning activities, and the introduction of plant and equipment in some buildings, this increases the risk profile, which add to the challenges in maintaining a fire safe environment. In particular, those areas where multiple contractors are working in and around each other in the same building / platform continue to offer challenges relating to the ownership, responsibilities and accountabilities for the fire safety arrangements in these areas.
I identified continued shortfalls on the roof of HF1 which has resulted in enforcement letters being sent to the organisations making up the MEH Alliance. The shortfalls related to the General Fire precautions on the HF1 roof (see CM9 2024/43734) which I identified in October 2024. Additionally, as a result of the Amber rating, I have sent regulatory advice letters to both the Principal Contractor and Bylor JV.
A Level 4 exercise took place(13/11/24) involving a wide range of the on-site emergency response teams, Hinkley Health, South West Ambulance Service and Devon and Sommerset Fire and Rescue Service. This demonstration was carried out on a construction platform (K19B) offering a realistic and challenging scenario. The exercise presented evidence of a good understanding between al of the organisations involved.
Conclusion
This intervention covered a wide variety of fire safety and emergency arrangements challenges that exist within the overall project. Meetings were held with various persons, involving Pre-Ops, Emergency Preparedness, Fire Safety Specialists and the Internal Regulator. Additionally I, along with other ONR colleagues, assessed a multi agency level 4 exercise. Many of the outcomes relating to these subject areas were of a positive nature and discussions, particularly around the future risk profile and the approach required to prepare for it, offered a clear direction of travel which is being driven by the Head of Site Environment, Fire, Radiation Protection and Harbours.
Although some improvements had been made I observed a lack of improvement with regard to many of the conditions identified by myself at the beginning of October 2024 on the roof of the HF1 building. In addition to the continued lack of compliance with certain aspects of the General Fire Precautions, during this intervention I identified a circumstances where a contractor had crossed a barrier to work in an area which was not assessed from a fire safety perspective, offered further concerns with regard to a lack of cooperation and coordination between different contractors.
The lack of progress to address the shortfalls in the General Fire Precautions in October, and the additional issues regarding workers crossing a barrier without due safety permissions, has resulted in an Enforcement Letter being written and sent to all five of the organisation that make up the MEH Joint Venture. Additionally regulatory advice letters have been sent to each of Bylor and the Principal Contractor.
Each of the Principal Contractor (RI-11853) and Bylor (RI-11855) have Regulatory Issues appertaining to required improvements on their cooperation and coordination arrangements and the ability of the PC to assure adequate oversight of these arrangements. I will continue to monitor progress against Regulatory Issues RI-11853 and RI-11855. The MEH Alliance also has a Regulatory Issue ( RI-12324) which relates to the conditions on the roof of HF1 as found in October 2024.