Hunterston B - Radsafe level 3 Training Emergency Exercise
- Site: Hunterston B
- IR number: 18-179
- Date: November 2018
- LC numbers: N/A
ONR Transport Inspectors inspected EDF Energy NGL’s (EDFE) offsite transport emergency arrangements by witnessing EDFE’s response to the scenario presented at exercise Kilmarnock on the 28 November 2018.
Purpose of Intervention
The purpose of the intervention was:
- To inspect the adequacy of EDFE’s arrangements for managing an offsite transport incident where they are the consignor.
- To inspect EDFE’s initial emergency response (Radsafe actions) and package recovery.
- To inform the future ONR transport inspection programme.
- To, where necessary, take enforcement action to ensure compliance with regulatory requirements including relevant good practice.
Interventions Carried Out by ONR
ONR undertook this inspection by observing exercise Kilmarnock on 28/11/2018. Inspectors simultaneously attended at both:
- The Scottish Fire & Rescue Service Training Centre, Cambuslang.
- The EDFE Central Emergency Support Centre (CESC) at Barnwood.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable to this intervention.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No regulatory issues were raised during the inspection. A number of observations were shared during the hot de-briefs. These provide learning opportunities for EDFE and Radsafe (i.e. an organisation that provides the initial response to an incident on behalf of the consignor) to consider.
During the hot de-brief ONR fed back to EDFE and Radsafe that they considered the exercise had been challenging for the participants but it had been handled well. The CESC controller had managed the team and an effective response had been demonstrated. ONR had observed good examples of questioning attitude and responding effectively to uncertainty.
ONR agreed with all the opportunities to improve identified by EDFE during the exercise. However, the following points for consideration were emphasised by ONR:
- Radsafe team did not have a formal means of identification to present to the incident commander. Consequently, the incident commander was not sure he was receiving advice from a credible source.
- Radsafe leader had difficulty in contacting the Emergency Control Centre (ECC) as they did not have a land line contact phone numbers stored on their phone.
- Springfields, the package owner and recipient, did not have the correct ONR contact phone numbers.
- Although the consignment documentation contained an EDF Energy phone number to call in the case of an emergency, this was not called by the Fire Incident Commander instead he relied on information provided by the driver of the lorry transporting the radioactive material. The lorry driver was considered ‘the expert’ at the scene although he tried to discourage this. It is suggested that the emergency phone number should be given greater prominence in the consignment documentation as a primary source of specialist information for to the emergency services at the scene.
- There was no evidence of a pre-existing recovery plan for this transport package.
- The CESC were not familiar with the Radsafe process. While not a requirement, EDFE should undertake more rehearsals of the arrangements to assist with the unfamiliarity experienced by the participants.
- It took more than two hours following the incident for ONR to be notified. A key role for the CESC, in the EDFE arrangements, is to communicate with ONR transport. Therefore, EDFE should consider if automated ONR notification is sufficient communication.
These points for consideration were well received by EDFE and ONR thanked the participants for their efforts. EDFE’s internal regulator agreed to follow up on the areas raised by ONR during the feedback.
Conclusion of Intervention
The test of the offsite transport (Radsafe) exercise (Exercise Kilmarnock) met the declared objectives. Therefore, the test demonstrated compliance with the requirement of Schedule 2(4)(3) of the Carriage of Dangerous Goods (CDG) and Use of Transportable Pressure Equipment Regulations 2009 (as amended 2011). A number of learning points were identified by the duty holder and ONR. These were communicated and will be addressed as part of EDFE’s routine learning process. ONR will monitor the response to these findings as part of routine interaction with the internal regulator.
The intervention was rated GREEN.