Date(s) of inspection:
- January 2023
Aim of inspection
The aim of the inspection was to determine the licensees compliance to the requirements of the nuclear site licence 102 and in particular License Condition (LC) 21 for Commissioning.
LC21 requires that the licensee “make and implement adequate arrangements for the commissioning of any plant or process which may affect safety.” LC21 also requires appointment of a suitably qualified person or persons for the purpose of controlling, witnessing recording and assessing the results of tests carried out for the purposes of commissioning.
Subject(s) of inspection
- LC21 - Commissioning- Rating - Amber
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation’s (ONR’s) Inutec Ltd intervention plan, ONR performs a series of planned compliance inspections of identified licence conditions (LCs) and other applicable legislation, to ensure that the site is meeting its legal requirements. This was a commissioning themed inspection taking account of the License Condition (LCs) 21.
LC21 requires that the licensee “make and implement adequate arrangements for the commissioning of any plant or process which may affect safety.” LC21 also requires appointment of a suitably qualified person or persons for the purpose of controlling, witnessing recording and assessing the results of tests carried out for the purposes of commissioning.
From discussions held, it was apparent that the licensee had no formal written arrangements for commissioning. The licensee currently identifies and implements any commissioning requirements under their LC22 arrangements in that the requirement for commissioning forms part of the modification implementation strategy. However, these arrangements and the process for commissioning activity itself have not been documented. I will therefore be seeking improvement from the licensee to bring the organisation back into compliance with the nuclear site license condition 21.
Conclusion
The inspection identified that the licensee has no written arrangements that address the requirements of LC21 for commission or takes into account relevant good practice such as the ONR Technical Inspection Guidance. Whilst there is some confidence that the licensee understands and applies the principles of commissioning, the lack of arrangements is a shortfall against the requirements of LC21(1). I consider a rating of AMBER, “Seek improvement” against LC21 to be appropriate.
A Level 3 regulatory issue will be raised to ensure Tradebe Inutec Ltd make and implement written LC21 compliant commissioning arrangements.