presentation to nuleaf - manchester town hall – 20 july 2012

Health and Safety Executive

Presentation to NuLeaf

- Manchester Town Hall – 20 July 2012

HM Superintending Inspector

Head of Discipline – Radiological Protection (RP),

Emergency Preparedness and Response (EP&R)

http://www.hse.gov.uk/nuclear/index.htm

Charles Temple

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Presentation overview

• About ONR

• ONR Chief Inspector’s Fukushima Reports.

• Aspects considered by ONR in assessing the extent of the detailed emergency planning zone (DEPZ) from a HIRE Report of Assessment.

• ONR’s expectations for extendibility of Off-site Emergency Plans.

• Preparedness for beyond design basis accidents including ways of addressing these in the programme of nuclear emergency exercises.

• Planning controls for developments in the vicinity of nuclear licensed sites.

• Stress Tests in Other European States.

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•ONR became an agency of the Health and Safety Executive on 01 April 2011

•The new body brings together the regulation of nuclear safety, security, safeguards and safe transport of radioactive materials.

•ONR’s mission is to secure the protection of people and society from the hazards of the nuclear industry

About ONR

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ONR Chief Inspector’s Reports

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• Interim report conclusion 1

No reason for curtailing operation of NPP or other nuclear facilities in the UK.

• Interim Report Recommendation 2

UK Government to review of the Japanese response.


Nuclear Emergency Planning Liaison Group to review UK’s national nuclear emergency arrangements.


ONR to consider … programme of emergency exercises overseen by the regulator.

ONR Chief Inspector’s ReportsKey Conclusions / Recommendations

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Some Key Issues:

• Extendibility

• Radiation/Reassurance monitoring

• Central Government Response

• Prolonged event (including Recovery)

• Safety / Security integration

ONR Chief Inspector’s ReportsKey Conclusions / Recommendations

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• New Technical Assessment Guide (Draft for Trial Use) to be published in August.

• Guidance to ONR’s assessors

• Will be available on website:

www.hse.gov.uk/nuclear/operational/tech_asst_guides/index.htm

ONR Assessment of DEPZ from HIRE Report of Assessment

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ONR Assessment of DEPZ from HIRE Report of Assessment• Operator

– Determines whether REPPIR applies.– Determines whether there is potential for a radiation

emergency.– If so, undertakes Hazard Identification and Risk

Evaluation (HIRE).– Submits Report of Assessment (RoA) to ONR. – If a Reasonably Foreseeable Radiation Emergency

might arise, provides information to LA who formulates Off-Site Emergency Plan (OSEP).

– Reviews REPPIR submission within 3 years of RoA and provides results to ONR.

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• ONR– Undertakes technical assessment of the RoA. – Determines the area of the DEPZ under Reg 9(1). – In doing so, liaises with organisations including the

Operator, LA, emergency services and local public groups.

– May approve the withholding of certain parts of a REPPIR submission, for example, where public security or national defence would be compromised.

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• Radiation Emergency – an event that is likely to result in a member of the public receiving an effective dose of 5 mSv in year following the emergency.

• DEPZ is informed (not prescribed) by technical assessment of area off-site in which a member of the public may receive 5mSv dose)– Recognises uncertainties with completeness, frequency and

consequences associated with severe accident analysis.– DEPZ need not be circular.

• Initiating events include ‘unauthorised behaviour by the public’ – which includes attempted terrorism or sabotage,

• ONR expects licensee’s analysis to be based on ‘best estimates’ approach – ie. not unduly conservative.

• Guidance considers multi-plant sites and potential for simultaneous common-cause events.

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• What is a ‘Reasonably Foreseeable’ event?– ‘less than likely but realistically possible’ (REPPIR guidance)– case law outside nuclear industry refers to ‘material risks’– Not defined numerically because:

• we believe that numerical evaluation implies undue precision

• some radiation emergencies are not amenable to probabilistic safety assessment.

– We expect HIRE reports to address uncertainties in selecting

reasonably foreseeable fault sequences.

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• In determining the size of the DEPZ ONR will take the following approach:– Review the HIRE report to determine the adequacy of the

technical argument: in particular with regard to the choice and extent of the worst case reasonably foreseeable radiation emergency and the extendibility scenarios presented. ONR will liaise with the operator as required to resolve technical issues.

– Review the proposed DEPZ in light of legal precedent, relevant good practice and Public Inquiries.

– Review site specific factors which may impact the size and shape of the DEPZ.

– Liaise and consult with the LA and other relevant organisations such as the operator, emergency services and local public groups.

– Write to the LA stating the requirements for the DEPZ.

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Extendibility

• Extendibility is needed ..– due to uncertainties in the predicted severity of a nuclear

accident– Because consequences can vary with time.

• REPPIR guidance recognises extendibility as good practice in dealing with accidents beyond the reasonably foreseeable.

• HIRE RoA should explore and present the types of accident that are larger but less likely than the chosen reference accident.

• ONR expects arrangements in Off-site Emergency Plans for extendibility to be less detailed than those for reasonably foreseeable events (ie within the DEPZ), but to provide a framework for extending the response.

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Extendibility

• ONR current expectations (NEPLG Consolidated Guidance, Chapter 9) is based on :– Evacuation out to 4 km – Sheltering / KI tablet administration out to 15 km

• This is a one-size-fits-all approach.

• Disproportionate to hazard.

• We are developing a new approach based on international guidance (IAEA GS-R-2).

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Extendibility

• HIREs should include technical information relevant to extendibility to enable emergency planners to consider, for example, – The number and distribution of population affected.– The infrastructure affected.– Monitoring distances required. – Evacuation and sheltering requirements.– Additional resource needs.– Possible provision and co-ordination from adjacent Local

Authorities.

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Preparedness for beyond design basis accidents including nuclear emergency exercises

• ONR and others are working with DECC to develop a national strategic framework which is seeking to identify and implement areas with scope for improvement.

• There is particular focus on improving the interface between emergency arrangements close to nuclear sites and those in place for wider civil contingencies in the UK.

• The programme of national exercises is published on ONR’s website at:

http://www.hse.gov.uk/nuclear/emergexeprog.htm

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Emergency Exercises

• Extendibility scenario has previously been successfully tested:

– Exercise Madonna, based on an event at Heysham Power Station, in 1997

• Off-site response to severe accidents has previously been tested:

– Prolonged exercise was held in 2002 based on an event Bradwell Power

Station.

• An exercise to test the national response to a prolonged extendability scenario event ‘Exercise Northern Chain’ is in planning for March 2013, based on a postulated event at Sellafield.

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Emergency Exercises

• A successful modular exercise to test extendibility of an off-site plan was recently held based on a postulated event at Hunterston.

• An exercise to test Reassurance Monitoring Arrangements has been arranged based on a postulated event at Heysham.

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Planning controls for developments in the vicinity of nuclear licensed sites

• Long-standing Government siting policy requires Planning Authorities to consult ONR before granting planning permission for developments around nuclear installations.

• ONR has previously provided all councils in England Wales and Scotland with details of relevant zones and consultation criteria.

• We are currently reviewing our arrangements for advising on land use planning applications.

• Our primary aim will continue to be ensuring the protection of people and society from the hazards of the nuclear industry.

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• ONR advice will be based upon the size and type of the proposed development and whether the Local Authority can accommodate it into its emergency planning arrangements.

• In particular we expect Local Authorities to consult with the multi-agencies involved in implementing an off-site emergency plan to ensure that it remains credible.

• Hence population density will always be a limiting factor in developing credible emergency planning arrangements.

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• Whilst demographics is one of a number of important factors for the siting of new reactors, its applicability to existing sites that are in close proximity to large populations (Aldermaston, Devonport, Barrow etc.) is less meaningful.

• In such cases ONR believes that it is more appropriate to consult with the Local Authority to establish whether such proposals can be accommodated with the existing off-site plan.

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• We are likely to propose moving towards a position where:– The Inner Consultation Zone is coterminous with the DEPZ. – The Outer Planning Zone is coterminous with the intermediate

extendibility zone.

• In the Inner Consultation Zone:– ONR would not usually object to industrial development so long as:

• The activity does not constitute an external hazard to the nuclear facility; and

• The emergency planning authorities raise no concerns.


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• Beyond the Inner Planning Zone but within outer consultation zone(ie. typically in the intermediate extendibility zone):

– ONR will not advise against proposals so long as consultation with the multi-agencies has confirmed that the development can be accommodated within the ‘extendibility’ arrangements of the off-site plan (evacuation, sheltering, reception centres, KI tablet distribution etc.)


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Stress Tests in Other European States.

• UK National Final Reports

– for Nuclear Power Plant:http://www.hse.gov.uk/nuclear/fukushima/stress-tests-301211.pdf

– for Non-Nuclear Power Plant:http://www.hse.gov.uk/nuclear/fukushima/ngpf-report.pdf

• ENSREG Peer Review Report for UK Nuclear Power Plants:

– http://www.ensreg.eu/sites/default/files/Country%20Report%20UK%20Final.pdf

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– ENSREG Peer Review Report for European Nuclear Power Plants:

www.ensreg.eu/sites/default/files/EU%20Stress%20Test%20Peer%20Review%20Final%20Report_0.pdf

ENSREG - European Nuclear Safety Regulators Group

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• Findings of ENSREG Peer Review for European Nuclear Power Plants:

• Review process compliance with ENSREG Recommendations– Submissions generally timely and well done.– External Hazards

• Design Basis Accidents for External Events generally ok.• Problem: Margin Assessments for Extreme Accidents – ‘Cliff Edges’.• Problem acute for extreme weather.• WENRA to develop guidance in this area.

– Electrical Power and Loss of Ultimate Heat Sink• Submissions generally of good quality

– Accident management• Submissions generally of good quality

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• Licensing Basis and Plant Compliance – Plant compliance verified by inspections and walk-downs in accordance

with current licensing safety case basis. – Scope for more systematic search for non-conformities. – Periodic Safety Review important – at least every 10 years or when new

relevant information comes to light.

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• Margins, Cliff-edges and areas for possible improvement.– Evaluation of seismic and flooding margins inconsistent.

• ENSREG ‘incremental’ approach not followed in many cases.• Regulators to encourage countries to adopt this approach.

– Electrical Power and Loss of Ultimate Heat Sink• Submissions generally detailed• Fuel can heat up within 1 – 10h if cooling lost without mitigation.• With recovery action, fuel heats up within periods extending > 72h.• Several improvement actions implemented or being developed.

– Accident management• Prevention measures better developed than mitigation measures.• Mitigation arrangements vary from initial consideration to advanced. • Maintaining containment integrity is key.

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• Measures to improve Robustness– Flooding and Seismic

• Several improvements identified:– Physical flood protection measures including

» increased height of openings into protected rooms» use of temporary flood protection dams).

– Electrical Power and Loss of Ultimate Heat Sink • All countries identified measures to improve robustness including:

– Additional power / water supplies to be provided by mobile units– Extended battery capacity– Additional sources of water– Extended / additional supplies of fuel– Improved access to valves

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• Measures to improve Robustness– Accident Management

• Measures already identified should be implemented.• For water-cooled reactors, includes measures to:

– Depressurize the primary circuit to prevent high pressure core melt

– Prevent a hydrogen explosion– Prevent containment over-pressurisation

• Extend Severe Accident Management to cover– Long-duration events on multi-plant sites– Devastated site conditions– Operation in harsh environments (including radiation /

contamination)

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• Summary:– National regulators have already been proactive in demanding

improvements in these areas.– Implementation scale and progress rates vary widely.– Action plans for further analysis and improvement plans are in place or

being developed in all countries.– Overall compliance with ENSREG specifications was ‘quite good’. – Western European Nuclear Regulators’ Association (WENRA) to:

• Develop guidance on natural hazards assessments, margins beyond the design basis and cliff-edge effects.

• Underline the importance of Periodic Safety Reviews• Ensure that regulators consider the implementation of measures to

– protect containment integrity.– prevent accidents and limit their consequences in case of

extreme natural hazards.

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• Measures to improve Robustness– Accident Management

• Severe Accident Management Guidelines (SAMGs) in place for operating reactors

– Only some countries have SAMGs for shut-down reactors, spent fuel ponds or multi-unit events. These should be developed.

– Equipment such as monitoring instrumentation and communications should be robust and protected from natural hazards.

– On-site emergency centres to be designed against extreme natural and radiological hazards.

– Necessary additional staff and resources should be made available (bearing in mind devastation from natural disasters).

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Thank You

Questions?

presentation to nuleaf - manchester town hall – 20 july 2012

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