ONR Transport inspected the EDF Dungeness B Site in relation to the safe transport of radioactive material. This intervention is one of a series detailed in the Transport Inspection Programme, and was carried out on 1st November 2016.
The purpose of the intervention was:
To assess the adequacy of EDF Generation and Dungeness B site arrangements for managing an offsite transport incident where they are consignor of radioactive materials packages.
Assessment of the initial Radsafe emergency response and subsequent planned package recovery operation. Exercise Rangers incident scenario. TRIM reference 2016/428150
To inform and revise the ONR Transport Work Stream 2 Capability map for EDF Dungeness B. This enables ongoing monitoring of performance and compliance against current transport regulations, Package Certificate of Approval conditions verification of safety case claims and stated operational controls.
To inform the ONR Transport risk based inspection programme. Provide intelligence for assurance aspects of the ONR Transport Permissioning process for Package approval submissions.
To improve safety outcomes by assuring, and where necessary, improving levels of industry compliance with regulatory requirements and encouraging relevant good practice.
The intervention team attended the incident scenario and the Dungeness B emergency control centre (ECC). The EDF Energy central emergency support centre (CESC) at Barnwood participated, although ONR inspectors were not present at that location.
Not applicable to this intervention.
The lead inspector reviewed the planned exercise scenario and in his judgement considered the scenario to be suitably challenging. The inclusion of a recovery phase, limited to desk top planning, in the afternoon was seen to be an improvement which would further challenge the participants.
A possible limitation to the exercise was the suggestion for “minimal impact” on routine station operations. This may have resulted in a reluctance to involve specialist staff in answering some queries from the ECC team.
The Inspectors observed exercise activities to determine if the stated objectives were met. The initial Radsafe response was undertaken by Dungeness B emergency responders.
ONR Transport were informed of the incident and consulted on the recovery plan (TRIM references; 2016/428151 2016/428152 2016/428153)
No Findings were raised during the inspection. There were a number of observations shared during the hot de-briefs which provide learning opportunities for the duty holder to consider when reviewing and improving their transport emergency arrangements.
The ECC team was calm, well managed and regular briefs were given to ECC team in the room.
The Dungeness B emergency response team was assembled in the ECC, briefed and dispatched to the scene of the incident in a timely manner.
The ECC health physicist confirmed that standard Radsafe advice in respect of dealing with radiological emergencies had been passed to the emergency services at the scene.
The Radsafe Level 2 responding team clearly understood their role and the emergency services control hierarchy.
The Radsafe responders quickly became part of the emergency services team.
During the recovery phase the CESC discussed with the ECC their proposals for recovery of the transport packages and eventual cleaning of contamination from the incident area. (It was noted that there was some discussion in the ECC regarding should the CESC have been providing fully formulated plans for implementation rather than discussing proposals).
There was minimal advice from the ECC to the emergency services at the scene during the early part of the exercise. It would be preferable for the ECC experts to determine hazards and risks based on their knowledge of the package contents and promptly advise the emergency services.
The ECC could have informed the emergency services in the early part of the exercise of the potential for airborne contamination in the event that the contaminated sludge dried out.
More frequent updating of the ECC action boards may have been beneficial.
The demands on the Radsafe Level 2 responding team (4) were considerable and it would be helpful if roles/behaviours were established prior to arrival at the incident. EG contact with ECC, contact with Incident Controller, evaluation of the situation, monitoring.
General procedures for Radsafe Level 2 responder actions at an incident could be further developed.
Dungeness B could work with the local emergency services to improve the process used by the emergency teams to exit a contamination zone.
Opportunities for improvement and comments within this report should be considered by the duty holder, benefits gained should be seen at the next exercise.
In conclusion the arrangements demonstrated during Exercise Rangers provided confidence that EDF Dungeness B emergency arrangements are adequate in relation to the transport of radioactive material for the purposes of compliance with the requirements of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended 2011)