Executive summary
Date(s) of inspection: June 2024
Aim of inspection
This inspection at Sellafield Ltd will be undertaken as part of the planned Intervention Strategy for the Sellafield, Decommissioning, Fuel and Waste Division (SDFW) of the Office for Nuclear Regulation (ONR).
The purpose of this intervention will be to inspect against compliance with the requirements of the Regulatory Reform (Fire Safety) Order 2005 (RRFSO).
This intervention will focus on matters relating to life fire safety.
Subject(s) of inspection
- Construction Fire Safety - Rating: Green
- Regulatory Reform (Fire Safety) Order 2005 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The SIXEP Continuity Plant (SCP) construction project aims to extend the life and capability of the SIXEP area and broadly consists of two areas itself:
- Process Building
- Service Building
This inspection focused on the life fire safety aspects of the current construction site and compliance with the requirements of the Regulatory reform (Fire Safety) Order 2005. It did not consider the final state of the buildings or their fire strategies. It also considered the requirements of the Construction (Design and Management) Regulations 2015
Fire Safety
Prior to this inspection we requested the relevant Fire Safety Strategy, Fire Risk Assessments (FRAs) and other relevant fire safety management documentation for review.
Sellafield Ltd and Programme and Project Partners (PPP) delivered a short presentation on the SCP project and how they are discharging their respective duties from the relevant legislation.
These two elements were then assessed further by a physical inspection of the SCP construction areas, where additional enquiries were made as appropriate for the following General Fire Precautions (GFP):
- Fire Warning and Detection Systems
- Travel Distances
- Emergency Lighting
- Portable Firefighting Equipment
- Sources of Ignition
- Combustibles & housekeeping
- Compartmentation and building enclosure
- Emergency Action Procedures
- Training
It was evident that this area is meeting the relevant legislative requirements for fire safety, however we identified elements which can be improved or clarified. These were discussed with the relevant persons / duty holders.
The inspection was rated GREEN for fire safety.
Construction (Design and Management) Regulations 2015
The following documents were reviewed prior to the site inspection.
- CDM Dutyholder Appointment AD B1811 PROJ 00001 J
- D042E4C007 – F10 Notification May 2023
- SCP CPP April 2024
The project is well managed and complying with the requirements of parts 2,3 and 4 of CDM. The project requirements, hazards and risks are identified in the Construction Phase Plan (CPP). Suitable arrangements are in place to continually review and update the CPP and communication between CDM dutyholders is well managed via the Aligned Delivery Team (ADT). Contractors are complying with their duties to plan, manage and monitor the work under their control and good, ongoing communication with the principal contractor and principal designer were seen on site during the inspection.
While we identified shortfalls relating to the emergency arrangements for the site, we are satisfied that these are well understood by the dutyholder and that a review is already planned. We requested the updated arrangements be shared with ONR once complete. We observed that there is a positive health and safety culture on site which was demonstrated during conversations with the ADT and individual contractors on site. Overall we are content that the duty holder demonstrated an adequate understanding of their legislative obligations, fire safety arrangements for the PPP SCP construction area and that these were being appropriately implemented.
This inspection was rated GREEN for construction aspects.
Conclusion
It is the opinion of ONR, that the areas inspected and discussed (SCP construction areas) demonstrated compliance to the Regulatory Reform (Fire Safety ) Order 2005 and the Construction (Design and Management) Regulations 2015.
The ADT is made up of representatives from the client, principal designer and principal contractor so project information is consistently shared and communicated between all the CDM dutyholders.
There is a positive health and safety culture within the ADT which feeds down to the workforce through positive interactions and conversations with the workforce. They were able to demonstrate how they listened and acted on suggestions and concerns; for example, work packs are now kept in dedicated pockets on the work area notice boards. This came about after a supervisor complained that the work packs were often ignored because operatives had to return to the office to review them.
The emergency planning and welfare issues identified by ONR were not a surprise to the ADT and they were already taking action to address them, as such we did not judge any formal action to be required at this stage. We requested the updated procedures be shared with ONR.
It was also good to see the positive relationship with the TU representatives.
This inspection was rated GREEN.