Executive summary
Date(s) of inspection: June 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. I intend to consider the 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 procedure arrangements during the construction phase of the HPC project. The focus of this inspection, amongst other things, will 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 is likely to include a variety of 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 my intervention. I will however want to visit the Turbine Hall area (HM) Unit 2 HF building and the Heat Sink. A randomly chosen number of other buildings that are currently covered by an Integrated Fire Risk Assessment are also likely to be an area of interest.
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. I will be keen 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
- Fire (Life Safety) Compliance Inspection - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This intervention involved an inspection and walk down of several work areas across the HPC construction project over a two day period. These included, amongst others, HR2, HM1, Heat Sink 1 and a number of MEH areas including HF. The third day was primarily taken up by a series of meetings with personnel from the Principal Contractor and other Tier 1 contractors.
The Principal Contractor's Fire Safety Team, which continues to settle into its new structure, further demonstrated a focus on the overall management and implementation of the required fire safety standards across the site. The greater intention to apply a proportionate degree of oversight across the Tier 1 contractors by the Principal Contractor continues in line with their Intelligent Customer role and responsibilities, although I do believe that this is still in development. Conversations that I had via a series of meetings with senior managers from the Principal Contractor and both Bylor and the Mechanical, Electrical and Heating, Ventilation and Air-conditioning (MEH) Alliance, offered further examples of the benefits of a common approach to sharing good practice amongst different organisations. Having a consistent, joined up approach and understanding of the important challenges and solutions lends itself to a safer working environment in relation to fire safety.
It was encouraging to note that the subject area improvements identified at my previous intervention have in the main continued to be applied.
I did identify 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 both the Principal Contractor and REEL UK with regard to the Enforcement Notices which were served on them in December 2023. Progress is being made by all parties.
Conclusion
Although none of the matters identified and discussed during this inspection warrant further formal regulatory action or the enhancement of existing enforcement, I do however believe that the recent introduction of revised hot work permitting arrangements warrants continued observation and assessment against RGP.
The Principal Contractor (NNB GenCo), and Reel UK Ltd continue to make adequate progress against the individual Enforcement Notices that were served on them in December 2023. A green rating has therefore been applied to this inspection.