April 2012 Page 1 of 65 Draft 1.1 November 2011 Final Report to ONR on the application of the ENSREG Stress Tests to the Sellafield Site All Sellafield Limited Sites Excellence in Safe Operations Site Resilience Excellence in Emergency Preparedness Excellence in Security April 2012 Page 2 of 65 Glossary of Terms A AC ACP AGR ALARP BRE BSI BSL BWR C CCTV CHP cm CF&R CNC CO2 COSR CSF DA DB DBA DBE DBF DC DMV EIM&T ENSREG ENW EPD ESI ESP ESS EU fdSC ft GI GMT GNI GT GTG Ha HAL HAST HAZOP HVAC Hz ICC Amperes alternating current Access Control Point Advanced Gas-cooled Reactor As Low As Reasonably Practicable Building Research Establishment British Standards Institute Basic Safety Level Boiling Water Reactor Celsius Close Circuit Television Combined Heat and Power centimetre Cumbria Fire and Rescue Civil Nuclear Constabulary carbon dioxide Continued Operations Safety Report Critical Safety Function Diesel Alternator Design Basis Design Basis Analysis Design Basis Earthquake Design Basis Flood direct current District Monitoring Vehicle Examination, Inspection, Maintenance and Testing European Nuclear Safety Regulators Group Electricity North West Essential Power Distribution Electricity Supply Industry ElectroStatic Precipitator Emergency Switching Schedule European Union fully developed Safety Case feet Guaranteed Interruptible Greenwich Mean Time Guaranteed Non-Interruptible Grid Transformer Gas Turbine Generator Hectare Highly Active Liquor High Active Storage Tank HAZard and OPerability study High Volume Air Conditioning Hertz Incident Control Centre April 2012 Page 3 of 65 IFP km kW LFE LFL LLW LLWR LN2 LTPR m m3 mAOD MDA MSML mm mph mSv MW NDA NIA65 NMP NPP NRE NSLC ONR PCM pga PMS PSA PSR PWR REPPIR RESEP S&SSM SAA SAMS SBO SEC SECC SED SEI SEMP SMC SF&R SL SLM SLMS SLP SLCP Insoluble Fission Products kilometre kiloWatt Learning from Experience Lower Flammable Level Low Level Waste Low Level Waste Repository liquid nitrogen Long Term Periodic Review metre cubic metres metres above Ordnance Datum Mobile Diesel Alternator Minimum Safety Manning Level millimetre miles per hour milliSievert MegaWatt Nuclear Decommissioning Authority Nuclear Installations Act 1965 (as amended) Nuclear Management Partners Nuclear Power Plant National Resilience Extranet Nuclear Site Licence Condition Office of Nuclear Regulation Plutonium Contaminated Material peak ground acceleration Plant Maintenance Schedule Probabilistic Safety Analysis Periodic Safety Review Pressurised Water Reactor Radiation (Emergency Preparedness and Public Information) Regulations REsilience Evaluation Process Safety and Site Shift Manager Severe Accident Analysis Severe Accident Management Strategy Site Black Out Site Emergency Controller Site Emergency Control Centre Safety and Environment Detriment Site Emergency Instruction Site Emergency Monitoring Point Strategic Management Centre Sellafield Fire and Rescue Sellafield Ltd Sellafield Ltd Manual Sellafield Ltd Management System Sellafield Ltd Procedure Sellafield Ltd Code of Practice April 2012 Page 4 of 65 SLSP SOER SPMS SQEP SSC SSG te UHF UHS UK UPS UU W WANO WCECC Sellafield Ltd Supporting Practice Significant Operating Experience Report Site Perimeter Monitoring System Suitably Qualified and Experienced Person Structures, Systems and Components Sherwood Sandstone Group tonne Ultra High Frequency Ultimate Heat Sink United Kingdom Uninterruptible Power Supply United Utilities Watt World Association of Nuclear Operators West Cumbria Emergency Control Centre April 2012 Page 5 of 65 Table of Contents Glossary of Terms ............................................................................................................... 2 Executive Summary ............................................................................................................ 6 Background ......................................................................................................................... 7 1 Introduction.................................................................................................................10 2 Systems for providing or supporting main safety functions ...................................14 3 Regulatory framework, license compliance and probabilistic safety assessment 23 4 Earthquake ..................................................................................................................28 5 Flooding ......................................................................................................................38 6 Extreme weather conditions ......................................................................................44 7 Loss of electrical power and loss of ultimate heat sink...........................................49 8 Severe Accident Management ...................................................................................52 9 Summary .....................................................................................................................62 April 2012 Page 6 of 65 Executive Summary The Tohuku earthquake on 11 March 2011 and subsequent events have prompted fundamental reviews of the resilience of nuclear power plants against a variety of extreme situations such as those that occurred at the Fukushima Dai-ichi Nuclear Power Plant, i.e. an earthquake and/or flooding as an initiating event; the consequence(s) of loss of safety functions from any initiating event at the site such as loss of electrical power, including Site Black Out (SBO), loss of ultimate heat sink (UHS) and/or a combination of both; and severe accident management issues such as means to protect from and manage loss of cooling and/or containment integrity. This has required the establishment of a climate wherein nuclear professionals can engage constructively with scenarios that they routinely strive to avoid in the course of ’normal’ operations and then progressively ’dismantle’ all of the support that they have come to depend on before determining how resilient they truly are. Sellafield Ltd (SL) has therefore developed the RESilience Evaluation Process (RESEP). This report details the application of RESEP to plants at Sellafield which could generate significant off-site radiological consequences so as to respond to the European Nuclear Safety Regulators Group (ENSREG) questions as requested by the Office of Nuclear Regulation (ONR). In doing so it makes a full response - for a diverse and complex nuclear fuel cycle site – to questions designed for Nuclear Power Plants (NPPs). On the basis of the current state of knowledge – A number of older plants will be adversely affected by a greater than design basis earthquake (DBE). The site has adequate protection against both tidal and river flooding with the only significant risk being that of an extreme rainfall event which could result in some shortterm surface water ponding. There is a high degree of diversity and redundancy for both on and off-site electricity and water supplies. There are sufficient fuel stocks for Sellafield site to be self-sufficient for a seven day loss of electricity supply from the national grid. The site has robust arrangements for a seven day loss of Ultimate Heat Sink (UHS) which, in a Sellafield context, relates principally to diverse means for cooling Highly Active Liquor (HAL), for keeping fuels wetted and for ventilation. Fuel ponds are unaffected by a seven day loss of cooling water make-up and relatively robust to a Design Basis Accident. Local plant arrangements, which are designed to prevent a reasonably foreseeable event arising, are robust. Existing site emergency arrangements, which are designed primarily to respond to a reasonably foreseeable event in a single plant, would soon be strained by requests for support to multiple plants as a consequence of an event with simultaneous site-wide effects. There are opportunities to improve the emergency infrastructure in support of a response to an extreme event such as those identified within this report. These preliminary findings are brought together in a number of “considerations” to be developed further as the basis for action by the Company. The work undertaken to date, as detailed within this report, has identified no potential deviations from the licensing basis. April 2012 Page 7 of 65 Background A Purpose and Scope Following the Tohuku earthquake on 11 March 2011 and subsequent events at the Fukushima Dai-ichi Nuclear Power Plant, the European Council on 24 and 25 March declared that “the safety of all EU nuclear plants should be reviewed, on the basis of a comprehensive and transparent risk assessment (“stress tests”)”. On 25 May 2011 the European Commission and the European Nuclear Safety Regulators Group (ENSREG) produced a joint specification for a three stage process of this “targeted reassessment of the safety margins of nuclear power plants”. These “stress tests” are intended to highlight the self-reliance of a nuclear power plant (NPP) against a variety of extreme situations such as those that occurred at Fukushima, i.e. an earthquake and/or flooding as an initiating event; the consequence(s) of loss of safety functions from any initiating event conceivable at the site such as loss of electrical power, including Site Black Out (SBO), loss of Ultimate Heat Sink (UHS) and/or a combination of both; and severe accident management issues such as means to protect from and manage loss of cooling and/or containment integrity. On 1 June 2011 the Office for Nuclear Regulation (ONR) issued a request to all UK nuclear operators, including Sellafield Limited (SL), to provide responses based on the ENSREG “stress tests” for each of their sites. This has necessarily required a structured interpretation by SL of many of the ENSREG “stress tests”, due to the radical differences between an NPP and a complex and diverse multi-plant nuclear chemical processing site. It has also required a clear definition of the Sellafield plants and supporting functions to which they would be applied. SL operates the Sellafield site (including Windscale), the Calder Hall nuclear power plant and also the Capenhurst site, owned by the Nuclear Decommissioning Authority (NDA). This paper represents the final report for the Sellafield site plants as of 30 June 2011. Many of the scenarios set out in this report can only result from extreme events, i.e. those involving the failure of multiple safety systems, prolonged (days rather than hours) loss of utilities and services and the absence of assistance from outside of the site. Such scenarios are often beyond, and in many cases significantly beyond, the current design basis of for the plants and this RESEP analysis has yielded new insights. B Context SL has established a Resilience Programme to deliver the totality of the company’s response to the events at the Fukushima Dai-ichi NPP, including the recommendations arising from the ONR Chief Inspector’s (”Weightman”) interim and final reports [1] [2] which have several issues in common with the ENSREG “stress tests”. The Programme comprises the following workstreams assessment of current site resilience and definition of future resilience architecture; support to Japan; and stakeholder engagement. April 2012 Page 8 of 65 C Sellafield response to ENSREG C.1 Scope for radiological consequences The ENSREG “stress tests” require evaluation of the resilience of a large number of facilities on the Sellafield site and the integrated site as a whole. Sellafield has an existing set of safety cases which are subject to regular review and update. To provide a proportionate basis for applying the ENSREG “stress tests” it was necessary to focus on significant plants. Accordingly all safety cases were reviewed for significant potential fault sequences with an off-site consequence threshold of 10 mSv to the critical group. This choice of 10 mSv threshold had already been used by SL as the starting point for Severe Accident Analysis studies. In addition, the 10 mSv dose threshold is broadly equivalent to that required for the Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR). As a cross check an alternative method was also used. The Safety and Environment Detriment (SED) Score is a prioritisation methodology used throughout the NDA estate. It uses a combination of harm potential (essentially magnitude of inventory), form factors (i.e. the physical state of the material – gas, liquid or solid), passivity and containment condition. The integrated toxic potential and form factors were reviewed to identify a number of facilities which may have the potential to give rise to significant offsite consequences from an equivalent inventory standpoint (with a SED cut off value of 1x1010). This allowed a wider range of plants to be included, especially those more modern facilities with more highly-engineered safety systems. The combination of these criteria allowed a list of plants to be generated which were then appropriately grouped to RESEP studies. However it is important to note that these off-site consequences to the critical group and the SED scores, and hence the RESEP screening criteria, are based on assumptions which themselves are intended to support conservative decision making. Hence the offsite consequences of any release may be lower than predicted with the time to respond somewhat longer. D.2 The RESilience Evaluation Process (RESEP) The RESEP process has been developed as a structured and consistent approach to resilience assessment for the Sellafield site that satisfies the requirements of the ENSREG stress tests. Additionally, ENSREG set the background scenarios as being, “the most unfavourable operational states that are permitted under plant technical specifications” for plants configured and operated as at 30 June 2011 with all plants being supposed to be simultaneously affected and offsite power assumed to be lost for several days, the site isolated from delivery of heavy material for seventy two hours and portable lightweight equipment for twenty four hours. The RESEP process was a staged assessment which included a screening process to identify those requiring further consideration due to their inventory and those plants that could not give rise to a significant off site consequence (greater than 10 mSv to the critical group) either because their inventory is low or non-mobile. The process allows for progression of events from individual plant to whole site, including ‘domino’ effects; searches for ‘cliff edge’ effects and enables development of timelines for critical mitigating response actions; assesses infrastructure requirements both on- and off-site to identify opportunities for resilience enhancement; and April 2012 Page 9 of 65 provides a key focus for damage control teams. Summaries of the RESEP reports were considered by the relevant Management Safety Committee(s) and the resultant recommendations will be included in phase 2 of the Site Resilience Programme commencing in 2012. The RESEP approach will also be applied to significant changes in configuration of existing plants or introduction of new plants following the ENSREG ‘cut off’ date (i.e. 30 June 2011) as the site continues to develop. Discussions are ongoing with both ONR and other licensees regarding the use of the ALARP process for determining the implementation of improvements within the Site Resilience Programme. The following principles (agreed at an ONR-industry workshop on 24 August 2011) will be observed as part of the decision making process in consideration of significant improvement opportunities the ALARP framework is appropriate; cost benefit analysis is of very limited value; qualitative judgement is key; balanced judgement is informed by “relevant good practice and LFE”; implementation must be credible in an accident situation; simple flexible solutions are preferred; and actions should be informed by the residual plant life (or time at risk). Options will be exposed to appropriate internal challenge and peer review as part of making any capital investment decisions at Sellafield. April 2012 Page 10 of 65 1 Introduction 1.1 Brief description of the Sellafield site The Sellafield nuclear licensed site is owned on behalf of Her Majesty’s Government (HMG), by the Nuclear Decommissioning Authority (NDA), and is operated by Sellafield Ltd. (SL; the Site Licence Company) under the shareholding of Nuclear Management Partners (NMP; the Parent Body Organisation) (see Figure 1.1). Regulatory bodies inc Office for Nuclear Regulation, Health and Safety Executive, Environment Agency Figure 1.1 Management arrangements for the Sellafield site The Sellafield site has been operational since the 1940s when it was used as a Royal Ordnance factory supporting the war effort. The site is also home to the world’s first commercial scale nuclear power station, Calder Hall, which operated successfully from 1956 to 2003. Today the site comprises a wide range of nuclear facilities, including seven reactors all of which are shutdown and undergoing defuelling/decommissioning, as well as operating facilities associated with the Magnox reprocessing programme, the Thermal Oxide Reprocessing Plant (THORP) and a range of waste treatment plants. Decommissioning and clean-up Legacy Ponds and Silos are historic facilities which contain Magnox fuel and reactor fuel from the Windscale Pile reactors, and cladding swarf from early reprocessing operations on the site. Work is ongoing to retrieve and treat the material held in these facilities so that the facilities can be decommissioned. Primary Separation Plant was Sellafield’s first reprocessing facility which began operations in 1952 and was used to process reactor fuel and support initial efforts in oxide reprocessing in the early 1970s. The facility is currently undergoing decommissioning. Pile 1 and Pile 2 were the first nuclear reactors at Sellafield; both were shut down following the 1957 fire in Pile 1. Work is ongoing to decommission both piles. Windscale Advanced Gas-Cooled Reactor was a small prototype reactor which was the forerunner to the UK’s second generation of nuclear power plants. Having ceased operations in 1981, it is now effectively decommissioned. Calder Hall was the world’s first commercial scale nuclear power plant which was officially opened in 1956. The four-unit plant ceased generating electricity in 2003 and is currently undergoing de-fuelling. April 2012 Page 11 of 65 Commercial operations Fuel Handling Plant receives Magnox and AGR spent fuel and stores it in ponds for a predetermined period prior to being conditioned for reprocessing and transfer to the Magnox and THORP plants respectively. Magnox Reprocessing Plant is used to reprocess Magnox fuel from throughout the UK. Thermal Oxide Reprocessing Plant (THORP) is used to receive, store and reprocess Oxide fuel from both UK and overseas. Sellafield MOx Plant was used to manufacture Mixed Oxide fuel for overseas customers. It ceased operation in 2011 and is currently undergoing run-down and POCO activities. Nuclear waste treatment/processing Highly Active Liquor Evaporation and Storage uses evaporators to concentrate Highly Active Liquor (HAL) prior to being processed in WVP. HA liquor operations commenced in the early 1950s. Waste Vitrification Plant (WVP) processes HAL into solid form by incorporating it into glass, followed by a period of on-site storage. This process dates from the 1980s. Effluent and Encapsulation Plant facilities process intermediate level solid waste and liquid effluents generated across the Sellafield site prior to final encapsulation or discharge/disposal to the environment within appropriate permit conditions and limits (including application of Best Available Techniques to minimise discharge/disposal). Waste and product storage facilities Sellafield Product and Residue Store provides safe storage for materials produced as a result of reprocessing operations at Sellafield. Encapsulated Product Stores are drum stores for Intermediate Level Wastes. Residue Export Facility is used to load canisters of vitrified high active waste into flasks for export back to overseas customers. The site also has a wide range of support buildings including, but not limited to, offices, workshops, flask maintenance, utilities, analytical laboratories, emergency management, fire and rescue, Occupational Health etc. as well as an on-site rail network and the Fellside Combined Heat and Power Plant. Hence, as previously discussed, there are significant differences between NPPs, for which the ENSREG “stress tests” were originally intended, and the Sellafield site. In the case of NPPs the consequences of a significant fault may be quickly apparent, whereas, at Sellafield the processes are at comparatively lower temperatures and pressures with relatively lower rates of change due to loss of cooling. Consequences of a significant fault at Sellafield are more directly related to the large inventories of radioactive materials and the conditions of storage. 1.2 Geography and topography The Sellafield site, which employs ~10,000 full-time equivalent staff, is located on the West Cumbrian coast adjacent to the Irish Sea on the western outskirts of the Lake District National Park (see Figure 1.2) and within the catchments of the rivers Calder and Ehen. The site licensed boundary encompasses an approximate area of 276 Ha and is located at 54N, 3W. The site is mainly in the Parish of St Bridget Beckermet, within the Copeland District of the County of Cumbria. The major local towns of April 2012 Page 12 of 65 Whitehaven, Workington and Barrow are approximately 14 km to the north, 25 km to the north and 38 km to the southeast respectively. There are about 200 people living within 2 km of the site: the nearest settlement of any size is Seascale 2.5 km distant, with a population of about 1800 [4]. The nearest main road is the A595 single carriageway which passes within ~1.5 km of the Sellafield site to the east. Smaller approach roads to Sellafield site are used by Sellafield traffic with access via four principal pedestrian/vehicle gates. The Network Rail line from Whitehaven to Barrow passes close to the Sellafield site. A branch line onto Sellafield site is used to receive spent reactor fuel from power stations, bulk chemicals and to export Low Level Waste (LLW) to LLWR and High Level Waste (HLW) to overseas customers. The site topographical range is +9.00 to +48.00 metres Above Ordnance Datum (mAOD). The approximate linear distances from the site in kilometres to other nearby installations and their approximate orientation with respect to Sellafield are Low Level Waste Repository (LLWR) Heysham Nuclear Power Stations Chapelcross Nuclear Power Station (ceased operations in 2004) Westinghouse Springfields (fuel manufacturing) 5 km SE 60km SE 70 km N 80 km SE The countryside immediately around the Sellafield site is mainly utilised for farming or residential purposes. There are no significant industrial establishments within 5 km of the Sellafield site; the nearest significant establishment in the chemical and allied industries is a contract manufacturer and processor of custom chemicals at Workington (32 km north). The gas platforms in Morecambe Bay are, at nearest, 50 km away and gas from the field is landed at Barrow (38 km southeast). The nearest military site is a firing range at Eskmeals (15 km south). The volume of aircraft traffic in the Sellafield area is low. The nearest airports are at Carlisle (70 km north) and Barrow (40 km south) neither of which presently represents significant commercial activity locations. All aircraft (commercial, military and general) are restricted from flying at a height of less than 2200 ft within a circle of radius 3.7 km around the Sellafield site. April 2012 Page 13 of 65 SELLAFIELD Figure 1.2 Sellafield location 1.3 Site radiological inventory Detailed inventories of all radioactive materials and wastes are published every three years. The most recent - UK Radioactive Waste Inventory Report 2010 - is available on the NDA website [5]. April 2012 Page 14 of 65 2 Systems for providing or supporting main safety functions Nuclear safety is a key aspect of all operations (see Figure 1.3) on the Sellafield site. Safe operating conditions are ensured by keeping all nuclear materials contained and controlled at all times, i.e. maintaining containment; maintaining cooling; preventing criticality with fissile materials; controlling chemical reactions that could challenge containment; and controlling discharges; and personal behaviours in which it is incumbent on all personnel to make high quality, safe decisions when faced with uncertain operating conditions. Improved Safety Margins achieved through Operational Nuclear Safety Focus Noncompliance Safe Operating Envelope as defined by Operating Rules Figure 1.3 The Operating Envelope Model Defence in depth is maintained through multiple barriers each of which must be treated as if it were the only one, i.e. prevention o design of facilities/equipment, e.g. geometrically safe fissile material vessels; protection o provision of engineered protective systems, e.g. hardwired trips and interlocks; o provision of operational controls, e.g. visual monitoring and operating instructions; and mitigation o provision of mitigating systems, e.g. ventilation systems and air monitoring. April 2012 Page 15 of 65 2.1.1 Reactivity control Reactivity control, i.e. the avoidance of a criticality in a Sellafield nuclear context, is ensured by the safe geometry, safe mass and spacing or moderator content. The potential loss of any one of these controls is compensated for by application of the ‘defence in depth’ approach in basic design. In general, an on-site criticality cannot lead directly to an off-site dose to the critical group in excess of 5 mSv although it is noted that the much higher on-site doses would inevitably place significant demands on site emergency arrangements and significantly impede some recovery options. CONSIDERATION 1: provide local neutron inhibiting materials for emergency deployment to prevent/halt a potential criticality excursion 2.1.2 Heat transfer from reactor to the ultimate heat sink Although there are no operational reactors at Sellafield, for which heat transfer from reactor to the ultimate heat sink (UHS) is directly relevant, it is noted that there are a number of plants which rely, because of the self-heating properties of the materials handled, on some type of forced water/air cooling so as to prevent an off-site release of radioactive material. High Active Liquors High Active Liquors (HAL) in High Active Storage Tanks (HASTs) and process vessels are cooled by in-situ cooling coils and jackets supplied by diverse cooling water networks. Each HAST contains several internal cooling coils, both horizontal and vertical (see Figure 1.4). Heat from liquor stored in any of these tanks is removed by circulating cooling water between the operational cooling tower through the coils and back to the tower. To prevent activity breakthrough into the cooling water system, cooling components (other than evaporator coils and jackets during heating/cooling changeover) are operated with waterside pressure higher than the maximum process side pressure. Each HAST has more than one monitoring pot and a monitoring pot alarm system which is set to trigger the auto valves to close on alarm. All monitoring pots and their alarm systems must have a constant cooling water flow through them. The water flowing through the coils, as indicated by flowmeters, is maintained at flowrates which regulate the liquor temperature such that it is above the crystallisation temperature and below the upper limit requirements. A working limit for the tank liquor temperature is imposed in order to give a margin of safety between normal operating temperature and the maximum permitted temperature. CONSIDERATION 2: review the arrangements for providing alternative sources of cooling water to HASTs in extreme circumstances April 2012 Page 16 of 65 Figure 1.4 Photograph illustrating internals of HAST Magnox fuel Magnox fuel in loaded flasks, skips and magazines is either kept immersed in water or, when exposed, kept wetted using installed water sprays within the process cells. Oxide fuel Oxide fuel fines in process vessels are kept wetted by the process liquors. Product and residues Canned product and residues are cooled via either forced or passive (i.e. reliant on natural convection) ventilation depending on the design of the store. Any such ventilation can often be re-configured as necessary, i.e. via dampers or removal of plugs, or else supplemented by local fans. However the off-site consequences of a prolonged loss of cooling are much less than 10 mSv to the critical group therefore product and residue cans are not discussed further in this report 2.1.3 Heat transfer from spent fuel pools to the ultimate heat sink (UHS) Sellafield has seven fuel storage ponds; five ponds are operational and two ponds are non-operational legacy facilities but still contain fuel inventories. Studies undertaken to identify fuel pond dependency on utilities, such as power, cooling, steam etc., have established that four of the ponds have no requirement for cooling due to either a very low fuel heat loading and/or very long term (greater than twenty years) cooled fuel. The remaining three ponds have pumped cooling water circulation. Bounding calculations undertaken to consider fuel heat loadings and the associated thermal challenge to the pond have established that, in a ‘loss of cooling water’ scenario, it is possible for the residual heat loading (range 1.2 to 1.7 MW) of the fuel to heat the pond to boiling point. However it is concluded that in practice, with the current inventories, the ponds will not reach 100 C. On this basis evaporative losses will reduce water levels relatively slowly (i.e. over several weeks). Therefore maintaining fuel cooling is only likely to be an issue if there was a significant loss of water resulting from a breach of the pond floor or walls. Hence there are no offsite consequences resulting from a loss of pond cooling for at least seven days provided that water cover can be maintained. April 2012 Page 17 of 65 2.1.4 AC power supply 2.1.4.1 Off-site power supply The Sellafield site is a node connection point on the 132 kV District Network electrical grid in West Cumbria and benefits from several supply connections to the national grid network. These lines are configured in pairs with each pair supplied from an independent grid supply and using different pylon routings. Any single 132 kV grid connection can supply the entire site electrical load. Additional lines deliver power to Sellafield from the adjacent Fellside Combined Heat and Power (CHP) plant. However Fellside is not self-sufficient; it requires at least one of the 132kV grid connection lines to start-up and/or to continue to operate. Therefore Sellafield cannot operate in an “island” mode with supplies from Fellside alone. Off-site supply routes are to standard District Network design. The diverse sources of the lines ensure that grid disturbances are unlikely to affect all of the lines and it is policy never to have more than two of these feeder lines out of service at any one time for planned maintenance. Off-site power can fail for a number of reasons and sufficient operational history exists to evaluate the likelihood of such failures. There is no history of extreme seismic or weather events envisaged by these stress tests. Operational experience from sixty years of Sellafield operations shows no simultaneous failure of all electrical feeds to site. 2.1.4.2 Power distribution inside the plant On site a 132 kV substation feeds separately located pairs of 132/11 kV transformers, configured in segregated dual circuits, any one of which has the capacity to support essential site loads. The main feeds into site from the 132 kV substation are stepped down to 11 kV for site distribution in grid transformers (GTs); two GTs supply redundantly each of the on-site primary substations and 12 MVA interconnectors allow cross-connection of these primary substations such that any grid transformer can supply all essential site loads. Connections from the substations supply all other toplevel 11 kV substations. The Sellafield distribution system, which is therefore best described as two firm networks with interconnect ability, includes many substations, each employing two 11kV:415V transformers and associated connection cables (separated by at least 2 m, or physically protected/shielded, to protect against common damage from fire or excavation). The system incorporates more than 100 km of high-voltage cable. A duty Telecontrol computer monitors distribution system conditions, operates individual switchgear under operator direction and operates switchgear throughout the system using operator-selectable, pre-programmed schedules for a wide variety of distribution system operations. Telecontrol drives standby panels that compose a communications system to signal site status and electrical plant actions. A standby Telecontrol computer mimics the duty one and can take control in case of failures (error conditions) in the duty unit. The 132 kV system is not seismically qualified. Since the early 1980s all new 11kV substations have been designed to be operable following a design basis earthquake (0.25g) and are located above the design basis flood level (132 kV substation +26.1 mAOD; primary 11 kV substations +23.3 and +20.9 mAOD). April 2012 Page 18 of 65 The distribution system uses protection systems that discriminate between faults so that they do not propagate to other parts of the system. Most protection schemes follow old CEGB schemes; generally the system uses circuit breakers for 400 A and higher circuits and fuse switches for lower power circuits, although some fuse switches are used in circuits up to 800A and some oil-filled breakers remain. Local solid-state rectifiers at each substation provide DC control power for breakers located at that substation. Separate battery-backed DC power systems are provided for control and switching of the 11 kV Substations, for the 415V distribution substations and for the switchgear/load centers in the process plants (see Figure 1.5). Within a substation, 11 kV is stepped down to 415V to the Level 1 boards and fuse switches connect the Level 1 boards to the essential power distribution (EPD) boards, where battery chargers provide DC control voltage through additional fuse switches to the DC loads. Figure 1.5 DC control power standard supply arrangement 2.1.4.3 Main ordinary on-site source for back-up power supply Normal AC power could be lost to the entire site, affecting all facilities, by the loss of off-site power or multiple failures in the incoming substation or to an individual process plant by selected failures within the on-site distribution network. Therefore regular reviews of standby power generation requirements are undertaken. In the highly unlikely (yet possible) event of zero national grid supply/connections being available, the site has adequate fixed emergency 11 kV electrical generation, in the form of diesel alternators (DA) and gas turbine generators (GTG), to satisfy safety demands. A few on-site facilities also have fixed emergency generators installed for the same purpose. The DAs and GTGs are directly connected to the on-site electrical distribution system and are designed to feed essential plant distribution systems in each of the sensitive facilities across the site. These generators are tested regularly at full load and the arrangements to re-establish essential power supplies to all sensitive Sellafield plants were exercised successfully (as far as possible without exposing the site to unnecessary risks) in April 2011. April 2012 Page 19 of 65 The PRISMIC computers control any combination of DAs and GTGs. The operator can select the priority for starting the standby generators and can set a differential between what is running and current electrical load or else demand that all of the generators run. During loss-of-grid events, the duty Telecontrol distribution management computer and the duty PRISMIC power management computer assist the operators in restoring electrical power to site, i.e. the former signals plant standby control panels that the grid has been lost and runs Emergency Switching Schedules (ESS) and the latter then primes and runs up the DAs. Telecontrol then uses fixed software schedules to ensure early restoration to important loads, to geographically spread restoration and to take credible steps to increase load and ensure the stability of restoration. The approach provides some diversity and can be revised as site priorities change. The general order for restoration of loads is to site utilities (as they provide fixed loads and are needed by all plants), to highest-risk priority systems and then to additional loads in priority order. Currently one or more of the site air compressors are normally used as the base load when starting the standby generators. In reality all plants requiring emergency power from central generation should have their electricity back in a timely manner thereby allowing UPS etc. to recharge and instruments to reboot before the individual plant instruction to start a large load. The DAs and the GTGs are housed in separate locations; it is unlikely that a single incident would disable all DAs and/or GTGs. The DAs are ‘black start’ design, i.e. self-reliant for initial start-up. The DAs require compressed air to start, cooling water, fuel (gas oil) and 50 V DC supply to the control instruments to operate – each DA has an air receiver which holds sufficient air for multiple starts; cooling water is normally fed from the ring main; there is an emergency cooling water tank that can feed all four DAs; each DA has a dedicated ‘day tank’ to supply gas oil; and the 50 V DC supply is battery-backed. The DAs will power the primary 11 kV substation which will then feed other substations as per the agreed ‘Standby Power schedule’. The GTGs need power to start, i.e. they cannot ‘black start’, and operate. This is normally supplied from the primary 11 kV substation which is powered by the DAs. If this is not available then the GTGs can be powered by a mobile diesel alternator (MDA). In this scenario the GTGs would be configured to power the primary 11 kV substation. The GTGs do not require cooling water but they do require fuel (gas oil) to operate. Both the DAs and GTGs could be adversely affected by very high concentrations of atmospheric particulates. Each of the fixed DAs and GTGs will operate for several hours from their local reserve tanks without replenishment. However, even if sufficient DAs and GTGs start and accept load, power to process plants will have been interrupted and any electric-powered process equipment not powered from an Uninterruptable Power Supply (UPS) will stop. Essential safety, control and security systems are supplied from locally-based battery back-up UPS, designed to maintain this essential functionality until the site emergency power supply is re-established. April 2012 Page 20 of 65 On grid failure there are significant fuel supplies in on-site storage tanks to last for several days. Under normal circumstances the fuel supply contractor can respond with a tanker delivery within forty eight hours (i.e. well within the duration of the on-site reserves) with further deliveries being required daily thereafter. There are further significant potential fuel supplies at the Fellside CHP plant. CONSIDERATION 3: review the arrangements for management of site fuel stocks CONSIDERATION 4: procure a bowser/road tanker capable of transferring fuel efficiently around the site 2.1.4.4 Diverse permanently installed on-site sources for back-up power supply Fellside CHP Fellside CHP plant provides both high and low pressure steam and ~170 MW electricity supply to both Sellafield and the national grid. However Fellside CHP plant was never designed to operate independently; it is not self-sufficient and requires at least one of the 132 kV grid connection lines to start-up and/or to continue to operate. Therefore Sellafield cannot operate in an ’island’ mode with supplies from Fellside alone. It would not in any case be practicable to operate the CHP plant independent of the grid with only Sellafield as its electrical load. The Fellside CHP site includes on-site fuel storage. At times of national grid failure CHP gas turbines would not be operating and the CHP auxiliary boiler does not operate on fuel oil. In future this fuel stock would be the back-up fuel for the Fellside boiler park following loss of the CHP gas supply. The CHP fuel stocks could therefore also be used to supplement site supplies and provide a few weeks of fuel supply. Mobile Diesel Alternators in the unlikely event that the highly redundant and diverse normal and standby power systems fail, Sellafield also maintains a fleet of mobile, trailer-mounted, 415 V diesel generators (MDAs), ranging from 50 kW up to 1 MW capacity, some of which have synchroscopes and are hence capable of synchronising to live circuits. The MDAs are housed in diverse locations across the site, all of which have been assessed as able to withstand a 0.25g seismic event. The MDAs can be connected to engineered input points clearly-labelled and located on the outside wall of a plant and these external connectors are wired to an in-plant EPD via fuse switches (see Figure 1.6). MDAs are managed by Site Utilities with the capability to deploy an MDA in a timely manner, allowing for the discovery of power failure, transport and hook up of the MDA itself. However this specifically does not recognise simultaneous and competing demands for the same personnel arising from an SBO, the need to deploy several MDAs and/or unfavourable transport conditions arising from a severe event and/or severe weather conditions. Further resourcing would also be required to ensure maintaining adequate levels of diesel fuel in MDAs and fixed generators and boilers. April 2012 Page 21 of 65 Figure 1.6 Arrangement for attaching MDA to site buildings CONSIDERATION 5: review the manning levels required to respond to prioritized site demands during a major event The MDA connection points on primary buildings are inspected frequently and have recently had identification and phase labeling renewed. Some plants have completed a full deployment and connection of an MDA to the EPD. MDAs are started weekly and periodically tested on load. CONSIDERATION 6: develop a programme to deploy, connect and test MDAs to EPD connection points routinely on safety significant plants 2.1.5 Batteries for DC power supply Within the process plants, important loads are protected against power interruptions by ’Guaranteed Interruptible’ (GI), ’Guaranteed Non-Interruptible’ (GNI) and ’Uninterruptible Power Supplies’ (UPS) – GI power supplies are derived from EPD and essential low-voltage distribution switchboards/distribution boards. GI power supplies provide good reliability, with a firm supply basis, and are guaranteed (by design and practice) to be restored within a few hours of total power supply failure. GNI power supplies are derived from a UPS (see Figure 1.7) and provide the best reliability. They are designed to see no power interruption resulting from power dips or loss of the main supply. They depend on the battery back-up time and whether the UPS is connected to an EPD switchboard (GI supply) or a ’normal’ power supply. Each critical plant has UPS within the facility and their own safety cases define the required battery capacity. Local UPS battery banks are stored in engineered racks in dedicated ventilated plant rooms located so as to provide protection from both internal and external hazards. The 415 V 50 Hz ‘A’ essential supply feeds a local charger which in turn charges the battery strings which comprise each battery bank. Mains back-up is provided by Reserve ‘B’ supply. Alternative means of recharging would necessitate a locallydeployed MDA. April 2012 Page 22 of 65 Figure 1.7 Typical UPS design in Sellafield process plants UPS supplies provide back-up supply to essential instrumentation (for control and/or monitoring purposes), as defined within plant safety cases, in the event of mains supply ‘A’ failure. Any additional dependencies are specified within plant safety cases on an individual basis. The only additional UPS functionality of relevance to these “stress tests” is that associated with the battery-backed fans to maintain ventilation for the wet storage of Magnox wastes. In the case of this additional ventilation UPS, a dedicated installed diesel alternator (DA) must be started if the fans are expected to operate from the battery supply so as to keep the batteries charged. April 2012 Page 23 of 65 3 3.1 Regulatory framework, license compliance and safety assessment Regulatory framework SL, like its counterparts in other industries and places of work in general, is required to comply with the Health and Safety at Work etc Act 1974 (HSW Act). The HSW Act places a fundamental duty on employers to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all their employees. It also imposes a duty to ensure, so far as is reasonably practicable, that persons not in their employment are not exposed to risks to their health or safety as a result of the activities undertaken. In determining whether any measures are necessary to reduce risk and achieve compliance with the HSW Act, employers must compare the sacrifice involved, whether in money, time or trouble, and the risk which would be averted by their implementation. Such measures should be implemented unless the sacrifice is grossly disproportionate to the risk that would be averted, i.e. risks must be reduced to a level that is as low as reasonably practicable (ALARP) [6] [7]. SL must also comply with the Nuclear Installations Act 1965 (as amended) (NIA65) which requires the licensing of sites for an indefinite term; each nuclear site licence is unique to its site. NIA65 allows ONR to attach to each nuclear site licence such conditions as it considers necessary or desirable in the interests of safety or with respect to the handling, treatment or disposal of nuclear materials. ONR also has power to add, vary or revoke conditions, so providing scope for the licence to be tailored to specific circumstances and the phase of the installation’s life. ONR has developed a standard set of 36 conditions [8] which are attached to all nuclear site licences. The licence conditions provide the basis for regulation by ONR. They do not relieve the licensee of the responsibility for safety. They are nonprescriptive and set goals that the licensee is responsible for meeting, amongst other things, by applying detailed safety standards and safe procedures for the facility. The arrangements, which a licensee develops to meet the requirements of the licence conditions, constitute elements of a nuclear safety management system. ONR reviews the licensee’s licence condition compliance arrangements to see they are clear and unambiguous and address the main safety issues adequately. Procedures which comply with site licence conditions are likely to satisfy other requirements under the HSW Act which relate to nuclear safety hazards, e.g. the Management of Heath and Safety at Work Regulations. Furthermore the Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) establish a framework of emergency preparedness measures to ensure that the population local to the site is informed and prepared, in advance, about what to do in the unlikely event of a radiation emergency occurring and provided with information if a radiation emergency actually occurs. REPPIR places obligations on the licensee to produce an emergency plan for dealing with any reasonably foreseeable radiation emergency, as well as providing prior information to the population around the site. REPPIR also places duties on the local authority in whose area the site is based, to prepare (and if necessary, implement) an offsite emergency plan for dealing with the consequences of any reasonably foreseeable radiation emergency in an area determined by ONR. The local authority is also required to ensure that relevant information is supplied to the affected population in the event that a radiation emergency should occur. April 2012 Page 24 of 65 Other relevant legislation is contained in the Management of Health and Safety at Work Regulations that require, among other things, a suitable and sufficient risk assessment, and in the other regulations made under the HSW Act, e.g. Provision and Use of Work Equipment Regulations; Lifting Operations and Lifting Equipment Regulations; Personal Protective Equipment at Work Regulations; Pressure Systems Safety Regulations; Control of Major Accident Hazards Regulations (as amended) and Dangerous Substances and Explosive Atmospheres Regulations. SL must comply with these regulations in the same way as any other employer, and the codes of practice associated with these regulations will often contain relevant good practice that can be used in safety cases when demonstrating what is reasonably practicable. Not all relevant legislation is covered by the HSW Act. Other examples include the Anti-Terrorism, Crime and Security Act 2001 and its subordinate Nuclear Industry Security Regulations, the Electricity Act 1989, the Environmental Protection Act 1990, the Radioactive Substances Act 1993, various planning acts and the Building Act 1984 and its subordinate Building Regulations. 3.2 Compliance of Sellafield with its current licensing basis Nuclear Site Licence Condition (NSLC) 14 requires “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 phases of the installation.” The Safety Case covers all activities on the site, the hazards associated with these and the safety measures, whether engineered or procedural, necessary to protect against or mitigate these hazards. The Safety Case defines “conditions and limits necessary in the interests of safety” on plant operation; these form the Operating Rules (NSLC 23) which are implemented in accordance with operating instructions (NSLC 24). By operating within these limits and conditions, the so-called ‘safe operating envelope’, it is shown that risks are adequately controlled and that safety significant issues have been addressed. NSLC 28 requires “adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety”, i.e. safety systems and components designated within the Safety Case, so as to ensure that they remain available and able provide their claimed safety function. All such plant are registered within Plant Maintenance Schedules (PMS) which both prompt and retain adequate records (in accordance with NSLC 25) of the EIM&T; civil structural inspections are carried out in accordance with defined asset care schedules. NSLC 12 requires “adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site” and “the appointment, in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety.” Such persons will be suitably trained in accordance with NSLC 10. NSLC 11 requires “adequate arrangements for dealing with any accident or emergency arising on the site and their effects.” Such arrangements also encompass the specific requirements of REPPIR. NSLC 22 requires “adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.” Such modifications must be classified according to their safety significance. NSLC 15 requires “adequate arrangements for the periodic and systematic review and reassessment of safety cases” to ensure that the cumulative effects of operating experience, plant modifications and plant ageing, are considered in totality. Such April 2012 Page 25 of 65 Periodic Safety Reviews are undertaken on a ten-yearly cycle and present an opportunity to re-evaluate existing plants against modern design standards (e.g. seismic) as well as to review estimates of external hazards (e.g. magnitude frequency values, data and methodological developments and consideration of climate change) and their impact over the remaining lifetime of the facilities. L99 are a set of “understandings” between SL and ONR, established since the joint Licensee/Regulator initiative which commenced in 1995 (commonly referred to as ‘Winter Seminar’), which are “binding on both parties” and provide guidance on specific aspects of safety and engineering analysis required to produce an adequate safety case in accordance with NSLCs 14 and 15. The Sellafield Ltd. Management System (SLMS), underpinned by the SLMS Compliance framework, details the arrangements for compliance with these requirements. 3.3 Potential deviations from the licensing basis and actions to address those deviations SL use ‘Mandatory Assessments’ to investigate potential safety shortfalls resulting from on-site or off-site operating experience feedback and initiate appropriate actions to address such shortfalls. Furthermore, as a member of WANO, SL responds to Significant Operating Experience Reports (SOERs). Following the Tohuku earthquake, SL has provided specific responses to WANO SOER 2011-2 Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami; and WANO SOER 2011-3 Fukushima Daiichi Nuclear Station Spent Fuel Pool/Pond Loss of Cooling and Makeup SL is currently considering its response to WANO SOER 2011-4 (draft) Extended Loss of All AC Power Actions in Response to the Fukushima Daiichi Event. The work undertaken to date, as detailed within this report, has identified no potential deviations from the licensing basis. 3.4 Scope and main results of Probabilistic Safety Assessments In order to develop a safety case(s) for nuclear operations it is necessary to undertake safety analysis. Such analysis is key in identifying initiating events and event sequences that might contribute significantly to risk, providing realistic quantitative measures of the likelihood of the risk contributors, providing a realistic evaluation of the potential consequences associated with hypothetical accident sequences and providing a reasonable risk-based framework for making decisions regarding siting, design and operation. Three forms of analysis can be used to establish a safety case for fault and accident conditions: design basis analysis (DBA), probabilistic safety analysis (PSA) and severe accident analysis (SAA) – DBA is focused on the key safety measures for those initiating faults that are most significant in terms of frequency and unmitigated potential consequences; PSA looks at the full range of fault sequences and allows full incorporation of the reliability and failure probability of the safety measures and other features of the design and operations; and April 2012 Page 26 of 65 SAA considers significant but unlikely accidents and provides information on their progression, both within the facility and also beyond the site boundary. For many years SL used PSA, and comparisons with a set of radiological risk criteria, as the principal means for demonstrating the adequacy of safety of non-reactor nuclear plant. The relevant radiological risk criteria were defined essentially in such a way that the overall risk from a plant, if the criteria were satisfied, would be at the ‘broadly acceptable’ level; there was in addition, an overriding obligation to demonstrate that any residual risk was ALARP. For operational plants the outcomes of these assessments were reported in fully developed Safety Cases (fdSCs). Whilst there had always been an element of deterministic assessment of safety, this had not been by use of any formal analysis technique. However, in the late 1990s, the requirement to demonstrate the adequacy of safety by means of a formal, structured, deterministic method (in addition to the use of PSA) highlighted some degree of noncompatibility between the deterministic and probabilistic approaches and identified the need for changes to the method in use for the design of safety measures. For operational plants, the outcomes of these assessments were reported in Continued Operation Safety Reports (COSRs). Fault modelling and risk analysis is an important contributor to safety cases for nuclear chemical plant. A wide variety of hazard identification techniques are well established in the nuclear and chemical industries. Plants design, assessment of continued operations, plant modifications and decommissioning studies all extensively utilise HAZOPs (HAZard and OPerability studies) as a key part of the safety assessment process. Risk analysis is then undertaken leading to the identification and determination of fault sequences utilising the initiating events identified by HAZOP to potential outcomes. Consequences are determined using data from plant inventories and release fraction models. Fault frequencies are estimated using both site specific and generic reliability data using fault and event trees as appropriate. The safety assessment process includes the identification of safety measures or barriers to the fault progression. Design-basis and probabilistic analysis is required to demonstrate that deterministic and risk criteria are met. Data and tools are needed for fault analysis include initiating event frequency data, failure probability data for safety systems, fault and event tree analysis, dependent failures analysis and human reliability analysis. These tools and techniques have been developed by SL over a twenty year period. Nuclear facility safety cases must also demonstrate adequate robustness against both natural and man-made external hazards. The most significant hazards are considered to be earthquake, extreme weather (especially wind and flooding) and aircraft crash. SL currently uses sophisticated, largely deterministic, methods to analyse plants for the effects of external hazards. Natural phenomena more extreme than those experienced on a day-to-day basis have the potential to challenge safety systems protecting against radiological (and other) consequences and so generate risk (see Table 1.1). SL standards require that their effect on the safety of plants and processes is assessed and that the risks are shown to be tolerable, ALARP and not disproportionate against risk from other sources. An important aspect of natural hazards is that unlike man-made hazards and plantinitiated faults, they can affect a whole site and the surrounding district at the same time. April 2012 Page 27 of 65 Hazards that could sensibly affect the site fall into two distinct categories – Sudden energetic hazards (e.g. earthquake, extreme wind, flooding and precipitation) capable of inflicting severe damage on structures and potentially leading to radioactivity release in a time-frame too short to allow significant operator intervention. These may require some measure of numerical or probabilistic assessment. Slower acting extreme natural effects (e.g. extreme temperature and snowfall) that do not act in a dynamic fashion but which could cause failures leading to radioactive consequences if a plant had insufficient engineering safeguards or if pre-defined operational intervention to counter the hazard was not carried out. These require consideration of the deterministic adequacy of engineering provisions and the possibility of control of consequences by operational means (i.e. responding to weather forecasts). Hazards requiring full treatment in all safety cases Generic Hazards affecting the Site but not uniformly (Consider in individual plant safety cases as appropriate) Natural Earthquake shaking, Extreme wind, Extreme high and low temperature, Snow loading, Aircraft crash, Failure of adjacent structures. Flooding (rainfall), Flooding (river), Flooding (marine), Snow, hail, ice, frost. Man-made On-site transportation, storage and handling of hazardous substances, On-site missiles, projectiles, On-site fire/explosion, Vehicle impacts, Flooding from man-made sources. Low Significance Hazard: do not require to be considered in individual plant assessments Acceptably remote, nonprobabilistic or prevented by design or operational measures Tsunami, Seiche (oscillation of waterbody), Seismically induced changes in river or ground water flow, Landslide/ avalanche, Soil shrink/swell, Off-site fire, Meteorites, Coastal erosion, Drought, Natural methane, Off-site transportation, storage and handling of hazardous substances, Off-site missiles/projectiles, Military activity, Mining, quarrying, tunnelling, Agricultural activity, Pollution of water supplies. Hazards Prevented by Engineering Safeguards and Operational Arrangements Not credible Volcanic activity, Glaciation/ice cover, High/low sea temperature, Seaweed, fish, Marine pollutants. Construction activities, Electro-magnetic interference, Lightning, Fog, humidity, Water table, Insects, birds, rodents, other animals, Sandstorm, Coastal atmosphere, Aquatic debris. Table 1.1 Potential external hazards for Sellafield Whilst for existing plants that pre-date extreme hazards design, tolerability may be judged against a 1 in 1,000 year event, the primary level of intensity hazard against which assessment is required is that corresponding to an annual probability of exceedance of 1x10-4, i.e. the intensity with a 10,000 year return period. This applies regardless of the original design basis of the plant. This return period is adopted as the deterministic design basis, against which tolerability can be judged, because of the difficulty of predicting the relationship between probability and intensity for more remote events. The possibility of disproportionate risk from more severe events is addressed by searching for ‘cliff edge’ effects beyond the design basis level; a margin earthquake of 0.35g (3.4x10-5 per year level) is used for such ‘cliff edge’ analysis. Prior to the Tohuku earthquake, SL was already developing a better way to take account of beyond design basis earthquakes than this margin earthquake and will continue to do so. All Sellafield Limited Sites Excellence in Safe Operations Site Resilience Excellence in Security April 2012 Page 28 of 65 Excellence in Emergency Preparedness 4 Design basis Geological information on site The geological sequence at the Sellafield site comprises made ground deposits, quaternary fluvial-glacial deposits and bedrock (see Figure 2.1). Made ground – comprising disturbed, mixed and re-deposited natural ground and a proportion of building debris (e.g. brick, concrete, tarmac, wood, wire, plastic etc.) in a layer (ranging from less than 1 m to over 5 m) across the majority of the Sellafield site arising from a long history of repeated excavation, construction, backfilling and landscaping works. Quaternary deposits (drift) – comprising a sequence of unconsolidated gravels, sands, silts and clays which are very variable in thickness (maximum thickness of 74 m) and lithology from predominantly glacial and fluvial origins. Bedrock – comprising the Triassic Calder and Ormskirk sandstone formations of the Sherwood Sandstone Group (SSG); the deeper Permian, Carboniferous and Ordovician formations are not considered relevant. The SSG strata beneath the Sellafield area ranges in thickness between 650 m and 1150 m, (averaging at about 800m thickness) and dips towards the southwest with an average inclination of 25. Figure 2.1 Geological description of the Sellafield region April 2012 Page 29 of 65 4.1 Design basis earthquake (DBE) The extent of seismic qualification depends upon the type of plant or structure and its required performance. To determine how a plant will respond to a particular seismic event requires engineering parameters to be derived from seismological data such as earthquake magnitude, distance from the epicentre and ground motion prediction equations. Since about 1980, new plants built at Sellafield have followed company standards in respect of the seismic hazard. These currently require plants to be seismically qualified, i.e. designed to prevent earthquake-induced failures where such failure would otherwise lead to specified radiological consequence thresholds being exceeded. At present the DBE is one with a conservatively determined 1 in 10,000 annual probability of exceedance (equivalent to a ground acceleration of 0.25g); before 1983 it was 0.125g, and prior to that it was a quasi-static force of 0.1g. The oldest plants, which predate any seismic standards, were subjected to Seismic Damage Assessment (SDA) between 1985 and 1990 and this has indicated the likely extent of damage from earthquakes; the damage was estimated with a confidence level varying from the conservative side of mean and tending towards a 95% confidence in a 5% probability of not being exceeded. Some buildings that have been modified or extended therefore conform to a mixture of seismic standards. 4.2 Methodology used to evaluate the DBE Statistical analysis of historical data and expected frequency of DBE An appraisal of British earthquakes [9] concluded that seismic activity varied considerably from one area to another within Great Britain. This prompted a site specific study to quantify the seismic hazard at the Sellafield site which concluded that the Sellafield site is situated in one of the more seismic regions of Great Britain (see Figures 2.2 and 2.3). Figure 2.2 Seismicity (since 1650) within 100km of Sellafield April 2012 Page 30 of 65 Figure 2.3 Seismicity (since 1650) within 50km of Sellafield Further studies determined the confidence levels on the acceleration levels (see Table 2.1). Confidence levels 50% Best estimate (~ 70%) 75% 90% 95% British average 0.175g 0.186g 0.192g 0.212g 0.225g Sellafield site 0.227g 0.241g 0.248g 0.269g 0.283g Table 2.1 Confidence levels on seismic acceleration levels Calculations show that most of the risk results from moderate shallow-near field earthquakes close to the site. The annual probabilities of exceedance for various peak ground accelerations calculated based on several historical earthquakes considered for the Sellafield area are presented in Table 2.2. Peak Ground Acceleration Annual Probability of Exceedance 0.125g 1.1 x 10 0.24g 1 x 10 0.25g 0.87 x 10 0.35g 3.4 x 10 -3 -4 -4 -5 Table 2.2 Annual Probabilities of Exceedance for seismic events in the Sellafield area Therefore the adopted site seismic hazard levels conservatively adopted for Sellafield are as presented in Table 2.3. April 2012 Page 31 of 65 Description Intensity (pga) Return period Comments Operating Basis Earthquake 0.05g 1 in 50 years Plants must shutdown and carry out and inspection before restart. Old Plant design criteria 0.125g 1 in 1000 years Design criteria used for relevant plants which pre-date the New Plant design criteria. New Plant design criteria 0.25g 1 in 10,000 years Design criteria used for relevant plants from the early 1980s onwards. This also requires assessment against a 0.35g ‘cliff edge’ event to demonstrate robust design. Table 2.3 Sellafield Site seismic hazard levels These design parameters are further illustrated and contextualised in Figure 2.4. There have been a range of seismic hazard studies at the Sellafield site over the last 20 years with the most recent being the detailed studies for the possible construction of the then (1998) new-build NPP and the NIREX Repository. These reaffirm that it remains appropriate to use 0.25g peak ground acceleration as a 10 -4 per annum hazard; this conclusion was endorsed in an independent assessment for ONR. Further confidence is provided by the fact that these levels are equal to the highest levels for the design of UK dams [10]. Studies initiated shortly prior to the Tohuku earthquake show that there is an arbitrary and unnecessary conservativism between SL’s design spectra and the design spectra corresponding to a 10-5 per annum probability of unacceptable performance. The conservatism varies between 1.2 and 2.0 over the response frequency 1 to 12 Hz that is most likely to cause structural damage. An outcome of this work is that the facilities designed to SL’s current standards have less than a 10-5 per annum probability of failing to meet their specified seismic performance criteria. This gives confidence that both modern and older facilities could in reality withstand earthquakes significantly beyond the levels herein specified. April 2012 Page 32 of 65 Figure 2.4 Earthquakes – a guide to size, examples, effects and design parameters. April 2012 Page 33 of 65 4.2.1 Provisions to protect the plant against the DBE Studies of the predicted seismic performance of the Sellafield site concluded that a number of buildings would be subject to varying degrees of failure during a severe seismic event. However recent analysis indicated that the majority of plants would either be able to achieve a safe shutdown state in the event of a DBE or else result in off-site consequences below the RESEP threshold of 10 mSv to the critical group. Significant work is already being undertaken to reduce the risk for high-hazard plants – processing and/or transferring of materials into more seismically-robust wasteforms and/or stores; and improved containment, encapsulation and seismically-qualified liquor recovery systems. The safety case process requires that key structures, systems and components (SSC) are identified and their safety functionality substantiated to the required level of confidence. Discussion of all SSC across Sellafield plants that are required for achieving safe shutdown state is therefore inappropriate within this report. Instead discussion is limited to the following materials wherein the associated plants have SSC that are required for achieving a safe shutdown state and for which their loss during an earthquake would result in off-site consequences greater than 10 mSv to the critical group. Magnox waste Magnox waste in wet storage evolves hydrogen as it corrodes and hence hydrogen must be continually dispersed via forced ventilation systems. Following loss of ventilation a build-up of hydrogen to explosive levels and subsequent deflagrations could defeat the integrity of primary containment and lead to loss of liquor to the environment. A 0.25g earthquake would almost certainly result in failure of SSCs relating to ventilation systems as well as potential damage to the fans themselves and associated battery-back-ups. Furthermore, although it is anticipated that any breaches in primary containment will be within the capacity of the existing recovery systems, there is an implicit reliance on the availability of such systems. CONSIDERATION 7: enhance the robustness of the forced ventilation system for Magnox wastes to a severe seismic event CONSIDERATION 8: review the potential for trapped hydrogen with the Magnox waste matrix being liberated as a result of a severe seismic event High Active Liquors High Active Liquors (HAL) within storage tanks (HASTs) are cooled by in-situ cooling coils and jackets which can be fed from a number of diverse sources including the River Calder. Under normal operating conditions cooling water is circulated via one of several cooling towers. The limited seismic response of some ancilliary plant and its likely collapse during a 0.25g earthquake (potentially damaging adjacent plant) would adversely affect the distribution of water, steam, compressed air and electricity necessary to maintain cooling to the HASTs. April 2012 Page 34 of 65 Magnox fuel Significant remedial work has already been carried out within the earliest Magnox fuel storage pond to ensure that breached pipework in the pond release material into a drain trench from which both water and sludge is then automatically detected and recovered to pond; all related pumps and generators are seismically-qualified. Water arising from smaller leaks could be returned to pond via compressed air sandpiper pumps. Therefore, although the pond walls will likely develop significant cracking sufficient to cause substantial leakage of water, this is extremely unlikely to result in a pond dry-out especially since the pond base lies below ground level, approximately equivalent to single skip stack height and bulk sludge levels in the main pond. Solid Waste Disturbance of sealed containers containing uranium or sodium within the waste could result in a local fire which could then spread and, if allowed to burn for several days, could lead to loss of containment and large aerial releases. To minimise this risk of a fire, the waste is retained under an inert argon gas blanket so as to keep oxygen levels below the lower flammable limit. The argon is supplied from independent systems which could remain self-sufficient for several weeks even at minimum argon stock levels. 4.2.2 Main operating contingencies in case of damage that could be caused by an earthquake and could threaten achieving safe shutdown state The Sellafield site has installed two seismometers, with alarm thresholds set at the Operating Basis Earthquake (i.e. 0.05g), that are linked to the British Geological Survey national network. As part of the arrangements, the British Geological Survey would inform Sellafield of all large distant events detected by the network. Hence, if there were to be an event with the potential to affect the site, early advice would be available to enable precautionary measures to be taken through modification of existing arrangements for marine flooding. Main operating contingencies in case of damage will vary according to plant and the critical safety function and may include – temporary containment, e.g. bunds, windbreaks, overbuilding/cover (e.g. with tarpaulin), sand/gravel, fixative sprays etc. temporary shielding, e.g. shield wall, earth, concrete etc.; criticality prevention, e.g. use of neutron inhibitor(s); and cooling, e.g. hosed water / local air ventilation as appropriate. 4.2.3 Protection against indirect effects of the earthquake Spent fuel storage ponds The most recent analysis indicates that spent fuel storage ponds would be expected to remain intact albeit, with the exception of the Magnox fuel storage ponds, with some new cracking and propagation of existing ones; any seepage would not be significant. In the case of the earliest Magnox fuel storage pond, previous assessments have considered the possible outcomes and there are already provisions for crack repair using dedicated repair plates, water containment, and various pumping systems. The success of these measures will then be dependent upon the position of the cracks/breaches and the loss rate. It should be remembered however that this pond is partially set below ground level and so leakage will be reduced somewhat as the level falls to a point just covering a single array of fuel skips and sludge levels. April 2012 Page 35 of 65 The later Magnox fuel storage pond was designed to prevailing seismic standards at the time. Subsequently a number of shortfalls have been identified in its seismic performance at 0.125g during COSR. These could result in leakage in the range 1100 m3/hour; from a 0.25g earthquake; a subjective assessment of potential leakage might be 10 m3/hour from each pond. Although this will not result in an off-site consequence greater than 10 mSv to the critical group it could potentially result in significant localised flooding with contaminated water. CONSIDERATION 9: obtain skid-mounted diesel pumps for potential deployment in the later Magnox fuel storage pond following a severe seismic event CONSIDERATION 10: review the robustness of alternative power supplies sufficient to allow timely crack repair (using already available dedicated repair plates, water containment and various pumping systems) following a severe seismic event Bridges Studies of the seismic resilience of the bridges over the River Calder, which connect the east and west sides of the Sellafield site, conclude that emergency vehicles and personnel would be still be able to use the bridges following a seismic event and that the bridge on the A595 at Calderbridge is also considered likely to be passable after such an event. Those bridges that have required seismic qualification to fulfil their safety functions have been assessed to an event with a return period of 1x10 -3 (0.125g) or 1x10-4 (0.25g). The latest study concluded that the probability of complete collapse of the bridges was very low, although some structural damage was likely (to lateral restraint guideplates, stone facing on abutments, damage to waterproof seals on expansion joints & bridge bearings). CONSIDERATION 11: seismically enhance existing bridges across the River Calder and develop the ability to deploy temporary structures 4.2.4 Other indirect effects (e.g. fire or explosion) 4.2.4 Magnox fuel The Magnox reprocessing dissolver is designed to shutdown safely under multiple scenarios both with and without UPS. However in the event of plant damage the resulting position of the dissolver, and hence its contents, is unknown and so the possibility of a dissolver fuel fire, due to overheating of the partially dissolved fuel rods following protracted exposure above liquor, cannot be discounted. Camera inspection, thermal imaging or alternative methods would need to be deployed to identify the condition of the dissolver and its contents; such methods would currently be dependent on SF&R and the ability to deploy personnel trained in wearing selfcontained breathing apparatus. Cooling water, from automatic gravity-fed supplies within the building, dry risers or via an alternative source, can be used either to feed through the dissolver’s cooling jacket, or to be applied directly into the dissolver from the Emergency Water Head Tank or alternative supply. As the fuel load could theoretically be self-heating (unlikely to be an issue at current batch sizes) this would have the added benefit of diluting the solution April 2012 Page 36 of 65 and thereby reducing the risk of any such self-heating; however detailed calculations on self-heating and quantities of water required are yet to be completed. CONSIDERATION 12: confirm realistic rates of self-heating within Magnox fuel undergoing reprocessing and the minimum quantity of water required to prevent self-ignition on potential loss of cooling Solid waste As discussed previously, disturbance of sealed containers potentially containing uranium or sodium within the waste could result in a local fire which could then spread and, if allowed to burn for several days, could lead to loss of containment and large aerial releases. In the event of such a fire there are currently no specific contingency plans in place to extinguish the fire partly because of the emphasis on fire prevention and partly because of the difficulty in fighting such a fire were it to be allowed to progress. This difficulty arises with respect to fire fighting media, as water or foam may initiate a release of hydrogen and present an explosion hazard, nitrogen could support combustion forming nitrides, and CO2 can be reduced by burning Magnox which could then continue to burn in the absence of oxygen. Limiting/mitigating actions may include cooling the waste facility walls, extinguishing the fire using sand/concrete, preventing the fire from spreading using fire breaks or preventing contamination spread by covering the waste facility with a heat resistant sheet. CONSIDERATION 13: develop and substantiate specific contingency plans to extinguish a fire within solid waste facilities 4.2.5 Earthquake-induced flooding 4.2.5 Changes in river and ground water flows A secondary effect of a significant earthquake could be the initiation of land slips on unstable slopes above lakes or rivers upstream of site and alterations to ground water flow patterns. The closest major lake, Wastwater (~ 10 km due east of Sellafield) outflows along the River Irt, which flows southwest before discharging to the Irish Sea at Ravenglass (~ 10 km southeast of Sellafield); this route and the surrounding topography suggest that any resulting flow would be very unlikely to reach the Sellafield site. However the next closest major lake, Ennerdale, located ~20 km northeast of Sellafield, outflows into the River Ehen before discharging to the Irish Sea at Sellafield and therefore could conceivably affect the site if water were suddenly to be displaced from lake to river although any such pulse would be greatly attenuated by the time it approached the Sellafield site. The effects of abnormal water levels in the Ehen due to intense rainfall are discussed in Section 5. The River Calder runs, in parts of its higher course, in steeply-sided valleys and lengths of gorge. Slope failures in these areas could conceivably block or restrict the channel and lead to the hold-up of water behind potentially unstable barriers. April 2012 Page 37 of 65 Tsunami DEFRA concluded in 2005 [11] that the probability of a tsunami hitting the UK is extremely low and therefore the risks from tsunami are considered insignificant; this conclusion was reaffirmed in 2011 within the ONR ‘Weightman’ reports on the response to the Japanese Earthquake and Tsunami [1] [2]. There are also a number of local features that give confidence that risk of inundation of the Sellafield site by tsunamis is extremely low The coastline in the vicinity of the site is open without marked inlets or bays where local effects could interact with successive tsunami waves and amplify their height. The Irish Sea is a fairly shallow area compared to the deep ocean to the north and south. Therefore, any tsunami waves entering the Irish Sea would tend to be slowed, increasing their height and the rate at which their energy is dissipated as they travel through these shallower waters. A relatively deep channel exceeding 100 m in depth (with a maximum of 315 m) runs through the west of the Irish Sea connecting to the Atlantic Ocean via St. George’s Channel to the south and North Channel/Malin Shelf to the north. It is considered that the main energy of any tsunami wave entering the Irish Sea would tend to be focused along and through this channel. In contrast, the waters in the eastern part of the Irish Sea are significantly shallower, being less than 50 m deep in general. There are no submarine features, such as east-west running canyons, which would tend to focus the tsunami energy towards Sellafield. Those canyon-like features that do exist run parallel to the coast and are located several miles offshore. It is therefore concluded that there is a very low risk of inundation to safety-related facilities at Sellafield for all credible sources of tsunami. Seiche The only water body whose overflow, caused by surface disturbance (i.e. a seiche), could conceivably affect the Sellafield site is Ennerdale as discussed previously. Nearer water bodies such as Brow Top Reservoir, Meadley Reservoir, Rowrah quarry and Lingbeck (Ponsonby) Tarn are small and would not present a hazard to the site if subject to a seiche. April 2012 Page 38 of 65 5 Flooding Hydrology Sellafield is located within the surface water catchments of the Rivers Calder and Ehen. The River Calder catchment, including its subsidiary stream, Newmill Beck, has a total area of 55.5 km2, while the River Ehen catchment has a total area of 156.6 km 2. The site is located at the down-gradient end of the River Calder catchment. The River Calder flows through the site in a south-southwesterly direction and forms a natural barrier separating the west and east areas of site. A section of the River Calder was realigned in 1974-5 and was designed to convey a rate of flow of 310 m3/sec arising from a 10,000 year flood (as then assessed). Since its realignment, the river has scoured out a deeper bed for itself, thus lowering the bed level by up to 1.5 m and increasing in its flow capacity. The River Ehen flows in a south-southeasterly direction along the southwestern site boundary, where it merges with the River Calder before flowing across the beach to discharge into the Irish Sea. Newmill Beck flows around the southeastern corner of the site, where it has been culverted to divert its flow around a licensed landfill and beneath the coastal railway line. Beyond the railway, it feeds two small ponds above the high water mark at the beach before discharging, via another culvert, into the River Calder. The site slopes gently from its inland boundary towards the coast with a decrease in ground elevation from approximately +40 mAOD to +9 mAOD. Two additional minor streams flow into the River Calder at Sellafield. Seaburn Beck drains into the river from its western side and flows through the northern end of Sellafield. The second is an unnamed stream that drains towards the river from its eastern side and flows through the site, although it does not discharge directly into the river. Instead it is intercepted and drains to the Irish Sea via an offshore pipeline. Both streams are partly culverted within the site boundaries. The location of the culverted section of Seaburn Beck has been modified several times since 1946. Analysis of seasonal river flow hydrographs for the Rivers Calder and Ehen indicates that they respond relatively rapidly to rainfall events due to the steep topography and rapid surface runoff in the catchment headwaters. Consistent flow to the river channel from groundwater is observed throughout the year, although baseflow indices are likely to increase between catchments as a function of the proportion of sandstone within that catchment. Flows through the Calder and Ehen vary seasonally, but typical averages are 1.5 105 m3 per day based on 1930 mm rainfall per year for the Calder, and 5.2 105 m3 per day based on 1750 mm rainfall per year for the Ehen. The coastline around Sellafield and further south comprises a sandy beach backed by low sparsely vegetated sand dunes and silted inlets. To the north the coast rises to St Bees Head where there are steep cliffs (about 100 m) of Triassic Sandstone. Groundwater abstractions Water is supplied to the Sellafield site from a variety of sources. Tidal patterns The maximum tidal range and tidal current are 8.4 m and 1.6 knots (0.82 ms -1, 3.0 km/hour) at spring tides and 3.3 m and 0.5 knots (0.26 ms -1, 0.93 km/hour) at neap tides. Tidal currents in the vicinity are approximately parallel to the coast (i.e. northwest). April 2012 Page 39 of 65 Normal tidal ranges are – Mean Low Water Springs -3.40 mAOD Mean Low Water Neaps -1.75 mAOD Mean High Water Neaps +2.10 mAOD Mean High Water Springs +4.00 mAOD 5.1 Design basis flood (DBF) Flooding, from whatever source, and extreme precipitation (except very significant snow accumulation) are generally unlikely to result in a structural failures due to overloading (though this may be relevant in a very limited number of instances where plant could be exposed to rapidly moving flood water and detritus). Normally the main concern is water gaining access to SSCs and dispersing radioactivity, affecting nuclear safety or interfering with the correct operation of CE&I systems. These issues are best addressed on a deterministic basis by examining the adequacy of the plant design and construction to resist the challenge presented by the extreme 1x10 -4 per year flooding event. Again, any possibility of consequences arising from a somewhat larger ‘cliffedge’ event should become obvious during the analysis. Work has been undertaken to determine which parts of the Sellafield site are at risk of flooding from wave/tidal action, extreme flows in the Rivers Calder and Ehen and extreme rainfall events on and local to the site. The site generally has adequate protection against external flooding with the only significant risk arising from extreme rainfall. However the nature of such occurrences are relatively low dynamic and extremely unlikely to result in the additional mechanical damage which arises from high dynamic events through the force of water and entrained debris. Tidal Estimated 10,000 year tides would be lower than the site topographical range (+9.00 to +48.00 mAOD) and therefore would not present a credible risk of flooding 10,000 year 7.39 mAOD 10,000 year + 1.5 m wave 8.89 mAOD Climate change (10,000 year 8.06 mAOD tide + 1.67 m wave) 9.73 mAOD River The estimated 1 in 10,000 year flow in the River Calder would be approximately 326 m3/sec as compared with the original design of the straightened river for 310 m3/sec. This presents a very slight but credible risk of fluvial flooding on the east bank at the upstream end of the Calder Hall site. However the topography of River Calder north of the site up to Calderbridge is likely to prevent any such flows through site. CONSIDERATION 14: consider the need to engineer additional flood defences alongside the River Calder Rainfall Following an extreme rainstorm with 0.01% probability of being exceeded in any year, i.e. a return period of 1 in 10,000-years, it was concluded that – The site slopes from north to south and surface runoff flows in this general direction. April 2012 Page 40 of 65 The major outflow points for the surface runoff are to the River Calder, across the railway at the southern extent of the site to the River Ehen and across the main road to Sellafield Tarn. The network of service trenches and ducts has sufficient capacity to convey the flow that they receive without any overtopping. However not all of these ‘ditches’ will be full and overland flow must occur before the water can enter the ditch system. Thus this considerable volume will not prevent some surface flooding but will provide significant storage. The central built-up area contributes a large volume of surface runoff that is in excess to the capacity of the dedicated drain water facility. Furthermore the initial volume of water in the facility and the pumping rate are important parameters in determining the timing and amount of surface run-off. The ‘one-hour event’ produces a larger flood outline in the northern areas of the site than the ‘two-hour event’. The flooding is generally deeper in the southern areas of the site during the ‘two-hour event’ compared with the ‘one-hour event’. The blockage of mesh fences up to a depth of 0.3 m by debris transported by the floodwaters has an impact on the flow routes and the extent of flooding on the site. CONSIDERATION 15: undertake more detailed modeling of surface run-off and drainage within built-up areas of the site CONSIDERATION 16: review the resilience of the current arrangements to pump out the central drainage water collection and discharge system CONSIDERATION 17: utilise the design of any future changes to the site infrastructure to direct rainfall flood flows so as to minimise ponding CONSIDERATION 18: re-engineer applicable flood defences to address very severe rainfall flooding CONSIDERATION 19: take local actions to address potential vulnerabilities to flooding of individual EPD boards and MDA connection points CONSIDERATION 20: consider the procurement of prefabricated flood barriers for local ad hoc deployment 5.2 Methodology used to evaluate the DBF The rainfall totals were estimated using the Flood Estimation Handbook [12] and two durations were considered, i.e. 124 mm and 148 mm rainfall depth for rainstorms of one- and two-hour durations respectively (see Figures 3.1 and 3.2); sensitivity to climate change was considered by increasing the estimates by 30% for each return period in accordance with DEFRA guidance [13]. Although the rainfall depth is greater for the longer storm the intensity of the shorter storm is much greater (35 mm h-1 compared to 24 mm h-1). These rainfall estimates, together with standard Summer April 2012 Page 41 of 65 rainfall profiles, were used as inputs into models of the subsurface drainage of the Sellafield site using proprietary software which was then used to show where the capacity of the sub-surface drains is exceeded and surcharging of manholes or culverts occurs. Such an intense storm with a return period of 1 in 10,000 years would be more likely to be caused by summer convective rainfall centered on the Sellafield site and this is in any case the recommended profile for generating design storms in built-up areas. The volume of water coming out of, or unable to drain into, the subsurface system will flow over the site governed by general topography, buildings, roads and other features such as the large surface ducts. The pattern of flooding for the two storms is similar, with more widespread flooding from the one-hour storm but increased depths predicted during the two-hour storm. More widespread flooding from the one-hour storm is experienced because the drainage system is less able to cope with the high intensity rain associated with the shorter storm and a greater number of manholes surcharge across the site . Figure 3.1 Rainfall depths and intensities of design storms CC denotes climate change Figure 3.2 Rainfall profiles for 1- and 2-hour duration storms with 10,000 year return period Parallel consideration of the river and tidal flood risk affecting the Sellafield site provides the boundary conditions for the surface and sub-surface modelling by determining whether the outfalls from the site were able to drain freely. A conservative study of the River Calder found that a 1 in 10,000-year rainstorm which encompasses the entire Calder catchment (see Figure 3.3) would likely prevent the free outflow at several of the outfalls discharging from the site. April 2012 Page 42 of 65 The river itself possesses a steep channel through the site and is relatively insensitive to tide levels. The tidal flood study found that most of the Sellafield site is above extreme tide levels and it is extremely improbable that a site-centered 10,000-year rainstorm, which is likely to occur during the summer, would coincide with extreme tide levels associated with winter storm surges; it could however coincide with a spring tide. Figure 3.3 Calder catchment area (red) and area of design storm (blue) External man-made sources The Brow Top Reservoirs are located ~2 km from the Sellafield site and at a higher elevation. On sudden failure, the contents of ~5000 m3 would drain into a stream which joins the River Ehen. The Meadley Reservoir above Cleator Moor would drain into the higher reaches of the Ehen. Abnormal events affecting the Ehen do not have the potential to affect the Sellafield site and therefore neither of these two reservoirs presents a credible hazard to the site. 5.3 Provisions to protect the plant against the DBF Localised flooding (due to failure of service lines, obstruction of surface water drains/run offs) of a small number of facilities (ground level switch rooms) could result in localised loss of power to safety systems and impede the connection of alternative power supplies (e.g. MDAs). Reference is made to current flood studies during new design and construction works at Sellafield so as to identify potential flooding issues and mitigate them through siting, finished floor levels and engineering of additional drainage works (e.g. a flood channel). Where flood risks are identified to existing plants, as a result of Periodic Safety Review and/or plant modifications, then such options are either no longer possible (e.g. siting and finished floor levels) or else become increasingly impractical (e.g. engineering of additional drainage works). Recourse would then be made to the retrofitting of flood protection (e.g. flood protection doors). April 2012 Page 43 of 65 Warnings of extremely high tidal surges or heavy rainfall which is likely to result in localised flooding will be issued by the Environment Agency, Meteorological Office or HM Coastguard to the S&SSM who will then relay the necessary warnings to building managers (via SECC) who will then take appropriate local action, e.g. onward briefing of personnel, closing of doors/louvres/windows, temporary bunding (using sandbags), protection of switchgear from water ingress etc. 5.4 Situation outside the plant, including preventing or delaying access of personnel and equipment to the site Recent experience [14] has demonstrated the vulnerability of the off-site infrastructure with severe damage to many roads (including the loss of significant road bridges) and the inundation of others as drainage was overwhelmed and surface water run-off flooded highways. This loss of functionality was soon compounded by traffic congestion throughout the day and very long queues on the diversionary routes which had insufficient capacity to accommodate the diverted traffic. It is therefore to be expected that there would be significant delays in access of personnel and equipment to the site. Such delays are anticipated within RESEP and form the basis of a sensitivity analysis in the resulting timelines. April 2012 Page 44 of 65 6 Extreme weather conditions Meteorology The site is adjacent to the Irish Sea on the southwest-facing stretch of the Cumbrian coastline. The foot of the Cumbrian Mountains lies some 2 or 3 km to the northeast, these mountains rising to a maximum height of 977 m on Scafell Pike, the highest point in England, 19 km to the east. The site therefore receives no shelter from the prevailing humid, often cloudy and rain-bearing, winds from the southwest but does receive strong shelter from north-northeasterly through easterly to southeasterly directions. As these are also the coldest wind directions in winter, this factor combined with the relative winter warmth of the adjacent sea, results in the relatively low incidence of frost and, particularly, snow. The duration of bright sunshine is estimated to average about 1460 hours per year. This is 33% of the maximum possible amount, December averaging 1.4 hours per day and June 6.5 hours per day. The annual average temperature in the period 1961-90 at Sellafield site was 9.4 C, interpolated from the UK grid data-sets. The time-lagging influence of the Irish Sea on the annual temperature cycle causes the warmest and coldest months to be delayed. August has a mean temperature of 15.0 C, which is slightly warmer than July, while February has a mean temperature of 4.4 C, which is slightly cooler than January. The average daily maximum and minimum daily temperatures in August are 18 C and 12 C respectively. Annually the warmest day typically is 24 C, but 30 C has been recorded with an estimated return period of about 30 years. The highest summer temperatures are likely with easterly winds, which have a long land track over both the Pennines and the Cumbrian Mountains. The average daily maximum and minimum temperatures in February are 7 C and 2 C respectively, the coldest night typically reaching as low as -4 C. Sellafield has its own meteorological station just outside the site fence at National Grid reference: NY02150455 which records wind speed and direction, daily maximum and minimum temperature, rainfall amount and sunshine duration. The information provided in this section is taken from data recorded at the Sellafield meteorological station and provided in reports written by Westlakes Scientific Consulting. Precipitation The rainfall data presented in this report is taken from the Sellafield meteorological station, 10 m above ground level. The average annual rainfall between 1961 and 1990 is estimated to be 943 mm - a high figure for a lowland area due to exposure to Atlantic and Irish Sea weather systems. There is a marked annual cycle in rainfall; autumn months typically yielding about twice as much rainfall as spring months (about 100 mm/month versus about 55 mm/month). The average annual number of ’rain-days’ (rainfall more than or equal to 0.2 mm) is 186 days with 26 of these days exceeding 10 mm. The rate of rainfall increases rapidly inland towards the mountains and exceeds 3000 mm/year near Scafell. Snow or sleet is estimated to fall on 18 or 19 days per year on average, but covers more than half the ground at 0900 Greenwich Mean Time (GMT) on only four mornings per year on average, mostly from December to March. Deep snow is rare; the greatest recorded depth in the nine years (1988-96) being 70 mm, though much greater depths exceeding 150 mm are possible on very rare occasions. April 2012 Page 45 of 65 6.1 Design basis Extreme weather hazards are assessed at a prescribed return frequency of 1 in 10,000 years in accordance with Safety Assessment Principle EHA.11 which states that “nuclear facilities should withstand extreme weather conditions that meet the design basis event criteria.” Some of the external hazards which nuclear plants are designed against are uncorrelated, i.e. they are independent of each other, whereas others (e.g. an earthquake and tsunami) are highly correlated. Equally some of the extreme weather hazards act in concert with each other, e.g. high wind and rain can often be seen to be semi-correlated, as can wind and snow. Energetic hazards Extreme wind analysis should consider the ability of the external shell of the building to withstand the wind-loading taking into account any dominant openings and, if the external cladding is not expected to resist the extreme condition, any dominant openings resulting from its failure. Depending on the outcome, the radiological implications of any anticipated structural failure, or disturbance to ventilation patterns, can be examined. The possibility of consequences from failures of nearby buildings should also be considered, e.g. stacks, collapse of structures, wind-borne projectiles. The assessment for extreme wind should be primarily based on 1x10 -4 per year conditions if the safety case makes this requirement. The appropriateness of a ‘cliffedge’ assessment should be obvious according to the margin-to-failure at the 1x10-4 level. For instance, massive concrete structures should not be expected to be at risk from any credible wind-loading whereas containment systems relying on clad steelwork frames might be to some extent. Reasoned argument may be able to provide a simpler but adequate demonstration of ALARP where margins to failure are large. This would be the only reasonable approach for older structures where failures were predicted for less extreme conditions than 1x10 -4 per year and the main objective was to seek improvements against ALARP. Slow-acting extreme hazards Extreme values of temperature (high or low), snow, frost or drought would only be reached at some time after the onset of abnormal weather, which in turn is unlikely to occur without some warning. These time factors may allow operational safeguards to be claimed against many of their consequences – protecting sensitive plant from heat or cold, removing snow or ice as it builds up, arranging alternative water supplies. This does not preclude the need to show, for instance by engineering analysis, that imposed loads from extreme snow accumulation could be resisted by a structure. Where safety-significant items are located inside the buildings where the thermal inertia and insulation properties of a building provide protection, this may also be claimed against the low temperature hazard. This may be relevant for instance in consideration of indoor SSC or the fatigue life of steelwork. 6.2 Weather conditions used as design basis Many of the identified weather conditions can occur in a variety of combinations. In the majority of cases it has been conservatively assumed that each of the design basis hazard levels can occur concurrently. April 2012 Page 46 of 65 There are already arrangements in place (managed by the S&SSM) to monitor the effects of extreme weather on the site in real time that provide assurance of the generally acceptable response of plants to such conditions, i.e. sheltering and/or evacuation via prescribed routes, conservation of resources etc. Extreme winds, tornadoes and hurricanes British Standards Codes of Practice are followed in the design and construction of plant at Sellafield. These design codes [15] [16] provide graphical information that can be used to determine the basic wind speed at any site when local records are not suitable and give further factors to account for local variations in exposure, altitude, height of structure, proximity of other buildings etc. For conventional design, a 50 year return period wind is adopted (reflecting building lifetimes). However further probability factors are given in the design codes to enable extreme wind speeds to be derived where more stringent design is required. The older design code [15], which determined the design of the majority of Sellafield plants, uses a three-second gust as a basis, i.e. 47 ms-1 (105 mph) and 66 ms-1 (148 mph) for 1 in 50 and 1 in 10,000 year gusts respectively. The new design code [16] is based on mean hourly wind speeds, i.e. 24 ms-1 (54 mph) and 30 ms-1 (67 mph) for 1 in 50 and 1 in 10,000 year gusts respectively. In both design codes, factors are given to enable the overall loads on structures and localised pressures on external features to be calculated and consideration to be given to dominant openings. SL often uses models for design purposes to determine local pressure effects and to check the validity and suitability of the design code approach on the heavily-developed Sellafield site. Site wind speed records are available for over fifty years at Sellafield and show a maximum gust (as recorded at the Sellafield Meteorological Tower) of 46.1 ms -1 (103 mph) in 2005. These records and other data sets have been used to predict extreme values for Sellafield but, for consistency with national practice, the BSI code data are used for design and assessment purposes. It should be noted that there is no history of major structural damage to plant due to strong winds at Sellafield, although there have been a number of incidents involving lesser damage to building cladding and construction sites. Tornadoes have the potential to generate wind speeds higher than the extreme conventional storms but are uncommon in the UK overall. A detailed study of 1,500 tornadoes in the UK [17] showed that events with localised wind speeds approaching 100 ms-1 (224 mph) have occurred and that the affected areas are relatively small, i.e. a few square kilometres with paths a few hundred metres wide for the largest event. It was therein concluded that the UK distribution of tornadoes is far from uniform because of meterological and geographical factors and they are much less frequent in northern England than further south. A tornado with a wind speed equivalent to the Sellafield 1x10-4 per year mean hourly wind has a probability of 5x10-6 per year; more intense events are increasingly less likely even than this. Lightning British Standards [18] provide guidance on lightning protection. It is considered that this hazard is primarily addressed by engineering standards and subsequent substantiation during LTPRs. April 2012 Page 47 of 65 Snow loading Information on the design of buildings to resist snow loading is given in BRE guides [19] and more recently BS6399 [16] which indicate a 50 year snowfall for Sellafield of 400 mm with a factor to convert this into a dead load. A multiplier (2.3) for estimating the depth corresponding to 10,000 years is also given. A further consideration is the susceptibility of drainage provisions to blockage by melting snow/slush resulting in ponding above the depth at which rainwater would escape. The extent of the hazard is dependent on the extent to which it is operationally practicable to clear accumulating snow from critical areas of structures. Note would need to be taken of the personnel safety implications of attempting this in what would clearly be extreme weather conditions. High and low temperatures Records of annual maximum and minimum temperatures from Sellafield since 1950 have been subject to several studies to predict extremes at long recurrence intervals. A recent study of data from 1950 up until the mid 1980s recommended values of +43 C and -24 C for the 10,000 year case based on a Meteorological Office analysis method. More recent assessments in support of Calder Hall/Chapelcross safety cases and new build NPP, using a method developed for the Sizewell B safety case, predicted 10,000 year extremes of +34 C and -16.2 C for Calder Hall. These may be compared with measured maxima and minima at Sellafield of +30 C and -12 C between 1950 and 1999; The most recent minima temperatures are Year Minimum Temp (C) 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 -7.6 -4.6 -2.4 -3.7 -3.8 -3.4 -5.3 -3.5 -3.8 -4.7 -7.6 Some consideration of the duration of sub-zero temperatures was made in the safety case for THORP where a 30 day average daily minimum temperature of -6.5 C was predicted at a 1x10-4 per year level. Climatic change may lead to an overall small increase in temperature but this is not likely to be sufficient to affect this extreme hazard significantly. Extreme temperatures may have implications for the behaviour of structural components, for the properties of process materials and for the ability to provide important heating or cooling as well as services/supplies. Extreme high temperature could be associated with drought and extreme lows with other winter phenomena. A further consideration for low temperature is the duration of abnormal conditions. Since the effect on water and other supplies is likely to be determined as much by the time below freezing point as by the actual minimum temperature reached during a cold spell. April 2012 Page 48 of 65 Extreme cold (and snow) may also have an effect on transportation and the safety of operating personnel, factors that may be relevant to radiological risk in some instances. However variations in indoor temperatures would be less extreme than outdoors, depending on the effectiveness of insulation and high volume airconditioning (HVAC) provisions, and even outside the average daily temperatures would be less than the daily maxima or minima. In any case, extreme temperatures will not occur unexpectedly and should allow for the timely introduction of operational safeguards. CONSIDERATION 21: take local actions to address the potential vulnerabilities of diesel stocks to protracted extremely low temperatures Drought Despite the maritime climate of the UK, extended periods of dry (or freezing) weather can occur and could lead to restrictions in supplies of water to the Sellafield site, particularly as a result of reduced river flows in the Calder and Ehen. This issue has been addressed in the past to ensure the adequacy of supply under drought conditions with a diversity of supplies available to the site. April 2012 Page 49 of 65 7 7.1 Loss of electrical power and loss of ultimate heat sink Loss of electrical power The diversity of supplies renders this scenario non-credible. Notwithstanding this, studies are currently in progress with ENW to explore the feasibility of providing equipment to effect a temporary direct connection of any one of the site 132/11 kV Grid transformers to the 132 kV overhead pylon system, thus creating the possibility to bypass many common mode and 132 kV node points of failure Furthermore work is already underway to supplement/replace the existing back-up onsite electrical generation system, to provide increased diversity (location/point of connection/control) and improved resilience to a range of external factors, thus creating the possibility to bypass common mode and node points of failure. 7.2 Loss of the ultimate heat sink (UHS) As discussed previously there are a number of plants at Sellafield which rely, because of the self-heating of the products, on some type of forced water/air cooling. High Active Liquors High Active Liquor (HAL) in High Active Storage Tanks (HASTs) and process vessels are cooled by in-situ cooling coils and jackets supplied by diverse cooling water networks. Conservatisms in the current safety case are extremely pessimistic so there are significant margins both in terms of time to respond to a total loss of cooling event or loss of individual cooling components. The safety case has recently been re-aligned to be based on this approach to spare cooling capacity. Magnox fuel Magnox fuel is self-heating and therefore the loaded flasks, skips and magazines must be kept topped up with cooling water. Whilst both flasks and magazines are fitted with engineered top-up points to which a water hose may be connected, the position of a fuel flask/skip/magazine will determine the speed of response to an overheating scenario. Fuel skips within inlet cells should be capable of being hand-wound to the pond or else wetted using in-cell spray-rings/hoses whilst flasks in park positions will already be appropriately positioned to allow manual addition of cooling water. Even flasks in rail/road transit should be capable of being cooled via manual addition of cooling water by SF&R. Similarly, exposed fuel within a decanner cell must be kept wetted. Although each of the cells has in-cell water sprays, the potential locations of some fuel/debris within the cell could be such as to require repositioning for better visibility and water coverage. CONSIDERATION 22: examine the potential to connect MDAs to facilitate the lowering safely of suspended flasks, skips and magazines in the event of a prolonged loss of electrical power Oxide fuel Oxide fines within the centrifuge bowl can contain self-heating, insoluble fission products (IFP) which have the potential to boil off feed/wash liquors leading to the drying out and decomposition of the cake, and the subsequent release of volatile ruthenium, if left for prolonged periods. April 2012 Page 50 of 65 On loss of power it may be possible, for the centrifuge, to use wash liquor to keep the cake wetted, to flood the centrifuge and/or use a small diesel generator to supply the wash pump. CONSIDERATION 23: examine the means by which product within the THORP centrifuge bowl can be kept wetted so as to avoid subsequent decomposition There are multiple water sources of varying quality capable of meeting the loss of primary UHS. However all of them require electrical power to get the water to the site. All of the declared back-ups require personnel to travel off-site and/or transport an MDA along country roads which may prove challenging in this scenario. Alternatively it would be possible to use the redundant River Calder Pumphouse, pump from River Ehen and make a connection into the ring mains or backfeed the fire hydrants and Water Treatment Plant water stocks. It would of course be possible to pump from the sea and make a connection into the ring mains or backfeed the fire hydrants and WTP water stocks. However this would only be considered as a final resort due to the adverse impact of sea water on nuclear plant. In any case the diversity of supplies renders this scenario essentially noncredible. CONSIDERATION 24: review the resilience of the water supplies to site in extreme circumstances CONSIDERATION 25: increase the flexibility and use of the existing water supply cells CONSIDERATION 26: consider the reinstatement of the River Calder pumphouse CONSIDERATION 27: review the size, number and location of emergency pumps 7.3 Spent fuel storage pools As discussed previously, heat transfer is only likely to be an issue if there was a significant loss of water resulting from a breach of the pond floor or walls. In the latter case attempts would be made to contain the breach and use tarpaulin/sand bags to create a temporary bunded area. Mobile pumps would then be used to return water from either the sump or the improvised bund and/or supplement water supplies. The only spent fuel storage pool for which loss of the UHS could result in off-site consequences greater than 10 mSv to the critical group would be earliest Magnox fuel storage pond for which significant remedial work has already been undertaken noting that a significant proportion of the pond structure is below ground level such that leakage will be reduced somewhat and a single array of fuel skips and the sludge inventory would still be wetted in the event of a significant breach in pond wall. CONSIDERATION 28: review the emergency responses for all spent fuel storage ponds to identify commonality between systems and equipment April 2012 Page 51 of 65 CONSIDERATION 29: procure further portable bunds for potential deployment around spent fuel storage ponds CONSIDERATION 30: utilise the site deep water facility to test both techniques and equipment and to carry out training and emergency exercises April 2012 Page 52 of 65 8 Severe Accident Management Severe accident management at Sellafield is defined within the Sellafield and Windscale Sites Emergency Arrangements – Emergency Plan (Issue 13, September 2009) and Handbook (Issue 41, June 2011) in accordance with NSLC 11. The Emergency Plan and other components of the emergency arrangements are designed to be compatible with the off-site Emergency Plan for Sellafield produced by the Cumbria County Council Resilience Unit. Command and control for severe accidents is managed at strategic, tactical and operational levels (see Figure 6.1). Plant (Operational) Site (Tactical) Incident Plant District (Strategic) Media Emergency Press Office Public Monitoring Access Control Point Parliament Cumbria Police SECC HP SMC Emergency Services Incident Control Centre National Engineering: services equipment MBC NEBR WCECC Work Force External Agencies Centres Other countries etc Figure 6.1 SL command and control arrangements for severe accidents 8.1 Organisation and arrangements of the licensee to manage accidents Tactical The duty Site and Safety Shift Manager (S&SSM) is a suitably qualified and experienced person (SQEP) to assume full emergency control while waiting for relief by the duty Site Emergency Controller (SEC). Shift personnel will assume sufficient manning of Site Emergency Control Centre (SECC) and associated roles to cope with the initial impact of any emergency. The SECC is responsible for the tactical management of the entire Sellafield site. The S&SSM and duty SEC have delegated authority from the Head of Site to take action(s) necessary to respond to an incident including, but not limited to, rationing of supplies, sheltering, mustering, roll call and evacuation. The critical safety functions of the SECC are to establish and maintain command and control in the event of a severe accident/event; and to establish and maintain internal and external information flow to key decision makers in the event of a severe accident/event. Loss of these critical safety functions could be caused by - April 2012 Page 53 of 65 lack of manpower to adequately resource the key roles within the SECC or other emergency buildings (access control points, emergency reception centres etc.); and/or degradation/unavailability/untenability of dedicated emergency buildings and equipment (loss of services within the building, loss of communications, building damage etc.). The SECC is permanently manned by the S&SSM and is located in the same building as the SF&R control room. During the day, the other SECC roles are filled by a team of day workers and shift workers. With the exception of the S&SSM, the SECC team members are volunteers who have a main work role and other safety related roles. All duty team members are trained against role profiles (defined in the Site Emergency Instructions, SEI) and are assessed as SQEP and appointed to their role. Occupied buildings have trained Building Controllers present to manage the building in an emergency situation. Groups of Building Controllers report to SECC via trained Area Controllers. Each of the key posts in the SMC and SECC is manned by nominated day staff who are available throughout the 24 hour period according to a duty roster (comprising eight teams) and who will be called in by telephone or pager as appropriate. In silent hours the SECC on-call duty team are expected to respond within one hour for key decision makers and three hours for technical support and backup. Dependent upon the scale of the incident it may be that the SECC members could experience significant difficulty in getting to site. Exercises and walkdowns have demonstrated that some selected shift team manning above minimum safety manning levels (MSML) is required to restore and then maintain all site utility services following a SBO or multiple/domino ’beyond DB’ events. CONSIDERATION 31: review the arrangements for personnel undertaking emergency roles CONSIDERATION 32: maintain a list of key plant parameters within the SECC Operational Access Control Points (ACP) are set up to control access into and out of affected areas. Incident Control Centres (ICCs) and are established to control actions within the affected plants. Both the ACP and the ICC report up to the SECC (see Figure 6.1). The ACPs and the ICCs are manned by plant personnel. A number of the key emergency people carry out associated roles which can be accommodated in response to a single plant incident; however it is not clear that there are enough SQEP emergency key role personnel to satisfy the CSF for command and control in a multiple plant or side-wide incident. Additionally, a number of plants share ICCs and again, whilst this is acceptable for a single plant incident, it would be impracticable in a multiple plant incident. CONSIDERATION 33: review ICC arrangements to ensure sufficient diversity to facilitate response to a multi-plant event April 2012 Page 54 of 65 Emergency services Sellafield has a dedicated Fire and Rescue service (SF&R) with airport-style crash tenders (deployed following the “9/11” terrorist attacks largely to respond to risk of an aircraft crash), ‘standard’ fire tenders plus a number of pumps and strategically positioned water bowsers around the site. SF&R own all breathing apparatus sets on the site and are required to be in attendance for all breathing apparatus entries. A number of the key plants at Sellafield rely on SF&R either to assist them with reentry into buildings or to deploy pumps to provide cooling or make-up water, dealing with chemical spills, rescue of injured personnel and, of course, to attend fires. SF&R is a rapid response unit, not a standalone service, and is backed up by Cumbria Fire and Rescue (CF&R) to tackle site incidents. In a prolonged SBO or seismic event it is considered unlikely that the CF&R would be available to attend on the basis that the surrounding areas would also be affected. Furthermore the CF&R local to site is manned by ‘retained’ fire crews and hence there is not a full time dedicated fire service guaranteed to be available to assist SF&R. CONSIDERATION 34: ensure that due cognisance is given to the need to retain appropriate access for emergency services during future changes to the site infrastructure CONSIDERATION 35: review the arrangements for fire and rescue response to a severe event 8.2 Use of off site technical support for accident management Arrangements exist for the operators of other nuclear sites to provide assistance in the event of a Site Incident or Sellafield Emergency. Arrangements for support from both Regional & National capability, e.g. fire tenders/pumping units, are in place but require regional & local transport infrastructure to be available for successful deployment. The future staging of this capability will be included as part of the Site Resilience Programme. 8.3 Training and Exercises The following site emergency exercises are carried out annually 2 x Level 1 radiological exercises (ONR demonstration exercises); 1 x security exercise (ONR demonstration exercise); 1 x chemotoxic exercise (Environment Agency observation); 1-2 x roll-call and communications exercises (full site exercises; no regulatory observation); and 8 x training exercises (minimum). Furthermore each plant carries out a programme of exercises against an Emergency Exercise Schedule endorsed by the appropriate Management Safety Committee. The following site emergency exercises are carried out three-yearly 1 x Level 2 exercise to demonstrate the Sellafield Off Site Emergency Plan; and 1 x radiation safety exercise to demonstrate the Transport Emergency Plan. The site has a range of associated procedures to deal with such eventualities as severe weather and/or loss of services. April 2012 Page 55 of 65 Specific Severe Accident Management Strategies (SAMS) have not yet been included in the scope of site emergency exercises to demonstrate that they are fully executable. A current programme of SAA is being accelerated and a review of the site capability to resource responses to multiple or domino ‘beyond DB’ events will be included as part of the Site Resilience Programme. 8.4 Control infrastructure The site has a primary and secondary SECC/SMC and twelve ICCs located on-site. There is a tertiary SECC/SMC located off-site. The primary and secondary SECC/SMC are located at opposite ends of the Sellafield site and seismically-qualified to 0.25g and 0.125g respectively. Plant control rooms are not generally designed to be occupied during a severe accident scenario with the notable exception of the main distribution control centre. Although some modern adjoining plants have some degree of control room redundancy, the usual plant response would be to evacuate and then make subsequent re-entries, where safe and appropriate to do so, via an ACP. CONSIDERATION 36: consider the construction of hardened and sustainable physical control structures 8.5 Emergency equipment Building emergency procedures require that suitable and sufficient equipment (e.g. radiation protection instrumentation, respiratory protection equipment and protective clothing) are readily available for use in emergency situations. Additional supplies of such equipment are stored at strategic locations throughout the site. Mobile trailers containing contingency emergency equipment are also available. Site equipment designed for severe accident mitigation is routinely inspected and checked although a full functional test/deployment is not included in regular testing. Furthermore a supply of additional contingency equipment procured following the reviews prompted by the “9/11” terrorist attacks has been inspected but again has not been subjected routinely to a full functional test or detailed condition assessment. A review of the current storage location and possible future dispersal of additional contingency equipment will be included as part of the Site Resilience Programme. Considerable engineering resources including, but not limited to, lifting devices, shielding, raw materials etc. are also available on-site for deployment under the overall control of Engineering Services. Arrangements are in place for the supply of additional equipment, e.g. air compressors, from off-site suppliers. However the time to deploy such external equipment will be dependent on the off-site infrastructure. In any case the ENSREG “stress tests” assume that the site will be isolated from the delivery of heavy equipment for seventy two hours and portable lightweight equipment for twenty four hours. CONSIDERATION 37: procure temporary mobile units (and possibly off-site air-transported deployable containers) for provision of either welfare support or to augment the management of emergencies April 2012 Page 56 of 65 8.6 Communication and Information Systems (internal and external) The site uses a number of diverse communication and information systems. Site Warning Sirens Site Warning Sirens are located across the site and are sounded on declaration of a Sellafield Emergency (or a Site Incident where appropriate) so as to warn both the workforce and the general public off-site to take shelter. The sirens are electrically powered and are provided with individual UPS arrangements which can provide continuous sounding for up to a day. The sirens communicate with each other by way of a secure encoded network. Pager system The Pager System is used by the S&SSM, via a pager terminal in the SECC, to inform members of the emergency teams of the action they are required to undertake. Initiation by the S&SSM activates the chosen Group Code which can be sent to key personnel within minutes. The base stations (masts) for the pager system do not have battery back-up and the pager system would be lost immediately on loss of power as the masts do not appear on the standby power lists or have a MDA hook point. Alternative back-ups to the paging system include landline telephones, mobile phones and the alert cascade communication management system. However these back-ups are time constrained to the length of the battery backup time and the battery back-up times for the information kept in the data centres, such as the phone lists etc. Telephones Telephones, including mobile phones, are the principal medium for on- and off-site communications. The site’s telephone network comprises a number of switches although the majority of lines route through a single distribution frame. The site uses more than one off-site exchange and all emergency telephones use copper rather than voice over internet protocol lines to ensure maximum resilience. On loss of power, all on-site exchanges have automatic battery back-up which will last for several hours after which time most telecommunications will be lost and some reconfiguration would be required. Alternative backups to the telephone system would however include ‘general’ mobile phones although, dependent upon the extent of the SBO, loss of power to the external mobile masts could be anticipated. The emergency fax lines could also be used as telephone lines by exchanging the plugged-in equipment. Additionally alternative backups could include radios and runners although these would not be as effective and may not be possible due to the site conditions at the time. A voice message system with a sixty four line capacity and a number of prerecorded messages can be operated from any SL internal telephone line. Radio systems Four radio systems are employed on the site. All radios are kept charged; however the base stations are not battery backed and the radios will therefore only last as long as the on board battery which will be dependent on usage. Most major plants also have their own radio to radio system which can be used within plants to communicate but cannot be used plant to plant or plant to SECC. April 2012 Page 57 of 65 Fax machines Fax machines are distributed widely across the site and are used, during an incident, to provide written communications between the SECC, Area/Building Controllers and external agencies. A dedicated thirty two line fax server is used by the SECC. The switch for the emergency fax lines for the site is on an emergency power distribution board and also has a hook-up point for an MDA. CONSIDERATION 38: enhance communications infrastructure the resilience of the CONSIDERATION 39: review the provision of support to the communications infrastructure during a severe event Internet The Safeguard Communications System is a web-based service and uses a standalone PC and broadband connection. The system is used to provide voice messages and warning notifications to off-site residents within the detail emergency planning zone (DEPZ) and sensitive sites such as schools out to a radius of 6 km. The system can also be activated using direct telephone notification to a call centre. The National Resilience Extranet (NRE) system uses a standalone PC and broadband connection to link to the NRE system that the Cumbria local resilience community has adopted. The NRE is an information sharing application sponsored by the UK Cabinet Office and intended to provide enhanced inter-operability and sharing. This capability is provided at both SECCs and the WCECC. 8.7 Radiological accident management Monitoring of releases The Site Perimeter Monitoring System (SPMS) provides continuous read outs of radiation/airborne contamination levels (and in some instances wind direction) and, along with the Site Emergency Monitoring Points (SEMP), relays readings directly to the SECC. These readings, along with any information from local stack monitoring, would provide an initial indication of the scale of any radioactive release. Such initial indications would then be confirmed by tactical deployment of the site District Monitoring Vehicles (DMVs) to facilitate monitoring of the local environment. Anemometers are installed a various heights at a weather station near the main gate. These diverse sources of information would be used by SECC to decide on the appropriate measures to be taken to limit the impact of the release on both the workforce and local population. SPMS would be affected by a prolonged site-wide loss of power. On loss of UPS there are only a small number of portable petrol generators, dedicated solely for this application, to be deployed and connected to the monitors by SF&R. Hence, during an SBO, only selected SPMS monitoring points (determined by the SECC) would remain in service. Furthermore transmission of the SPMS data to the SECC requires that UPS back-up systems are maintained to power data servers together with power supplies from other buildings to node point data routers comprising the site data network. April 2012 Page 58 of 65 SEMP are powered by adjacent buildings and are also reliant on the site data network to transmit the readings. On loss of power SEMP would be lost immediately as it does not have battery backup. Loss of power would also adversely affect local ventilation systems and hence both local airborne activity and stack monitoring systems. SL is obligated to monitor out to a forty mile radius limit and uses fully-equipped health physics vehicles, i.e. DMVs, for this purpose. In an SBO event, Sellafield would be very reliant on this resource to provide crucial radiological data to enable critical decisions to be made and therefore a balance would have to be made between the requirement and frequency of on-site information and the requirement and frequency for off-site information. The weather station would be lost in a prolonged SBO and although the Met Office provides continuous weather forecasts and associated data on temperature, solar radiation (atmospheric dispersion), wind speeds and wind direction through its PACRAM procedure this is dependent on power at both transmitting and receiving end. Clearly the provision of this data would be key to generating estimates of aerial plume size and direction. There are no additional backups identified for this system; hand-held anemometers could provide useful data but the eddying effect of the buildings would have to be taken into consideration. CONSIDERATION 40: review the resilience of the site data network and the need to extend the period of monitoring and data transmission to SECC CONSIDERATION 41: consider the balance to be struck between the deployment of DMVs on- and off-site and whether current provision is suitable and sufficient Dose control Ongoing health physics monitoring and the use of electronic personal dosemeters (subject to individual device battery lives) will allow response teams to perform dynamic risk assessment so as to determine appropriate work practices and levels of personal protective equipment and thereby ensure that any doses accrued are ALARP. Furthermore the site has an extensive network of cameras and a remote-operated vehicle which may facilitate inspection of affected areas prior to entries. In a severe accident it is likely that REPPIR doses would apply, i.e. to mitigate high offsite consequences (> 5 mSv), worker doses could exceed the limits set in the Ionising Radiations Regulations). This effectively allows more operator-based intervention than under normal operations although this would normally be limited to establishment of local access control points, initial surveillance activities and activities to ’make safe’ materials. In these circumstances the SEC could authorise the accrual of doses of up to 100 mSv by operators and the further accrual of doses of up to 500 mSv for informed volunteers for specific tasks. Longer term recovery operations are likely to be subject to normal dose controls and would be justified using normal safety assessment techniques. April 2012 Page 59 of 65 Containment Radioactive inventories at Sellafield are stored within at least primary and secondary containment. Design provisions for restricting releases after loss of such containment integrity are primarily centered around sumps and associated pumps and the reconfiguration of ventilation systems (e.g. dampers). Operational provisions will be dependent on the physical state of the radioactive release with immediate actions being to bring to ground any aerial dust release (e.g. via deployment of a water mist and/or foam) and keeping sludges and ground dusts wetted to prevent drying out and subsequent dispersal. Temporary containment could then be deployed, including bunds, windbreaks, overbuilding/cover (e.g. with tarpaulin), sand/gravel, fixative sprays etc. CONSIDERATION 42: consider the criticality implications of using water sprays and/or foams to bring to ground potential aerial releases CONSIDERATION 43: determine practical means for deploying safely widespread fixative agents to minimise potential spread of airborne contamination 8.8 Feasibility and effectiveness of accident management measures under the conditions of external hazards (earthquakes, floods) The effectiveness of existing accident management measures will be dependent on – the availability and deployment of key resources, i.e. SECC, SF&R and utilities; access to site for both personnel and light/heavy equipment; and human factors (as noted in the ONR Chief Inspector’s (”Weightman”) reports). These aspects will be subject to further evaluation as part of the Site Resilience Programme. In addition, protracted loss of power supply will restrict significantly analytical support from on-site laboratories with only limited analytical instrumentation being batterybacked. Other sources of analytical support, i.e. National Nuclear Laboratory or Geoffrey Schofield Laboratories, would be expected to be compromised by damage to on- and off-site infrastructure. Similarly, provision of medical, decontamination and welfare (e.g. emergency reception centres) services would be affected adversely by a protracted SBO. CONSIDERATION 44: review the resilience of key support services likely to be necessary for ongoing plant control and/or emergency response On loss of plant instrumentation, temperature can readily be measured using a resistance thermometer connected to a multi-meter and then using a relevant conversion chart. Similarly levels for the smaller vessels and sumps could be measured using a Druck-type instrument; however levels especially for larger vessels would be more readily taken if a portable compressed air bottle/system was available to provide a back pressure to measure. Pond levels could be visually checked. Changes in differential pressures could be measured by setting up a simple manometer from clear tubing. April 2012 Page 60 of 65 8.9 Management of hydrogen risks A number of plants have specific design provisions to manage the accumulations of hydrogen resulting from radiochemical interactions. However the only plants for which failure to manage hydrogen risks could then result in off-site consequences greater than 10 mSv to the critical group are those required for the wet storage of Magnox wastes and the storage of HAL. Magnox waste In the case of the wet storage of Magnox wastes, diverse provision of back-up ventilation and inert gas capability is maintained. These include battery-backed fans which start automatically on power failure and, in most instances, are backed up by installed diesel alternators. Upon failure there is provision made for either nitrogen flushing (although this has never been fully tested due to asphyxiation hazards and radiological containment issues) or air ejectors which are run by a dedicated diesel compressor. Recourse can also be made to natural ventilation via the stack effect (weather dependent). Alternative back-up systems, as yet unproven, may include widespread Nitrogen flushing; pressurised inerting (however the effectiveness of pressurised inerting using nitrogen is unknown); an optimum combination of nitrogen flushing and pressurised inerting; and lifting some of the inspection plugs. Mitigating actions could include stopping levels in the cavity from rising (using installed pumps), pumping liquors back into compartments and/or sealing penetrations in the secondary containment. Notwithstanding this it is evident that the current back-up systems could be improved to deal with a prolonged power outage, without recourse to site MDAs and ongoing fuel supplies. CONSIDERATION 45: engage with the Hydrogen Working Party to determine the minimum air displacement flows for the wet storage of Magnox wastes so as to remain below the lower flammable level CONSIDERATION 46: determine, via simple modeling, whether either or both ‘natural ventilation’ and/or ‘lifting plugs’ would be effective as a back-up means for managing hydrogen during wet storage of Magnox wastes High Active Liquors In the case of the storage of HAL, hydrogen evolves from the radiolysis of water and a ‘hydrogen purge’ is therefore used to maintain hydrogen levels in vessels below the lower flammable level. This requires compressed air to operate pneumercators and jet ballasts, HP steam to operate various ejectors for the fill/empty cycle and the vessel ventilation system which in turn requires power and HP steam to operate the ESP inlet and outlet seal vessels. Within HASTs, on loss of power impacting loss of compressed air, established backups are bottled supplies or standby Atlas Copco compressors (powered by a site MDA) each of which is capable of supplying all HAST needs; however these require the ring main to be intact. Alternatively a portable start-up hydrogen suppression compressor is available which has flexible hoses and therefore does not require the April 2012 Page 61 of 65 ring main; however this compressor can only feed one HAST at a time. Furthermore it may be possible to create emergency air connection points and mobile compressors and to provide a diesel compressor for instrument air to replace bottles. Mitigating actions, assuming that a hydrogen deflagration has caused plant damage and HAL is on the cell floor, could include shutting the cell inlet and outlet dampers (to contain HAL as much as possible) and to monitor the cell sump temperature with a probe (to monitor time until HAL boiling). On loss of power there would likely be sufficient mains pressure to empty immediately the ESP seal pots as effectively as possible as per existing plant emergency instructions. The ESP seal pots must be emptied to allow free flow of the ventilation system which would prevent hydrogen purge and lead to possible pressurisation. Current back-ups include four emergency steam boilers. CONSIDERATION 47: review the resilience of both power and steam supplies to HASTs in extreme circumstances 8.10 Accident management after uncovering of the top of fuel in the fuel pool 8.10Significant damage to pond structures could result in significant radiation doses on-site from shine through any significant cracking and sky-shine from loss of pond water. However recent seismic studies indicate that site ponds would, with the exception of the Magnox fuel storage ponds, be expected to remain intact, albeit with some new cracking and propagation of existing ones. The principal means for restricting releases would be to ensure sufficient water cover within the pond as this will provide both cooling (where required) and some containment. April 2012 Page 62 of 65 9 Summary The Tohuku earthquake on 11 March 2011 and subsequent events at the Fukushima Daiichi Nuclear Power Plant have prompted fundamental reviews of the resilience of nuclear power plants. European Commission and the European Nuclear Safety Regulators Group (ENSREG) produced a joint specification for a three stage process of this “targeted reassessment of the safety margins of nuclear power plants”. These “stress tests” are intended to highlight a NPP’s self-reliance against a variety of extreme situations such as those that occurred at Fukushima, i.e. an earthquake and/or flooding as an initiating event; the consequence(s) of loss of safety functions from any initiating event conceivable at the site such as loss of electrical power, including Site Black Out (SBO), loss of ultimate heat sink (UHS) and/or a combination of both; and severe accident management issues such as means to protect from and manage loss of cooling and/or containment integrity. Application of these “stress tests” to the Sellafield site, as requested by ONR, has necessarily required a structured interpretation by SL of many of the ENSREG “stress tests”, due to the radical differences between a NPP and a complex and diverse chemical multi-plant site, as well as clear definition of the Sellafield plants and supporting functions to which they would be applied. An interim report for the Sellafield site was submitted on 15 October 2011. This paper represents the public domain version of the final report for the Sellafield site based on local interpretation of the ENSREG “stress test” requirements for plants configured and operated as of 30 June 2011. The RESilience Evaluation Process (RESEP) has been developed as a structured and consistent approach to resilience assessment for the Sellafield site. Detailed assessment of resilience has been applied to those facilities which are capable of generating fault sequences that lead to off-site consequences exceeding 10 mSv to the critical group and/or having a SED score greater than 1x1010. However it is important to note that these off-site consequences, and hence the RESEP screening criteria, are based on bounding safety case assumptions and plant flowsheets which themselves are extremely pessimistic when compared with actual plant operations. Hence the off-site consequences of any release are likely to be much lower in reality. The RESEP included key plants (i.e. those with a greater than 10 mSv off-site dose fault sequence consequence to the critical group and/or having a SED score greater than 1x1010), utilities (electricity, water, compressed air and steam) and Site Emergency Control Centre (SECC), Sellafield Fire and Rescue (SF&R) and communications. On the basis of the current state of knowledge – A number of older plants will be adversely affected by a greater than design basis earthquake (DBE). The site has adequate protection against both tidal and river flooding with the only significant risk being that of an extreme rainfall event which could result in some shortterm surface water ponding. There is a high degree of diversity and redundancy for both on and off-site electricity and water supplies. There are sufficient fuel stocks for Sellafield site to be self-sufficient for a seven day loss of electricity supply from the national grid. April 2012 Page 63 of 65 The site has robust arrangements for a seven day loss of Ultimate Heat Sink (UHS) which, in a Sellafield context, relates principally to diverse means for cooling Highly Active Liquor (HAL), for keeping fuels wetted and for ventilation. Fuel ponds are unaffected by a seven day loss of cooling water make-up and relatively robust to a Design Basis Accident. Local plant arrangements, which are designed to prevent a reasonably foreseeable event arising, are robust. Existing site emergency arrangements, which are designed primarily to respond to a reasonably foreseeable event in a single plant, would soon be strained by requests for support to multiple plants as a consequence of an event with simultaneous site-wide effects. There are opportunities to improve the emergency infrastructure in support of a response to an extreme event such as those identified within this report. These preliminary findings have prompted a number of “considerations” as listed overleaf to be developed further as the basis for action by the Company. However these preliminary findings will inevitably evolve and prompt further considerations as SL develops a deeper understanding of interactions and processes across the site. The work undertaken to date, as detailed within this report, has identified no potential deviations from the licensing basis. April 2012 Page 64 of 65 Considerations for enhancing the resilience of the Sellafield site to extreme events 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 provide local neutron inhibiting materials for emergency deployment to prevent/halt a potential criticality excursion review the arrangements for providing alternative sources of cooling water to HASTs in extreme circumstances review the arrangements for management of site fuel stocks procure a bowser/road tanker capable of transferring fuel efficiently around the site review the manning levels required to respond to prioritized site demands during a major event develop a programme to deploy, connect and test MDAs to EPD connection points routinely on safety significant plants enhance the robustness of the forced ventilation system for Magnox wastes to a severe seismic event review the potential for trapped hydrogen with the Magnox waste matrix being liberated as a result of a severe seismic event obtain skid-mounted diesel pumps for potential deployment in the later Magnox fuel storage pond following a severe seismic event review the robustness of alternative power supplies sufficient to allow timely crack repair (using already available dedicated repair plates, water containment and various pumping systems) following a severe seismic event seismically enhance existing bridges across the River Calder and develop the ability to deploy temporary structures confirm realistic rates of self-heating within Magnox fuel undergoing reprocessing and the minimum quantity of water required to prevent self-ignition on potential loss of cooling develop and substantiate specific contingency plans to extinguish a fire within solid waste facilities consider the need to engineer additional flood defences alongside the River Calder undertake more detailed modeling of surface run-off and drainage within built-up areas of the site review the resilience of the current arrangements to pump out the central drainage water collection and discharge system utilise the design of any future changes to the site infrastructure to direct rainfall flood flows so as to minimise ponding re-engineer applicable flood defences to address very severe rainfall flooding take local actions to address potential vulnerabilities to flooding of individual EPD boards and MDA connection points consider the procurement of pre-fabricated flood barriers for local ad hoc deployment take local actions to address the potential vulnerabilities of diesel stocks to protracted extremely low temperatures examine the potential to connect MDAs to facilitate the lowering safely of suspended flasks, skips and magazines in the event of a prolonged loss of electrical power examine the means by which product within the THORP centrifuge bowl can be kept wetted so as to avoid subsequent decomposition review the resilience of the water supplies to site in extreme circumstances increase the flexibility and use of the existing water supply cells consider the reinstatement of the River Calder pumphouse review the size, number and location of emergency pumps review the emergency responses for all spent fuel storage ponds to identify commonality between systems and equipment procure further portable bunds for potential deployment around spent fuel storage ponds utilise the site deep water facility to test both techniques and equipment and to carry out training and emergency exercises review the arrangements for personnel undertaking emergency roles maintain a list of key plant parameters within the SECC review ICC arrangements to ensure sufficient diversity to facilitate response to a multi-plant event ensure that due cognisance is given to the need to retain appropriate access for emergency services during future changes to the site infrastructure review the arrangements for fire and rescue response to a severe event consider the construction of hardened and sustainable physical control structures procure temporary mobile units (and possibly off-site air-transported deployable containers) for provision of either welfare support or to augment the management of emergencies enhance the resilience of the communications infrastructure review the provision of support to the communications infrastructure during a severe event review the resilience of the site data network and the need to extend the period of monitoring and data transmission to SECC consider the balance to be struck between the deployment of DMVs on- and off-site and whether current provision is suitable and sufficient consider the criticality implications of using water sprays and/or foams to bring to ground potential aerial releases determine practical means for deploying safely widespread fixative agents to minimise potential spread of airborne contamination review the resilience of key support services likely to be necessary for ongoing plant control and/or emergency response engage with the Hydrogen Working Party to determine the minimum air displacement flows for the wet storage of Magnox wastes so as to remain below the lower flammable level determine, via simple modeling, whether either or both ‘natural ventilation’ and/or ‘lifting plugs’ would be effective as a back-up means for managing hydrogen during wet storage of Magnox wastes review the resilience of both power and steam supplies to HASTs in extreme circumstances April 2012 Page 65 of 65 10 References 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 ONR. 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