Executive summary
Date(s) of inspection: December 2024
Aim of inspection
The aim of this inspection was to seek a demonstration that the licensee is implementing adequate arrangements under Licence Condition (LC) 22 for the control of any modification or experiment carried out on any part of the existing plant or process that may affect safety.
Subject(s) of inspection
- LC22 - Modification or experiment on existing plant - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection included a general overview of the dutyholder’s LC 22 arrangements, which were reviewed and discussed with the licensee. The arrangements were judged as adequate and in line with relevant good practice as outlined in ONR’s LC22 Technical Inspection Guide. We sampled modifications taking place, or planned to take place, at four different facilities. The sampled modifications were: the replacement of the Active Filter Change robot in D1206; the upgrade to the ventilation system in D1203; the introduction of a new scabbler system in D1217; and the change from using medium fuel oil to kerosene. Representatives from each facility gave an overview of the modification taking place, or planned to take place, within their facility, and provided evidence of how the LC 22 arrangements are being implemented. We walked down the relevant project areas to witness the work been conducted and to gain confidence the licensee’s arrangements were been implemented appropriately.
Conclusion
Based on the sampling undertaken during this inspection, I judge that the licensee was adequately implementing its LC 22 arrangements and rate this inspection GREEN. Two observations were made; the first regarding licensee-proposed improvements to the LC 22 arrangements, and the second regarding the application of a standard project management approach to complex projects. I judged neither observation to be of particular concern, and considered it appropriate that the licensee reflect on the observations as part of normal business.