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Half yearly site report forSellafield, Calder Hall and Windscale West Cumbria Sites Stakeholder Group

Emergency Planning Working Group Report for the period1 September 2011 - 29 February 2012

Foreword

This report is issued as part of the Office for Nuclear Regulations (ONR) commitment to make information about inspection and regulatory activities relating to the above sites available to the public. Reports are distributed half yearly to members of the Emergency Planning Working Group of the West Cumbria Sites Stakeholder Group (WCSSG) and cover activities associated with emergency planning at Sellafield, Calder Hall and Windscale. The reports are also available on the ONR website.

Site Inspectors from ONR attend the Emergency Planning Working Group meetings and will be happy to respond to any questions raised there. Any other person wishing to inquire about matters covered by this report should contact the ONR.

Email: ONRenquiries@onr.gov.uk
Post: Office for Nuclear Regulation
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS

1. Introduction

This report gives a summary of the areas that have been the focus of regulatory effort over the past six months, and a forward look to those areas where effort will be spent in the future.

2. Areas covered

2.1 Level 1 - Demonstration exercises

On 1 December a team from ONR witnessed the Level 1 Exercise Nightingale. The scenario was quite challenging and involved a leak of highly active liquor in the Highly Active Liquor Evaporation & Storage (HALES) facility.

Although there were examples of good performance by those participating, including the tactical manner in which the event was dealt with by the Site Emergency Control Centre (SECC), some shortcomings were evident at the operational level. Had it been a real event, emergency response personnel would have been put at increased risk and delays would have been experienced in bringing the event under control.

We concurred with SLs view that it would take several months to develop and implement training packages to address the main shortcomings. It was therefore agreed that the effectiveness of this additional training would be demonstrated at the next Level 1 Exercise now planned for 13 June.

From the evidence gathered in the main during the Level 1 Exercise in December, and from discussions with SL staff, we have identified shortcomings in the capability and staffing of the Sellafield Fire & Rescue Service (SFRS). We have utilised the HSE Enforcement Management Model (EMM) to inform our regulatory way forward, and this has resulted in us issuing an Improvement Notice in February against Licence Condition 11, which covers emergency arrangements, that is intended to ensure that SL addresses the capability and staffing issues.

At the meeting of the Emergency Exercise Review Group (EERG) on 18 January, it was agreed that the terms of reference for the Group would be extended. The Group now oversees both the implementation and learning from all emergency exercises, and the full integration of safety and security arrangements for dealing with emergencies.

2.2 Emergency Management Arrangements

2.2.1 Emergency Management Improvement Plan

We are pleased that emergency management is now receiving a much greater focus from the SL Executive Team, which has resulted in better focus and objectivity in delivering improvements. A detailed Emergency Arrangements Improvement Plan has been put in place, with clear accountability, to ensure the timely delivery of the required improvements. The plan covers the period up to the end of June 2012 and work is on programme. SL is developing the plan to cover the period beyond June.

Matters raised during our site wide inspection, undertaken in June 2010, are included in the improvement plan, and progress in dealing with these matters is satisfactory.

Other improvements covered by the Plan are progressing at an acceptable rate. Work on Severe Accident Management Strategies (SAMs) and Severe Accident Analyses (SAAs) has been given a higher priority and the production of these documents is now on programme.

A new governance structure has been put in place for emergency management, and an Emergency Manager has been assigned to each Directorate. We view these improvements as necessary to ensure the preparedness of Sellafields emergency response organisation.

We have concerns about the SFRS and this matter is covered in Section 2.1

2.2.2 Licence Condition 11 (Waste Vitrification Plant [WVP])

In October 2011, SL attended our headquarters in Bootle to explain the reasons behind the poor findings from our June 2011 inspection of Licence Condition (LC) 11 compliance in WVP and SLs associated remedial action plan. SL fully accepted our findings and expressed disappointment with the poor performance we had identified. We were satisfied with SLs response and planned improvements, and we stressed the need for SL to progress and sustain these improvements.

Some weeks after the Bootle meeting, we carried out a verification inspection on WVP against the commitments given by WVP Senior Management. Based upon the findings of the inspection, it was our opinion that significant improvements had been made towards the facility's compliance with LC 11, and that there were no outstanding significant regulatory concerns that would not be suitably addressed by SLs remedial action plan. However, it is noteworthy that our observation of a shift exercise revealed shortcomings in local command and control similar to those evident during the Level 1 Exercise Nightingale.

2.3 Fukushima

Implications for the UK Nuclear Industry HM Chief Inspector of Nuclear Installations Report

In September, the HM Chief Inspector of Nuclear Installations issued a report responding to the request, from the Secretary for State for Energy and Climate Change, to examine the circumstances of the Fukushima accident to see what lessons could be learnt to enhance the safety of the UK Nuclear Industry. The report, the Governments response and a podcast featuring Mike Weightman are available on the ONR website.

The Secretary of State for Energy and Climate Change made a statement about the report, and in that statement he specifically highlighted that the report emphasises the need to continue the Sellafield legacy ponds and silos cleanup with the utmost vigour and determination. Both EA and ourselves will continue to focus on ensuring that SLs programmes of work in this area will be delivered in a timely manner. SL has now embarked on programmes of work to address the recommendations in the Chief Inspectors Report. The outcome of the SL work will be reflected in the Chief Inspectors Implementation Report which will be issued in the summer or autumn of 2012.

EU Stress Tests

SL has produced reports, following the Fukushima event, to address the stress test requirements requested by the Council of the European Union relating to Nuclear Power Plants (NPP). The reports produced by SL relate to the Calder Hall NPP located on the Sellafield Site. The four Calder Hall Magnox reactors are no longer operational and are currently being decommissioned. The final SL report, along with the reports produced by other UK NPP operators, have been reviewed by us and our report covering the application of stress test requirements for all UK NPP was issued in December 2011. SL has now commenced work to respond to the recommendations of our report

Application of Stress Tests to the facilities on the Sellafield Site

SL has also produced reports, as requested by our Chief Inspector, covering the consideration of the stress test requirements for the various non NPP facilities which are located on the Sellafield Site. The final SL report was issued in December 2011 and is being reviewed by our Specialist Inspectors. An ONR report covering the review of the submitted report is planned to be issued in the spring of 2012. The report produced by SL reflects an extensive review of the resilience of the facilities across the Sellafield Site with respect to major accident scenarios. The SL review work is ongoing and SL plans to produce a further report in June 2012. A number of improvements have been identified and SL is currently developing programmes to implement improvements across the site. 

2.4 SL Resilience Project

We continue to be engaged with the SL Resilience Project Team, which is managing the extensive programme of ongoing work to review the resilience of the facilities on the Sellafield site to significant accidents and events. This programme of work includes the Fukushima work mentioned above, the site Emergency Arrangements Improvement Plan and aspects of the security improvements work programme. Measures to enhance the resilience of the facilities on the Sellafield Site are now being identified and these will be reviewed to see what reasonably practicable improvements can be implemented.

2.5 Security

An IAEA International Physical Protection Advisory Service (IPPAS) mission to the UK took place in October 2011. This was the first such mission to a nuclear weapons state. In addition to assessing security in the UK against recently published international standards, the IPPAS mission team also visited Sellafield and Barrow to assess security on the ground.

This was a highly successful mission and the team reported that the state of UK civil nuclear security was sufficiently robust. The team identified many examples of good practice and made a number of recommendations and suggestions to further improve the already resilient security regime. The mission report is sensitive and will not be released into the public domain.

Security at all nuclear sites is kept under continuous review by ONR and a routine enhancement programme is presently underway at Sellafield.  Some of the enhancements are visible, such as new security fencing, but the majority are less apparent. We will work with SL to minimise the impact of the enhancements on emergency arrangements and hazard reduction.

SL is required, under the Nuclear Industries Security Regulations 2003 and the Site Security Plan, to conduct at least one major security exercise each year. On 10th November 2011, a Counter Terrorist exercise was held at Sellafield. The exercise tested key personnel and provided valuable learning for all involved. We are working closely with SL to ensure that safety and security arrangements for dealing with emergencies are fully integrated.

3. Focus of future regulatory effort

Some of the areas where we will be focussing our effort are given below.

  1. Follow up work as a result of Fukushima
  2. Improvements in the management of emergencies across the site.
  3. Assessment of the improved SAMs and SAAs.
  4. Integration of safety and security arrangements for emergencies.