Merton Road BOOTLE Building 4S.1 Merseyside L20 7HS ONR ... · Dr M Weightman HM Chief Inspector of...

16 June 2011

Dr M Weightman HM Chief Inspector of Nuclear Installations, Head of ONR Redgrave Court Building 4S.1 Merton Road BOOTLE Merseyside L20 7HS

Dear Dr Weightman,

Direct tel:

Direct fax:

Your ref:

Old bury Technical Centre

Old bury Naile, Thornbury South Gloucestershire 8535 1 RQ Tel: +44 (0)1454422200 Fax: +44 (0)1454 422258 www.magnoxsites.com

Our ref: MXN32024/N

JAPANESE EARTHQUAKE AND TSUNAMI: IMPLICATIONS FOR THE UK NUCLEAR INDUSTRY - INTERIM REPORT

Please find enclosed herewith the response from Magnox Lld to the 26 recommendations in your Interim Report. Our responses are provided on the pro forma agreed amongst the UK Licensees and also include a high level programme for the work.

As you may appreciate, we have been working on how we should apply the learning from Fukushima and I have previously written to you on 15 April 2011 (Ref MXN32013/N) to provide our early thoughts on the matter. The attached responses to your recommendations provide a greater level of detail and I anticipate that the work scope and detailed plans will evolve further as more information becomes available.

We are currently progressing workshops for our two generating Sites to identify early enhancements. We consider this particularly important for our Sites due to the relatively short time remaining for generation. Similar workshops will also be held for the non-generating Sites.

In addition to the response on the 26 recommendations, we will also respond to the EU Stress Test and we are developing a common work programme as part of our Fukushima Response Project. The intention is to optimise the work where there is overlapping scope between the Stress Test and the recommendation responses.

Our approach will be to undertake the reviews and assessments utilising our arrangements for compliance with Site Licence Condition 15 - Periodic Review. These arrangements, as detailed in our Model MCP 029 - Management of Safety Case, allow non-periodic 'ad hoc'

f) INVESTORS 'U IN PEOPLE

Magno)! limited, a company owned by EnergySoluffons.ln(. Registered OffH:e: Berl::eley Centre, 8ell::eley, G!ouct'sleuhire G1I3 9/>8 RegislefOO in England under Company No. 2264251

reviews of safety in response to major events. We will therefore use this approach to document our response to the Fukushima event and this will incorporate our Independent Nuclear Safety Assessment process and review by the Nuclear Safety Committee.

I trust that you will find these responses satisfactory. Should you wish further information please feel free to contact me or our Fukushima Project Sponsor, Paul

Yours sincerely

Chief Nuclear Officer Fuelled Sites Magnox Lld

Encs

Cc

If) INVESTORS ~ IN PEOPLE

Magnox limited, a company owned by EnergySolutlons, Inc. Registered Office: Berkeley Centre, Berke!ey, Glou<estershire GL13 9PB Registered in Eng!and under Company No. 2264251

Magnox Ltd Fukushima Project Interim Report Action Timeline (Issue 1 - 17June 2011)

July August September October November December January February

1 International Arrangements for Response

2 National Emergency Response Arrangements - review of Japanese

3 National Emergency Response Arrangements - review of UK arrangements

4 Openness & Transparency

5 Safety Assessment Approach

6 Emergency Response Arrangements & Exercises - long-term accident exercise review

7 Emergency Response Arrangements & Exercises - - severe accident regulatory response

8 Off-site Infrastructure Resilience - off-site dependency review

9 Off-site Infrastructure Resilience - Fukushima Dai-ichi/Dai-ni comparison

10 Impact of Natural Hazards

11 Multi-Reactor Sites n/a

12 Spent Fuel Strategies n/a

13 Site & Plant Layout

14 Fuel Pond Design

15 Seismic Resilience

16 Extreme External Events

17 Off-Site Electricity Supplies

18 On-Site Electricity Supplies

19 Cooling Supplies - longer-term capability

20 Cooling Supplies - pond water make-up

21 Combustible Gases

22 Emergency Control Centres, Instrumentation & Communications - on-site

23 Emergency Control Centres, Instrumentation & Communications - off-site

24 Human Capabilites & Capacities

25 Safety Case

26 Way Forward

2012Magnox Ltd Fukushima Project Interim ReportJune

Collection of Information PhaseDescision PhaseONR UpdateONR final response with any recommendations

Not Protectively Marked Magnox Limited Issue 1 17 June 2011

Response to Recommendations contained within the ONR Interim Report Japanese Earthquake 2011

Recommendation

No. Recommendation Text

1

International Arrangements for Response: The government should approach IAEA, in co-operation with others, to ensure that improved arrangements are in place for the dissemination of timely authoritative information relevant to a nuclear event anywhere in the world.

1 Does the Submitting Body agree with the recommendation?

Yes.

2 How does this apply to the Submitting Body? Describe level of relevance.

The recommendation is for the government. Magnox will contribute as requested.

3 Outline the process to gather the information to enable an informed decision. (Include key dates/timescales)

n/a

4 Outline the process to enable a decision (if required) for any improvements resulting from the recommendations. (Include key dates/timescales)

n/a

5 Key date(s) to revert to ONR on this recommendation with forward plan of actions/timescales.

n/a

6 Process to ensure effective delivery of any actions to be completed.

n/a

Not Protectively Marked Rec 1 Page 1 of 1



Recommendation


2

National Emergency Response Arrangements: The Government should consider carrying out a review of the Japanese response to the emergency to identify any lessons for UK public contingency planning for widespread emergencies, taking account of any social, cultural and organisational differences.


Yes.


The recommendation is for the government. Magnox will contribute as requested.


n/a


n/a


n/a


n/a




Recommendation


3

National Emergency Response Arrangements The Nuclear Emergency Planning Liaison Group should instigate a review of the UK’s national nuclear emergency arrangements in light of the experience of dealing with the prolonged Japanese event.


Yes.


The recommendation is for NEPLG. Magnox will contribute as a member of NEPLG, but will not otherwise take any corporate action until NEPLG makes its recommendations.


n/a


n/a


n/a


Magnox Ltd has appointed a central Project Manager to oversee the response to the Fukushima event. The Project Manager will oversee all actions to which Magnox Ltd commits, through the use of appropriate project management tools together with full and open progress reporting to all stakeholders.




Recommendation


4

Openness and Transparency: Both the UK nuclear industry and ONR should consider ways of enhancing the drive to ensure more open, transparent and trusted communications, and relationships, with the public and other stakeholders.


Yes.


This applies to the whole of Magnox Limited.


Magnox Limited will support ONR as necessary in their drive to enhance relationships with the public and other stakeholders. In addition, Magnox Limited will work with the Nuclear Decommissioning Authority to seek the views of stakeholders, in particular the Site Stakeholder Groups (SSGs), on openness and transparency in order to identify any learning opportunities. This will be completed by 31/10/2011. Magnox Limited will, through its parent body (EnergySolutions,) support any industry wide approaches to openness and transparency lead by the Nuclear Industry Association – the nuclear industry trade body.


In light of the above stakeholder views will be considered by the Magnox Executive by 31/12/2011 and any enhancements agreed.


Initial response by 31/7/2011 Recommendations resulting from stakeholder feedback and follow-up actions by 31/1/2012


Magnox Limited has appointed a central Project Manager to oversee the response to the Fukushima event. The Project Manager will oversee all actions to which Magnox Ltd commits, through the use of appropriate project management tools together with full and open progress reporting to all stakeholders.




Recommendation


5

Safety Assessment Approach; Once further detailed information is available and studies are completed, ONR should undertake a formal review of the Safety Assessment Principles to determine whether any additional guidance is necessary in the light of the Fukushima accident, particularly for “cliff-edge” effects.


Yes.


The recommendation is for ONR. Magnox will contribute when consulted.


n/a


n/a


n/a


n/a




Recommendation


6

Emergency Response Arrangements and Exercises: ONR should consider to what extent long-term severe accidents can and should be covered by the programme of emergency exercises overseen by the regulator.


Yes.


Magnox will liaise with ONR and EdF to better inform and support the programme of emergency exercises, particularly with respect to joint sites.


Magnox will arrange liaison meetings with ONR and EdF to help in developing future exercises covering severe accidents. These will be held by 31/8/11.


Any recommendations for improving future emergency exercise arrangements will be considered by the Magnox Operational Resilience Manager by 31/10/2011 and any enhancements proposed discussed with the Magnox Executive.


Initial response by 31/7/11 Recommendations resulting from ONR and EdF liaison and follow-up actions by 31/12/11






Recommendation


7

Emergency Response Arrangements and Exercises: ONR should review the arrangements for regulatory response to potential severe accidents in the UK to see whether more should be done to prepare for such very remote events.


Yes.


The recommendation is for ONR. Magnox will contribute as requested.


n/a


n/a


n/a


n/a




Recommendation


8

Off-site Infrastructure Resilience: The UK nuclear industry should review the dependency of nuclear safety on off-site infrastructure in extreme conditions, and consider whether enhancements are necessary to sites’ self sufficiency given the reliability of the grid under such extreme circumstances.


Yes.


This applies to all sites.


SQEP emergency planning staff will undertake the review by 30/9/2011. The work will identify any off site support that may be called upon under severe accident conditions and identify opportunities for reducing dependencies by providing on-site equipment. NB - The reliability of the electricity grid is addressed under recommendation 17.


The conclusions of the review will be considered by the Magnox Ltd Operational Resilience Manager by 31/10/2011 and any enhancements proposed to the Magnox Executive.


Initial response by 31/7/2011. Final response with any recommendations by 30/11/2011.






Recommendation


9

Off-site Infrastructure Resilience Once further relevant information becomes available, the UK nuclear industry should review what lessons can be learnt from the comparison of the events at the Fukushima-1 (Fukushima Dai-ichi) and Fukushima-2 (Fukushima Dai-ni) sites.


Yes.




Our approach to this recommendation will be to work jointly with Sellafield Ltd and EdF Energy - we will produce a fact based joint report which each company will then take forward as appropriate within their own normal systems and processes. This joint work will commence once sufficient information regarding the topic area has been obtained from the Japanese authorities and will be completed within 12 weeks of agreeing a commencement date. It is anticipated that sufficient information will become available on or before 30/09/2011 allowing a review to be completed by 31/12/2011.


The joint report will be considered by the Operational Resilience Manager and any recommendations for improvements agreed by the Magnox Executive by 31/1/2012.


Initial response by 31/7/11. Issue of joint report summarising outcome of review by 31/12/2011 and recommendations as necessary with action plan by 31/1/2012.






Recommendation


10

Impact of Natural Hazards: The UK nuclear industry should initiate a review of flooding studies, including from tsunamis, in light of the Japanese experience, to confirm the design basis and margins for flooding at UK nuclear sites, and whether there is a need to improve further site-specific flood risk assessments as part of the periodic safety review programme, and for any new reactors. This should include sea-level protection.


Yes.


This applies to all sites but priority will be given firstly to generating Sites (Oldbury and Wylfa) followed by fuelled Sites and then non-fuelled Sites.


SQEP external hazard staff will complete the review by 31/7/2011 for generating Sites with the remaining Sites following on soon after. The review will consider previous studies and ensure that any data used remains valid and that the conclusions remain supportable. It may identify the need for further work.


The conclusions of the review will be considered by the Magnox Nuclear Safety Committees by 31/10/2011 and any enhancements agreed.


Initial response by 31/7/2011. Final review of all Sites completed and programme of follow up work as appropriate to be issued by 30/11/2011.






Recommendation


11

Multi-reactor Sites: The UK nuclear industry should ensure that safety cases for new sites for multiple reactors adequately demonstrate the capability for dealing with multiple serious concurrent events induced by extreme off-site hazards.


Yes.


Magnox do not intend to build new plants. Hazards from existing plants are addressed under Periodic Safety Reviews. Hazards from planned adjacent plants are considered as part of the planning process.


n/a


n/a


n/a


n/a




Recommendation


12

Spent Fuel Strategies: The UK nuclear industry should ensure the adequacy of any new spent fuel strategies compared with the expectations in the Safety Assessment Principles of passive safety and good engineering practice.


Yes.


Magnox does not intend to adopt any new spent fuel strategies; if they were adopted, any hazards would be addressed through the modification process. The hazards from existing spent fuel facilities will be reviewed under other recommendations.


n/a


n/a


n/a


n/a




Recommendation


13

Site and Plant Layout: The UK nuclear industry should review the plant and site layouts of existing plants and any proposed new designs to ensure that safety systems and their essential supplies and controls have adequate robustness against severe flooding and other extreme external events.


Yes.


This applies to all sites. It will be prioritised in three tranches according to the hazard:

1. Generating Sites (Oldbury & Wylfa) 2. Defuelling Sites (Chapelcross, Dungeness A & Sizewell A) 3. Sites with mobile ILW and FED storage facilities

3 Outline the process to gather the information to enable an informed decision. (Include

key dates/timescales)

Reviews will be undertaken by Site System Engineers, supported as necessary by central engineering expertise, to review vulnerability. Where possible, advantage will be taken of the Magnox Value Management Process being used under Recommendations 18, 19, 20 and 22.


The conclusions of the reviews will be considered by the Magnox Nuclear Safety Committees by 31/10/2011 and any enhancements agreed.








Recommendation


14

Fuel Pond Design; The UK nuclear industry should ensure that the design of new spent fuel ponds close to reactors minimises the need for bottom penetrations and lines that are prone to siphoning faults. Any that are necessary should be as robust to faults as are the ponds themselves.


Yes.


Magnox do not intend to build any new spent fuel storage facilities; if they were built they would be addressed through the modification process. However, existing ponds containing either fuel or high dose active items will be considered as a prudent measure in respect of bottom penetrations and the potential for pond siphoning. Therefore, this applies to Dungeness A, Chapelcross, Hunterston A, Oldbury and Sizewell A.


SQEP staff will undertake the review by 30/9/2011. The work will consider the design of the existing ponds and identify any mechanisms for loss of water, and the potential for any enhancements.




Initial response by 31/7/2011. Results of review and any recommendations by 30/11/2011.






Recommendation


15

Seismic Resilience: Once detailed information becomes available on the performance of concrete, other structures and equipment, the UK nuclear industry should consider any implications for improved understanding of the relevant design and analyses.


Yes.




Our approach to this recommendation will be to work jointly with Sellafield Ltd and EdF Energy - we will produce a fact based joint report which each company will then take forward as appropriate within their own normal systems and processes. This joint work will commence once sufficient information regarding the topic area has been obtained from the Japanese authorities and will be completed within 12 weeks of agreeing a commencement date. If sufficient information is not available in the short term the submission planned for 31/7/2011 will identify a plan for obtaining the relevant information and completing the review.


n/a


Initial response by 31/7/2011. Subsequent response timescale dependent upon availability of data but plan to be provided as part of interim response.


Magnox Ltd have appointed a central Project Manager to oversee the response to the Fukushima event. The Project Manager will oversee all actions to which Magnox Ltd commits, through the use of appropriate project management tools together with full and open progress reporting to all stakeholders.




Recommendation


16

Extreme External Events: When considering the recommendations in this report the UK nuclear industry should consider them in the light of all extreme hazards, particularly for plant layout and design of safety-related plant.


Yes.




This recommendation is being taken into account in our response to all other recommendations. The hazards include naturally occurring external hazards (eg. earthquake, flooding, extreme weather), hazards accidentally arising from commercial activity (eg. off-site explosion, noxious materials, aircraft crash), and suitable combinations of hazards. The hazards considered will be confirmed to be appropriate.




Initial response by 31/7/2011. Results of review and any recommendations by 30/11/2011.






Recommendation


17

Off-site Electricity Supplies: The UK nuclear industry should undertake further work with the National Grid to establish the robustness and potential unavailability of off-site electrical supplies under severe hazard conditions.


Yes.


This applies to all sites. Most relevant to generating sites (Oldbury and Wylfa) although site safety cases conservatively assume that grid will be lost for long periods and it is considered a ‘frequent fault’ within probabilistic safety assessments. Limited relevance for other fuelled sites, minimal relevance to unfuelled sites. The strong Magnox relationship will continue to be kept under continuous review under the auspices of the Nuclear Site Licence Provisions Agreement (NSLPA). An additional review will be carried out in the light of the Fukushima experience.


Sites will consider prolonged unavailability of off-site electrical supplies, see Recommendation 18. SQEP Magnox staff will collaborate with EdF to: • hold a workshop with industry participants to develop terms of reference for

robustness review • review risks and the current mitigation measures available, with initial identification

of any reasonably practicable improvements or further work required by 30/9/2011.






Initial response by 31/7/2011. Final response with any recommendations will be submitted by 30/11/2011. Implementation of any identified enhancements would subsequently be agreed with network owners/operators, with dates to be agreed with ONR.






Recommendation


18

On-site Electricity Supplies: The UK nuclear industry should review any need for the provision of additional, diverse means of providing robust sufficiently long-term independent electrical supplies on sites, reflecting the loss of availability of off-site electrical supplies under severe conditions.


Yes.


This applies to all sites and it will be prioritised in three tranches according to the hazard:

1. Generating Sites 2. Defuelling Sites 3. Sites with mobile ILW and FED storage facilities



Reviews will be undertaken by Site System Engineers, supported as necessary by central engineering expertise, to review vulnerability. Part of this will include use of the Magnox Optioneering Process (part of the Project Engineering Process, G-175). Workshops are being held to help to identify improvements. These will cover generating Sites, defuelling Sites and ILW facilities across all Sites as follows:

1. Generating Sites (Oldbury planned 22nd June 2011, Wylfa held 15th June 2011) 2. Sites with fuel stored in ponds/Wylfa dry store facilities (July 2011) 3. All Sites with mobile ILW and FED storage facilities (Aug-Sept 2011)

4 Outline the process to enable a decision (if required) for any improvements resulting

from the recommendations. (Include key dates/timescales)





Not Protectively Marked Magnox Limited Issue 1 17 June 2011 6 Process to ensure effective delivery of any actions to be completed.





Recommendation


19

Cooling Supplies: The UK nuclear industry should review the need for, and if required, the ability to provide longer term coolant supplies to nuclear sites in the UK in the event of a severe off-site disruption, considering whether further on-site supplies or greater off-site capability is needed. This relates to both carbon dioxide and fresh water supplies, and for existing and proposed new plants.


Yes.


This applies to Oldbury and Wylfa, the sites with operating reactors and will include fuel in the fuel route.



Reviews will be undertaken by Site System Engineers, supported as necessary by central engineering expertise, to review vulnerability. Part of this will include use of the Magnox Optioneering Process (part of the Project Engineering Process, G-175). Workshops are being held as follows to help with identifying improvements:

• Oldbury 22nd June 2011 • Wylfa 15th June 2011


The conclusions of the review will be considered by the Magnox Nuclear Safety Committees by 31/10/2011 and any enhancements agreed








Recommendation


20

Cooling Supplies: The UK nuclear industry should review the site contingency plans for pond water make up under severe accident conditions to see whether they can and should be enhanced given the experience at Fukushima.


Yes.


Applies to Dungeness A, Chapelcross, Hunterston A, Oldbury and Sizewell A, who have either spent fuel or other high dose active components in their ponds.


Reviews will be undertaken by Site System Engineers, supported as necessary by central engineering expertise, to review vulnerability. Part of this will include use of the Magnox Optioneering Process (part of the Project Engineering Process, G-175). A workshop will be held to identify improvements for these sites during July 2011.










Recommendation


21

Combustible Gases: Recommendation 21: The UK nuclear industry should review the ventilation and venting routes for nuclear facilities where significant concentrations of combustible gases may be flowing or accumulating to determine whether more should be done to protect them.


Yes.


This applies to all sites. It will be undertaken in two tranches:

1. Oldbury & Wylfa: generation of hydrogen or carbon monoxide; 2. All sites: corrosion of fuel clad in ponds and vaults.



This will be run as a separate workstream under the main project. The assessments will be undertaken by SQEP technical staff by 30/9/11.










Recommendation


22

Emergency Control Centres, Instrumentation and Communications: The UK nuclear industry should review the provision on-site of emergency control, instrumentation and communications in light of the circumstances of the Fukushima accident including long timescales, wide spread on and off-site disruption, and the environment on-site associated with a severe accident.


Yes.


This applies to all sites. It will be prioritised in three tranches according to the hazard:

1. Generating Sites (Oldbury & Wylfa) 2. Defuelling Sites (Chapelcross, Dungeness A & Sizewell A) 3. Sites with mobile ILW and FED storage facilities



Reviews will be undertaken by Site System Engineers, supported as necessary by central engineering expertise, to review vulnerability. Part of this will include use of the Magnox Optioneering Process (part of the Project Engineering Process, G-175). Workshops are being held to help to identify improvements. These will cover generating Sites, defuelling Sites and ILW facilities across all Sites as follows:

1. Generating Sites (Oldbury planned 22nd June 2011, Wylfa held 15th June 2011) 2. Sites with fuel stored in ponds/Wylfa dry store facilities (July 2011) 3. All Sites with mobile ILW and FED storage facilities (Aug-Sept 2011)

4 Outline the process to enable a decision (if required) for any improvements resulting

from the recommendations. (Include key dates/timescales)







Recommendation


23

Emergency Control Centres, Instrumentation and Communications: The UK nuclear industry, in conjunction with other organisations as necessary, should review the robustness of necessary off-site communications for severe accidents involving widespread disruption.


Yes.




Magnox SQEP emergency planning staff will undertake the review by 30/9/2011 and will consider, in conjunction with other organisations, where current off site communication channels are vulnerable and how these may be reinforced. Magnox will also consider by 31/12/2011 the learning from Fukushima in respect of multiple demands for information from stakeholders under severe accident conditions and the impact this has on the company’s ability to brief the media and the public.


The conclusions of the review by emergency planning staff will be considered by the Magnox Operational Resilience Manager by 31/10/2011 and any enhancements proposed discussed with the Magnox Executive. Any recommendations resulting from a review of severe accident public and media briefing arrangements will be agreed by the Communications Director by 31/1/2012.


Initial response by 31/7/2011. Recommendations regarding improvements in off site communications under severe accident conditions to be issued by 31/11/2011. Recommendations regarding media and public communications to be issued by 31/1/2012.




Recommendation


24

Human Capabilities and Capacities: The UK nuclear industry should review existing severe accident contingency arrangements and training, giving particular consideration to the physical, organisational, behavioural, emotional and cultural aspects for workers having to take actions on-site, especially over long periods. This should take account of the impact of using contractors for some aspects on-site such as maintenance and their possible response.


Yes.


This applies to all sites. It will be prioritised to Oldbury and Wylfa (the generating sites) where actions are required on shorter timescales.


SQEP human factors and emergency planning staff will undertake the review by 30/09/2011. The review will include consideration of the SBERGs and SAGs for all phases of a Site’s lifecycle and will also include adequacy of training and exercising the arrangements.


The conclusions of the review will be considered by the Magnox Emergency preparedness cross company group by 30/10/2011 and any enhancements agreed. Any additional training courses required would also need to be agreed by the Learning and Development peer group. The conclusions of the review will be considered by the Magnox Nuclear Safety Committees by 31/10/2011 and any enhancements agreed.








Recommendation


25

Safety Case: The UK nuclear industry should review, and if necessary extend, analysis of accident sequences for long-term severe accidents. This should identify appropriate repair and recovery strategies to the point at which a stable state is achieved, identifying any enhanced requirements for central stocks of equipment and logistical support.


Yes.




SQEP safety case and transient analysis staff will undertake a review by 30/9/2011, with interim results being available by 31/8/2011 (as this assessment may support the responses to other recommendations). It will include the safety of fuel in operating reactors and in fuel storage, and waste storage. The Severe Accident Guidelines will be reviewed and any necessary enhancements identified.










Recommendation


26

Way forward: A response to the various recommendations in the interim report should be made available within one month of it being published. These should include appropriate plans for addressing the recommendations. Any responses provided will be compiled on the ONR website.


Yes.




The proforma responses to all Recommendations 1-26 are being completed by SQEP staff. They will be accepted within Magnox and submitted to ONR by 17th June 2011.


n/a


Submit pro forma responses to recommendations by 17/6/2011.




Merton Road BOOTLE Building 4S.1 Merseyside L20 7HS ONR ... · Dr M Weightman HM Chief Inspector of...

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