Compliance inspection of LC19 - Construction or installation of new plant
- Site: Barrow
- IR number: 19-127
- Date: November 2019
- LC numbers: 19
Purpose of Intervention
This intervention, conducted at the licensee’s BAE Systems Marine Ltd. (BAESML) Barrow licensed site, was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.
Interventions Carried Out by ONR
I conducted a licence condition (LC) 19 “Construction or installation of new plant” compliance inspection, focused on the adequacy of the licensee’s arrangements for the LC, and that the arrangements have been appropriately implemented to control construction and installation, both completed and in-progress.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No matters were identified as requiring immediate regulatory attention during the conduct of this compliance inspection.
From the evidence presented by the licensee during this LC19 inspection, I am of the opinion that the licensee’s existing arrangements are adequate and have been appropriately applied to control construction activities, both completed and in-progress (including the site redevelopment programme, referred to as SRP).
The following represent minor shortfalls against relevant good practice with respect to the licensee’s LC19 arrangements:
- Insufficient linkage between the arrangements (e.g. the SRP Construction Management Strategy) and the requirement for specific object evidence (e.g. as identified within the Construction Management and Quality Plan).
- Adequacy of verifying records (e.g. as proposed by the contractors inspection and test plans) are not reviewed by licensee, to ensure that they are appropriate for nuclear safety.
- Lack of explicit requirements for the oversight and management of the requirements for retention of documents, records, authorities and certificates relating to construction.
The following observations and associated recommendations were identified through the course of the inspection:
- The ground improvement works (GIW) (circa 1700 piles) are likely to generate a significant amount of data. Prior to the commencement of the GIW piling activity, the licensee, Principal Contractor and the piling specialist should further discuss the records that are going to be produced for the GIW and what is important to nuclear safety.
- The Principal Contractor was not aware of any project hold points or regulatory hold points associated with the D58 works. Licensee to share relevant hold point information with the Principal Contractor for information and awareness.
Conclusion of Intervention
Based on the evidence sampled, overall I judged that the licensee’s arrangements for LC19 are adequate and have been appropriately implemented.