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Joint inspection of Pre-Operational Hold Point Control arrangements

  • Site: Devonport
  • IR number: 21-074
  • Date: August 2021
  • LC numbers: 19, 21, 22

Executive summary

Purpose of Intervention

This joint ONR / DNSR inspection, on the Devonport licensed nuclear site, was undertaken in line with the Major Infrastructure Task Sheet 2021/22 for the Devonport Royal Dockyard Limited (DRDL) licensee. The scope of the joint intervention is aligned to the 2021/22 propulsion sub-division strategy.

Interventions Carried Out by ONR

The main scope of this inspection was to form a joint regulatory judgement on the adequacy of the Pre-Operational Hold Point Control arrangements and their implementation made under the following Licence and Authorising Conditions:

  • LC/AC19 Construction or installation of new plant
  • LC/AC 21 Commissioning
  • LC/AC 22 Modification or experiment on existing plant

The inspection of the DRDL Pre-Operational Hold Point Control Arrangements comprised of office-based examination of procedures and documentation and interviews with staff.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The joint inspection judged that:

  • The licensee was able to demonstrate through its written arrangements; from the project briefings provided; and the staff interviewed during the inspection, that it complied with the requirements of LC/ACs 19(4), 21(4) and 22(4);
  • The new arrangements were not only adequate, but appropriate to control the significant level of strategic change on the site;
  • ONR/DNSR recognised that the arrangements had only recently been approved (May 21) and as such DRDL were still close to the start of the journey to fully implementing these arrangements and as such ONR/DNSR judged that implementation so far was proceeding reasonably well. It should therefore be noted that only strategic implementation status has been inspected rather than direct implementation of these arrangements for a specific Hold Point release;
  • The identification of the Hold Point prerequisites enables the identification of compliance, via evidence, with all LC/AC’s that are applicable to the specific activity necessary to release the Hold Point. More importantly, the prerequisites identify interdependencies and integration across the capability, rather than being constrained by an individual project scope;
  • With the production of a Hold Point Control Plan (HPCP), a proportionate and transparent joint regulatory strategy could be overlayed and included within the pre-requisites for release, as appropriate; 
  • The agreement of the HPCP, with associated pre-requisites, at the Level 3 Regulatory Interaction Meeting, was appropriate and in line with regulatory expectations.  As such it is recommended that the Programme Managers own the Pre-Operational Hold Point Control Logic and documentation, which would also allow the strategic site wide co-ordination to be effectively managed.

Conclusion of Intervention

In our joint opinion, the Licensee's arrangements for compliance with LC/ACs 19, 21 and 22 were adequate from the arrangements examined, the project briefings provided and the staff interviewed during the inspection.  The intervention is therefore rated GREEN (no formal action) and it was concluded that this inspection identified no matters that may impact significantly on nuclear safety.