Executive summary
Date(s) of inspection: September 2024
Aim of inspection
The aim of this inspection was to observe a demonstration of the Springfields Fuels Ltd extant emergency arrangements to confirm the sites ability to respond to significant emergency events and hence compliance to the made arrangements, for: Licence Condition 11 (Emergency arrangements).
Subject(s) of inspection
- LC11 - Emergency arrangements - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
Springfields Nuclear Fuels undertook a level 1 (on site) and level 2 (off site) emergency exercise on 18 September 2024 to demonstrate the site emergency arrangements as required by its site licence under the site Licence Condition 11 ‘Emergency Arrangements’. This report under the site license obligations covers the level 1 element of the exercise. The offsite site level 2 response under local authority emergency planning is detailed in a separate contact record.
The exercise Heron 9 scenario proposed by the site encompassed both safety aspects (a hydrogen explosion leading to mass casualties and a criticality incident with radiological risks) and security aspects (a malicious actor). I consider the licensee’s scenario suitably challenging and realistic to the extent required to test the exercise objectives.
ONR observed the exercise in several key locations to assess the adequacy of the arrangements, the capability and capacity of the licensee to respond to the emergency effectively and swiftly.
Whilst ONR identified some areas of good practice, I consider that the exercise objectives were only partially achieved. It is my opinion that the site failed to demonstrate adequate welfare consideration of casualties and persons at risk, including the lack of timely medical assistance to the casualties. Demonstration of the site's ability to mitigate the threats posed to public and personnel is a primary objective for the exercise and mandate for the level 1 response under the sites LC11 emergency arrangements. Coupled with other exercise observations I have therefore rated this intervention ‘Amber’ - Seek Improvement.
Conclusion
I consider that the exercise objectives were only partially achieved. It is my opinion that the site failed to demonstrate adequate welfare consideration of casualties and persons at risk, including the lack of timely medical assistance to the casualties. Demonstration of the site's ability to mitigate the threats posed to public and personnel is a primary objective for the exercise and mandate for the level 1 response under the sites LC11 emergency arrangements.
The command and control structure at the FCP was not clear to those participating from supporting services.
Support to the level 2 response was not adequately demonstrated due to lack of SFL technical SQEP attendance at the SCC and a failure of communication channels between site and the SCC. Coupled with other exercise observations I have therefore rated this intervention ‘Amber’ - Seek Improvement.
I have considered the need for re-demonstration of these areas and judge that demonstration at the next annual exercise will suffice coupled with monitoring corrective action progress through level 3 and 4 regulatory issues.