This was a planned inspection of Hinkley Point C’s security and emergency arrangements (EA) exercise, Exercise ‘Wheelhouse 16’, undertaken by ONR Safety and Security inspectors. The purpose was to seek assurance that the Counter-Terrorism Contingency Plan (CTCP) and LC 11 arrangements are effective and the site’s security and emergency arrangements can respond effectively to a security incident.
As detailed in the National Objectives, Requirements and Model Standards (NORMS) document, the maintenance of an exercise programme and provision of exercise reports is regarded by ONR as a regulatory issue that provides a key indicator of a site management’s understanding of the importance of an effective counter-terrorism (CT) response. Whilst the NORMS document primarily deals with the strategy for ensuring the security of nuclear material (NM), other radioactive material (ORM) and Vital Areas (VAs), it is considered that the conduct of a CT exercise at such an early stage of construction demonstrates the Duty Holder’s commitment to an effective security culture and allows ONR to assess aspects of the Duty Holder’s approved Nuclear Site Security Plan (NSSP) and supporting contingency arrangements.
The site’s key objectives for the exercise were to:
The exercise was conducted in a very professional, positive manner. The scenario and objectives were realistic and credible, and sufficiently challenging to test the main aspects of the site’s security and emergency arrangements.
The exercise was well organised and, considering the significant construction work currently taking place on the site, it was conducted with minimal impact on operations whilst at the same time, ensuring maximum participation. The site is commended on gaining the participation of Avon and Somerset Police whose contribution provided valuable realism to the exercise. The presence of the HPC Internal Assurance and Challenge Organisation (IACO) also proved beneficial in identifying and capturing the learning points. There were some very strong individual performances, including the Emergency Controller (EC) and the Shift Team Leader (STL), and the site demonstrated a very good team performance overall. Lessons identified from previous exercises had been captured and measures taken to prevent reoccurrence during this exercise.
One area which site should address is the Participants Brief immediately prior to the start of the exercise. ONR inspectors felt that too much information on the nature of the exercise was given, which pre-empted some of the decision-making processes which were being assessed. It was felt that a more over-arching brief on safety issues and non-exercise activity should be provided to all participants, without focussing on the exercise scenario
The four main areas attended by ONR inspectors were the Security Control Room (SCR), the Emergency Control Centre (ECC), the Simulation Cell (Sim Cell) and the incident location, in the main reception area.
The site was assessed as Adequate for both security and EA, in what was a challenging exercise. During the debrief immediately following the exercise, internal critique of the performance was robust and comprehensive. The site staff were receptive to ONR comments and appreciative of the feedback, which they took positively.
HPC is required to write to ONR and provide proposals for addressing the areas for improvement identified in this record, with realistic timeframes. HPC should provide ONR with a copy of the consolidated Post-Exercise Report. These should be with ONR (CNS) no later than 21 October 2016.