v1 t htz.) - ONR

41
Reply to: Direct Dial: E-mail: RICC Ref Our Ref: UNCLASSIFIED RICC Office F6.1 01189851015 [email protected] ONR 107-008N AWE/MD/29/11 Office for Nuclear Regulation Building 4S2 Health & Safety Executive Defence Division Redgrave Court Merton Road Bootle Merseyside L207HS Aldermasto n • Reading Berkshire • RG 7 4PR Te l •••• 17June2011 For the attention of Or M Weightman, HM Chief Inspector of Nuclear Installations Dear . /v1 t htz.) AWE RESPONSE TO THE JAPANESE EARTHQUAKE AND TSUNAMI: IMPLICATIONS FOR THE LlK NUCLEAR INDUSTRY - INTERIM REPORT Thank you for the opportunity to respond to the above interim report. AWE welcomes the opportunity to learn from events across the world and is working in concert with the UK nuclear industry and the Safety Directors Forum. I would like to acknowledge the efforts made to date by you and your team in carrying out a review of such depth and breadth in a short period of time. This covering letter and the enclosed detailed issue sheets form our response to the Interim Report. AWE has already made an initial response to the regulatory request for early information and we recognise that this interim report focuses on the implications for the nuclear power sector. As part of this initial response we confirmed that AWE has no immediate vulnerabilities. However, AWE has reviewed all the recommendations to date and their applicability to our operations. We will continue to support the review process and work with our industry colleagues to ensure the lessons learned are applied to the whole industry. We look forward to the final report which will cover all nuclear installations. Noting the applicability of the Interim Report, we believe it useful to set out in this covering letter the key characteristics of AWE. AWE Government Owned Contractor Operated organisat ion . AWE Is operated by Cl joint v nture of Jdcobs Engineering, lockheed Martm and Ser( . AWE" the trading name of AWE plc. RegIStered in England Md Wale5. RegIStration no. 02763902. Registered office: Alderma<ton • Read ing· Be,k,hlfe RGI 4PR ® Secretary of SI le for Defence Website: www.awe.co.uk

Transcript of v1 t htz.) - ONR

Page 1: v1 t htz.) - ONR

Reply to: Direct Dial: E-mail: RICC Ref Our Ref:

UNCLASSIFIED

RICC Office F6.1 01189851015 [email protected] ONR 107-008N AWE/MD/29/11

Office for Nuclear Regulation Building 4S2 Health & Safety Executive Defence Division Redgrave Court Merton Road Bootle Merseyside L207HS

Aldermaston • Reading Berkshire • RG 7 4PR

Tel •••• 17June2011

For the attention of Or M Weightman, HM Chief Inspector of Nuclear Installations

Dear . /v1 t htz.)

AWE RESPONSE TO THE JAPANESE EARTHQUAKE AND TSUNAMI: IMPLICATIONS FOR THE LlK NUCLEAR INDUSTRY - INTERIM REPORT

Thank you for the opportunity to respond to the above interim report. AWE welcomes the opportunity to learn from events across the world and is working in concert with the UK nuclear industry and the Safety Directors Forum. I would like to acknowledge the efforts made to date by you and your team in carrying out a review of such depth and breadth in a short period of time. This covering letter and the enclosed detailed issue sheets form our response to the Interim Report.

AWE has already made an initial response to the regulatory request for early information and we recognise that this interim report focuses on the implications for the nuclear power sector. As part of this initial response we confirmed that AWE has no immediate vulnerabilities. However, AWE has reviewed all the recommendations to date and their applicability to our operations. We will continue to support the review process and work with our industry colleagues to ensure the lessons learned are applied to the whole industry. We look forward to the final report which will cover all nuclear installations.

Noting the applicability of the Interim Report, we believe it useful to set out in this covering letter the key characteristics of AWE.

AWE 1~ Government Owned Contractor Operated organisat ion . AWE Is operated by Cl joint v nture of Jdcobs Engineering, lockheed Martm and Ser( . AWE" the trading name of AWE plc. RegIStered in England Md Wale5. RegIStration no. 02763902. Registered office: Alderma<ton • Read ing· Be,k,hlfe • RGI 4PR

~ ® Secretary of SI le for Defence Website: www.awe.co.uk

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UNCLASSIFIED

AWE is a scientific research, design and manufacturing organisation. It occupies two main sites which although large in size have a relatively small nuclear installations component. The sites are located well inland away from any coastal areas. Operations include non nuclear and nuclear component manufacture, explosive manufacture, assembly and disassembly of warheads and scientific research. Operations are undertaken on a batch production basis, almost wholly during standard daytime working hours with nuclear production materials stored over night in safes within the nuclear facilities. Nuclear materials within the facilities are handled in glove boxes and can remain in a quiescent state for months at a time. The sites do not undertake any reactor operations and there are no bulk quantities of highly active liquors, irradiated reactor fuel (hot fuel) or large quantities of High Level Waste stored on site. The Aldermaston site is a lower tier COMAH site and complies fully with the COMAH regulations in terms of storage and handling of chemicals.

Both sites are nuclear licensed and comply with the requirements of the Nuclear Installations Act 1965. AWE undertakes safety assessments for all its nuclear facilities using the principles of defence in depth against accident scenarios. AWE's principle aim is to ensure that engineered solutions are designed and built into the facilities where possible to prevent against foreseeable accident scenarios. In the unlikely event of these engineered systems failing control measures are operated within the facilities to ensure the facilities are returned to a steady state. All facilities have an emergency plan and AWE has a site Emergency Plan to mitigate against any off site consequences should the suite of defence in depth measures fail. As part of the safety assessment the facilities are required to consider the effects on the facility from seismic events, flooding, fire and extreme weather. The engineered systems are controls are design to operate and withstand certain criteria and emergency exercises are undertaken on a routine basis.

AWE is about to complete its ten year periodic review of safety cycle. As part of this cycle individual facility periodic reviews of safety were undertaken for all the major nuclear facilities and a periodic review of safety for the Aldermaston Site is currently drawing to a conclusion. This Site PRS covers the site infrastructure and management systems and these functions have been reviewed and compared to modern standards. Improvements have been identified and are now in a forward action plan; these will strengthen our current arrangements and go some way towards meeting the wider possibilities envisaged in the Interim Report. AWE is also investing heavily in a major infrastructure upgrade which includes new build and refurbishment of existing facilities all of which will meet modern standards and will strengthen the resilience of the site into the future.

As a result of the type of operations conducted on the AWE sites some of the recommendations within the interim report are not applicable. Therefore AWE has not included a response to recommendations 1,2,5,6,7,11,12,14,19,20 and 21.

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UNCLASSIFIED

AWE's responses to the Interim Report recommendations are attached. Furt queries should be addressed in the first instance to myself or Heather Young (Director ESH&Q). I await the final report from the ONR and will continue to support and co-operate with the regulators, government and the rest of the nuclear industry.

Yours sincerely

Dr A Jupp Managing Director, AWE plc

Copies to:

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 1 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recom mendation Recommendation Text

No. 1 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 Submittin9_ Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE. AWE anticipates that the cabinet office and DECC will form a coordinated response to this recommendation.

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 2 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 2 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.

1 Does the Submitting_ Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE. AWE anticipates that the cabinet office and DECC will form a coordinated response to this recommendation .

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 3 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 3 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

1 Does the SubmittinQ Body aQree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE. AWE is committed to contributing to any review of national nuclear emergency arrangements and will, through its membership of the Nuclear Emergency Arrangements Forum

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 4 - Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 4 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

AWE has a specific duty under the Radiation (Emergency Preparedness and Public Information) Regulations to provide the public with suitable information about its hazards, risks and emergency arrangements. AWE also has a specific duty under Licence Condition 11 to ensure that agencies involved in supporting AWE's emergency arrangements are properly consulted in the making of those plans.

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

• Collation of AWE's stakeholder management process and associated protocols and procedures (032011) .

• Collation of current information provided to the public and other stakeholders by AWE and partner agencies relating to its nuclear hazards (03 2011).

• Identification of existing forums through which the public and other stakeholders are engaged (e.g. Local Liaison Committee, website) (03 2011 ).

• Identification of national and international good practice for stakeholder management and risk communication (03 2011).

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

• Review of AWE's stake holder management process with specific regard to nuclear safety (03 2011) .

• Review of current public information provided to public and stakeholders by AWE and partner agencies relating to its nuclear hazards - to be undertaken by AWE Off Site Plan Working Group (04 2011) .

• Review of effectiveness of existing forums through which the public and other stakeholders are engaged (01 2012) .

I Security Classification I I UNCLASSIFIED I

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 4 - Issue 1

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

• Report (with recommendations where appropriate) on stakeholder management process review (04 2011)

• Report (with recommendation where appropriate) on review of current public information provided to public and stakeholders by AWE and partner agencies relating to its nuclear hazards (04 2011)

• Report (with recommendation where appropriate) on review of effectiveness of existing forums through which the public and other stakeholders are engaged (01 2012)

6 Process to ensure effective delivery of any actions to be com~eted.

• Existing corporate action management process will be used to manage all internal actions.

• Any actions placed/reliant on external agencies will be managed via suitable governance routes (e.g. Local Liaison Committee, Off Site Plan Working Group).

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 5 - Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text No. 5 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 6 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 6

1

2

3

4

5

6

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.

Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE. However, AWE is committed to participating positively in any future decisions relating to national emergency exercise programmes.

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

• N/A

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

• N/A

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

• N/A

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

• N/A

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control

UNCLASSIFIED AWE Rec 7 - Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 7 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 8 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 for the reliability of the grid under such extreme circumstances.

1 Does the SubmittinQ Body aQree with the recommendation?

yes

2 How does this apply to the Submitting Body? Describe level of relevance This recommendation of moderate relevance to AWE. AWE has recently undertaken a Site PRS assessment which has reviewed the nuclear safety reliance on the infrastructure facilities and services, and has compared these infrastructure facilities to modern standards. To date the PRS has not highlighted any off-site dependencies other than for electricity supply. A programme of improvements is in place which will remove this nuclear safety reliance on off site electricity generation. Therefore AWE believed that there are no other nuclear safety dependencies placed on off site infrastructure such as gas, water, roads etc but will undertake a confirmatory review with the on site nuclear facilities to confirm this .

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

• Analysis of claims within facility safety cases (042011)

• Review of Site PRS assessments (04 2011)

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

• Alarp optioneering assessment of findings (01, 2012)

• Production of any relevant improvement plan (01, 2012)

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

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

• Alarp optioneering study and any relevant improvement plan (Q1, 2012)

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

• Existing corporate action management process will be used to manage all internal actions

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. g 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.

1 Does the Submitting Body agree with the recommendation?

yes

2 How does this apply to the Submitting Body? Describe level of relevance AWE has two licensed site in relatively close proximity to each other. AWE will work with the rest of the nuclear industry to understand the lessons that can be learned and where applicable implement any subsequent recommendations.

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

• Undertake a review as an when the information becomes available, timescales to be confirmed.

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

• Alarp optioneering assessment of any recommendations (Timescales TB C)

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

• Alarp optioneering study and any relevant improvement plan (Timescales TBC)

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

• Existing corporate action management process will be used to manage all internal actions

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 10 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 margins for flooding at UK nuclear sites, and whether there is a need to improve further sites specific flood risk assessments as part of the periodic review programme, and for any new reactors . This should include sea level protection .

1 Does the Submitting Body agree with the recommendation?

yes

2 How does this apply to the Submitting Body? Describe level of relevance N/A Both of the AWE sites are over 50 Km inland and therefore will not be subject to a tsunamis risk. The Aldermaston site is not on a flood plain and is in a relatively elevated position (around 85 m). A specific flood risk assessment has been carried out for the Burghfield site. We therefore believe the design basis and margins for the AWE sites are correct and no further work is required.

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

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

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

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

Security Classification UNCLASSIFIED

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Security Classification UNCLASSIFIED

I I

Security Classification UNCLASSIFIED

Submitting body/Licensee Issue Control AWE ISSUE I

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 11 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 11

1

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3

4

5

6

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.

Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

• N/A

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

• N/A

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

• N/A

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

• N/A

Securit Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 12 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 12 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

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 13 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.

1 Does the Submitting Body agree with the recommendation?

yes

2 How does this apply to the Submitting Body? Describe level of relevance As part of the facility and Site PRS assessments AWE has assessed flooding risk to its nuclear facilities. Neither site is coastal and therefore will not be subject to a tsunamis risk. The Aldermaston site is not on a flood plain and is in a relatively elevated position. A specific flood risk assessment has been carried out for the Burghfield site. New facilities are being designed to modern nuclear standards with respect to severe flooding and other extreme external events. Construction of these new facilities uses a staged permissioning approach which includes assessment of the location of the facility. The current nuclear facilities on site have been assessed against flood risk and other external events as part of their recent PRS considerations. The Site PRS assessment has an associated action plan, one area of which is to consider the consequences of a severe flooding event on the emergency management services.

3 Outline the process to gather the information to enable an informed decision. {Include key dates/timescalesl

• Assessment of the consequences of a severe flooding event on the ability of the emergency management services to deliver their safety functions (03 , 2011) .

• Assessment of the suitability of the site drainage network to cope with a severe flooding event as a result of the findings from bullet 1 (04, 2011) .

• Agreement of an implementation plan for any reasonably practicable improvements to ensure the ability of the site emergency arrangements to be implemented during a severe flooding event. (01, 2012)

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

• Site PRS Forward Action Plan monitoring and verification process to be used to track and progress actions.

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

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE ISSUE 1

• Implementation Plan for any reasonably practicable improvements (01, 2012)

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

• EXisting corporate action management process will be used to manage all internal actions

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control

UNCLASSIFIED AWE Rec 14 - ISSUE 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 14 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

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Security Classification Submitting body/licensee Issue Control UNCLASSIFIED AWE Rec 15 -Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 15 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

AWE has a specific duty under licence Condition 14 to ensure that there are adequate arrangements for the production and assessment of safety cases consisting of documentation to justify safety during the design, construction, manufacture, commissioning , operation and decommissioning. Existing facilities are subject to Periodic Review under the requirements of License Condition 15 to ensure that safety cases periodically undergo a systematic review and reassessment. For new plant AWE has a duty under License Condition 19 to ensure that there are adequate arrangements to control the construction or installation activities.

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

The performance and design requirements of structures, plant and equipment at AWE are well understood and assessed through the requirements placed for compliance with License Conditions.

At AWE the plant and facilities have a range of seismic withstand capabilities based on age and process usage.

For new facilities, AWE complies with international best-practice through appropriate National and International Standards, Codes of Practice and Guidelines ensuring that building and plant designs meet the necessary seismic performance requirements. This includes identification and implementation of appropriate Quality Control and Testing arrangements during construction . This ensures identified safety requirements and performance of concrete structures are met and are proportionate to the required performance of the structure.

For existing facilities, some of which pre-date current seismic withstand expectations, AWE implements an engineering design review approach on a periodic basis. This demonstrates that buildings and plant meet the appropriate

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Security Classification Submitting body/licensee Issue Control UNCLASSIFIED AWE Rec 15 -Issue 1

performance requirements. Where this cannot reasonably be achieved then practicable improvements are made and it is then demonstrated that the risks are acceptable.

Facilities which do not pose a radiation hazard in a seismic event ,such as office accommodation blocks, comply with relevant national Building Regulations.

4 Outline the process to enable a decision (if required) for any improvements resultin~ from the recommendations. (Include ke~ dates/timescalesJ

Notification of any changes required as a result of recommendations on concrete performance following the examination of the Fukushima accident.

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

Dependant on any change requirements being identified .

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

Any changes required as a result of recommendations on concrete performance following the examination of the Fukushima accident will be addressed through inclusion within the seismic modelling assessments undertaken at AWE.

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 16 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 16 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

AWE has a specific duty under Licence Condition 14 to ensure that there are adequate arrangements for the production and assessment of safety cases consisting of documentation to justify safety during the design, construction, manufacture, commissioning, operation and decommissioning. Facilities are subject to Periodic Review under the requirements of License Condition 15 to ensure that safety cases periodically undergo a systematic review and reassessment. .

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

The assessment of all hazards including extreme hazards such as those presented by external natural and man-made hazards is undertaken at AWE through the requirements placed for compliance with License Condition 14. As a result there is confidence that the requirement to identify and assess all potential extreme hazards has been undertaken.

The nature of operations at AWE are such that any extreme event which affects site service supplies (such as electrical power and cooling water supplies) to facilities and processes does not result in unacceptable or severe accident consequence .

For all external events, including flooding, criticality safety is assured for all foreseeable faults

Where claims are made on structures providing radiological containment, these are assessed against all external events. Some containment may be vulnerable to flooding in which case some limited spread of radiological contamination could occur. This is a minor consequence event.

Some containment (Qrocess and structures) may be vulnerable to damage from

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 16 -Issue 1

a seismic event. There could be particulate release as a result of loss of containment or fire . These scenarios are considered in the REPPIR submission .

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

As a result of recommendations following the Fukushima Incident in Japan, AWE is considering further the potential impact of co-incident events.

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

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 17 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.

1 Does the Submitting Body agree with the recommendation?

yes

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

AWE has undertaken a Site Periodic review of Safety. The on site Electricity Distribution System is to be enhanced over the coming year. This enhancement will remove any nuclear safety dependency on the National Grid . However, AWE is prepared to take part in any UK nuclear industry programme of work with the National Grid .

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.

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Securiti Classification UNCLASSIFIED

Security Classification UNCLASSIFIED

Submitting body/Licensee Issue Control AWE Issue 1

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 18 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.

1 Does the Submitting Body agree with the recommendation?

yes

2 How does this ap~ to the Submitting Body? Describe level of relevance AWE has undertaken a Site Periodic review of Safety. The on site Electricity Distribution System is to be enhanced over the coming year. This enhancement will remove any nuclear safety dependency on the National Grid. These enhancements also allow for AWE to generate electricity to serve the emergency response facilities and to monitor the key nuclear facilities . Whilst it is believed this situation could be sustained for a sufficiently long period of time a review will be carried out to assess the possible time frame that this capability could be maintained.

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

• Undertake a review with the nuclear facilities and the on site EDS services to establish the timeframe over which temporary generation could be sustained, and assess the effect this would have on the nuclear facilities with respect to nuclear safety. (Q4, 2011)

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

• Alarp optioneering assessment of findings (01 , 2012)

• Production of any relevant improvement plan (01, 2012)

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

• Alarp optioneering study and any relevant improvement plan (01, 2012)

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

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Issue 1

• Existing corporate action management process will be used to manage all internal actions

Security Classification UNCLASSIFIED

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Security Classification Submitting body/licensee Issue Control UNCLASSIFIED AWE Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 19 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.

1 Does the Submitting Body agree with the recommendation?

yes

2 How does this apply to the Submitting Body? Describe level of relevance Not relevant. Coolant is not required on site by the nuclear facilities.

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

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

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

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

Security Classification UNCLASSIFIED

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Securiti Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 20 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 20 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation does not apply directly to AWE.

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 21 - Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of low relevance to AWE

There are no processes generating large volumes of combustible gases at AWE.

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

Only one facility on-site can release flammable gas as a result of fire which would result in an off-site radiological release. The risk from this has been demonstrated as being acceptable with appropriate control and emergency arrangements in place.

Some processes (e.g. Uninterruptable Power Supply (UPS) battery charging) may generate very small quantities of combustible gases as a by-product. Where identified faults have the potential to generate small amounts of flammable gases then suitable controls are identified , installed and maintained (i.e. gas detection) .

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.

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 21 - Issue 1

I I

N/A

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 22 - Issue 1

Response to recommendations contained within the ONR interim Report­Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 22 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

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

• Review of AWE's internal communications processes against various scenarios with widespread impact. (04 2010) .

• Review of adequacy of AWE's internal emergency notification arrangements (04 2010).

• Review of control room configuration and robustness to deliver functions required to support emergency arrangements as part of site safety basis report. (03 2010) .

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

• ALARP study on communications capability for on-site emergency responses to a range of scenarios with widespread impact (01 2011).

• Consideration of review of internal emergency notification arrangements (01 2011).

• Consideration of outputs from safety basis report on facility required to support emergency plans (Q4 2010).

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

• AWE Aldermaston Periodic Review of Safety (PRS) submission to ONR (012011).

• AWE(A) PRS Forward Action Plan submission to ONR (02 2011).

• Submission of updated emergency arrangements to reflect any changes to notification and liaison processes (03 2011).

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

UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 22 - Issue 1

• Existing corporate action management process will be used to manage all internal actions.

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 23 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 23

1

2

3

4

5

6

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.

Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

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

• Multi-agency review of communications in support of generic arrangements to respond to a range of emergencies with a widespread impact.

• Review of adequacy of AWE's external notification and liaison arrangements (31/12/2010) .

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

• Thames Valley Local Resilience Forum to consider outcomes of multi-agency review and to decide on any improvements required (tba -timescale beyond the control of AWE) .

• Consideration of internal review of external notification and liaison arrangements (31/03/2011)

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

• Improvement plan as identified by TV LRF (tba - timescale beyond the control of AWE) .

• Submission of updated emergency arrangements to reflect any changes to notification and liaison processes (31/08/2011).

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

Security Classification UNCLASSIFIED

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 23 - Issue 1

• Existing corporate action management process will be used to manage all internal actions.

• Any actions placed/reliant on external agencies will be managed via suitable governance route (Thames Valley Local Resilience Forum).

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Security Classification Submitting body/Licensee Issue Control

UNCLASSIFIED AWE Rec 24 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 24 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of high relevance to AWE

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

• Human factors review of key emergency response roles (30109/2011) . • Review of AWE emergency training and exercise programme

(31/10/2011). • Review of the role of contractors in emergency roles (31/10/2011).

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

• Consideration of recommendations from human factors review (30/11/2011) .

• Consideration of training and exercise programmes (31/01/2012).

• Consideration of outcomes from contractor review (30/11/2011) .

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

• Submission of human factors report (30109/2011). • Submission of updated training material and exercise programme to

reflect any changes in philosophy (31/01/2012).

• Submission of revisions to emergency arrangements identifying the roles of contractors (29/02/2012).

6 Process to ensure effective delive_1Y of any actions to be com~leted .

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 24 - Issue 1

• Existing corporate action management and governance processes will be used to manage and deliver all internal actions.

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Security Classification Submitting body/Licensee Issue Control

UNCLASSIFIED AWE Rec 25 - Issue 1

Response to recommendations contained within the ONR interim Report -Japanese Earthquake - 2011

Recommendation Recommendation Text

No. 25 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.

1 Does the Submitting Body agree with the recommendation?

Yes

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

This recommendation is of low relevance to AWE

The fissile material processes at AWE are predominately those associated with a metallurgical plant (casting, machining, pressing and joining) or material recovery using pyro-chemical processing. None of these processes involve fissile material being used to generate energy as a result of the fission process .

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

Faults leading to radiological hazards on and off-site are identified within safety case documentation to ensure protective and mitigation measures and adequate emergency responses are implemented . Potential accidents are assessed with an identified inventory of radioactive material which could be involved giving rise to a known radiological release for the accident condition. The nature of potential radiological accidents at AWE are such that longer term issues following an accident are of a non-escalating severity which would require intervention to a establish a stable state. Moreover the consideration is for arrangements to mitigate the consequences should an accident occur.

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

Recommendations 18 and 19 provide consideration against electrical and coolant supplies. AWE Will however review it's existing stocks of repair materials to support stabilisation of damaged nuclear facilities in emergency situations (04 2011)

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

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Security Classification Submitting body/Licensee Issue Control UNCLASSIFIED AWE Rec 25 - Issue 1

N/A

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

Existing company action tracking process will be used.