Cae ie Head of Assurence (Nuclear Safely & Tee ea Regulation Department) Sento BAE Systems Marine Linited BAE Systems Submarine Soluions Sarrovin Furness — TAMAR OurRet: TRIM 20101407869, Unique No: BAE 70003N cramming. NUCLEAR INSTALLATIONS AGT 1965 (AS AMENDED) BAE SYSTEMS MARINE LIMITED DEVONSHIRE DOCK COMPLEX NUCLEAR SITE LICENCE No-428 VARIATION No.t LICENCE CONDITION 11 RADIATION (EMERGENCY PREPAREDNESS AND PUBLIC INFORMATION) REGULATIONS 2004 LEVEL 2 DEMONSTRATION EMERGENCY EXERCISE “INDIGO 2010" Exercise INDIGO 2010" which tock place on 1" July 2010 was a combined Level 1/Grade Cand Level 2/Grade @ amargeney exercisa based around 2 nuclear reactor accident on 3 submmadine dung ts Power Range Testing pase al the BAE Systems ste at Barrou-in- Fumess, The exercise aims were + Todemonstrate the effectiveness of BAE Syslems Marine Limited's (BAESM) Nuclear Emergency Orders atthe operalianal, tactical ane strategic levels in onse loa Feactor accident; and EPPIR 2001, This etter raced the cor «¢ (NI) ane! the i by obsarvers from HSE Nu fence Nuclear Safety Requiato ing objective NOT PRCNOT PROTECTIVELY MARKED B: To.demonsteale the Command and Conitol praceduses at Nuclear Accident Heaiquarters (NAHI), G: To demonstra evacuation ofthe Exclusion Zone and accatintailyof personne! at the Exclusion Zone Recepiion Cenire (EZRO). D: To damonstraleinfermation low between Forward Control Point (FCP), Forwerd Contra Contre (FCC), NAH and tne South Cumoria Emergency Control Cente (ScECe), E: To demonstrate the integration of BAESM/Local Miliary Co-ordinaing Authoriy and subsequently Nuclear Accident Back-Up Support Team (NABUST) on arival within the SCECC, F: To demonstrate the Integration of BAESM Communicallons Department into the ‘SCECC and the Off Ste Mosia Briefing Centro. The conments of our inspectors who observed the oft-sie Level 2 aspects ofthe eercise at the SCECC wil be reported separately using the protocols established Dy Cumoria County Counc ‘The scenario wes well conceived and planned, provided an interesting and sultably chalengng tes of he on site emergency plan, and was successfuly directed. We recognise ane eppreciie the hard work invested by all who were invaivad in planwing, setting and directing the exercise We alsoracognise that a nuirber ofthe cscrete pats ofthe arrangements worked well Howevay, there were a numer of specific areas where the performance did not meat expeciatons. A cumber of these weaknesses could be characterised as being abou the interiaces between different pars ofthe arangemen's. Those weaknesses seriously. tracted from the Integrated response we would expect to see. The assessmenttearh did nol conser that the execution ofthe exercise provided an adequate demonstration ofthe Licensee's operational and tactical response toa reacior accident. In pariodar: + Ths numbers of personnel requiing to be accounted fo rom the exclusion zane is & ‘atively low number so the time taken to fully account for these persons during the exercise nas considered to be a significant fling in the demonstration of the arrangemenis. Procedures and precesses for parsonnel accountancy across the {erent elements ofthe aecident response need to be 8aniesnly kmoroved. “+ Asignificant amount of ime was taken in desing wth the briefing and paperwork for the inlervention leas. The process for briefing such leame shoule be reviewed _and consideration given to how the process can be expediied. + Communications between the EZRG and the Command and Coniral Cel in NAH. wore net effective. Consideration needs tobe given te how to ensure consistent irrormation fon between thee locations, ‘+The arrangements for casualty handling and debriefing at EZRC were poorand ~ sfoulé be reviewer, ‘+ There was litte evidence of conto of intervention teams once the FCP stosd- heme by ‘ane person and to hospital by another). ive D: Te Je information fw between al Poiot Fe igo Centre and the South Cumbr i (SCEGAL, This Objective was partaly demonstrated. Goud pits + There was clear evidence of communication links being established and good levels of information ow between the Manoeuving Room, FCP, FCC, NAHG nd SCECC. + There nas consictent use of NARIMS fo ensure that he same information was ‘avaiable to al locaions and easly cificutes with NARIMS at some locations were overcome by use of telephones and faxes. +The FCC was considered to have worked well with clear command and control processes being evident. ‘+ Good team-working was established between BAESM personnel and Cumbria Fire and Rescue Service (CFRS). Briefings clearly established tne necassary ‘tational ‘overview (inluding thal there was, al tha! poin, no radiation hazara), Baling of teams (using boat schematic aids) and a pian of acon, including each-alhers Hlerdegendencies, Leeming Pints + Onca the FOP was stood-down on declaration of Catagory 2, the function that 's carried out there was lost. This meant that once subsequent Inte-vention ieams were sent out, the was litle evidence of control ofthe team or knowledge of where they were or what they had found or done. The absence ofthe functions of a FCP after Category 2 Is considered to be a significant ‘ailing in tho arrangomonts that noods to be addrossod.. ‘+ DATEL previde support to the site for ensuring NARIMS Is working and problems are overcome. However, this support would not be immectately avaliable ina resi event. Nil and ONSR wus therefore net expect DATEL to be on ste Guring ture 4+ HARIMS within PRT HO was ullisad fully and effocively unl such ima 2s PRT HQ nas evacuated. The only exception being thatthe team within PRT HQ were unable to locale the Post Accident Questionnaire template within NARIMS and therefore hod to input the inforation into NARIMS line by ine, again this process aut an avaidable delay into te management process. + Availabilty ofa printer within PRT HO would have greally assisted the communication between the Stil Supervisor, RTG represeniaive and NARIMS operator which would have great'yassistas win the timely paputation of NARIMS. NOT PROTECTIVELY MARKEDNOT PROTECTIVELY MARKED + There were several instances where PRT HO mere trying to communicate with ‘Ships Steff and finding the lire engaged. Uni such time as PRT HQ Is evacuated the only condul to Ships Siaft (Manoeuing Room and Control Room) should be ‘hvough PRT HQ. The desire for personnel fo get THEIR information fom the ‘norses mouth’ requifes fo be suppressed: his even more important in 2 reat situation PRT HO was only ied with one teleshone line. A minimum of two should be provided so thatthe RTG representaive and the Duty Shift Engineer both havea ‘means of communicating enabling one to talk tothe boat and one la talk to NAHO. ‘Areal stualion could demand more 2s for exercise purposes PRT HQ was manned with two personnel and one NARIMS operator; in realty this number would be greater, ‘+ Tha intontions and prorites pages on NARIMS belonging to the MCA and tha IC remained biank for the duration of the exercise therefore. although they and their Immediate teams may wel have been aware oftheir prlonias and intentions, tvs Was not being communicated to the wider corarumnity, bigctive E: To demonstrate the integration itary Cox oa sseguenly Nuciear Accident Back-Uo Suspor Team (NABUST) on arrival \wifin the SCECC. This Objective was partially demonstrated. Sood pants ‘+ The operator's susport fo the off-site response was led by the company, wth MOD overseeing and also providing Lead Governiment Department input. The MOD ‘response was later supplemented by a large-scale NABUST from HIMNB Ciyde. All ‘of is support (incuding technical, heaith physics and communtcations/PR) was ‘efrecively integrated info the of-sile responce as a whole. ‘Lewin Poinss + Although briefings were provided tothe Senior Co-ordinating Group (SCG) on the Current stalus ofthe plan, these were nol forwarc-looking to include likely ‘developments, timescales, consequences etc. Folowing SCG prompting, a request ‘was made to the TASG for en estimated timescale for core damage (2. Category 2) ‘but na information was provided prior 'o Category 2 subsequent being declared. ‘The offsite response thereby lacked an understanding ofthe overall scope of the likely development ofthe accident. This cficully was seriously compounded by the absence of any meaningful advice on the lkely radiological consequences of the accident ar even on the planning basis which underpins the arrangements. Again, {his [ed to a complete lack of understanding by the cul authorities ofthe ikely ‘consequences ofthe accident and resulted in consideration by tnem of ever more precautionary counlermeasires, including large scale evacuation (~18,000 people) ‘and PlTs/sheller exiencing well beyond the 2 km zone. In he absence of any olner Information the SCG sought information on a potential source term in order to be able to make their own ballpark assessments, The operator eventually advised a Value of 10°° Bq 131, which ie well beyond the planning basis and therefore excessively pessimielic, ut drove countermeasure considerstions to sil futher precautions. All ofthis represented significant shortfall in the operator ‘support to the off-site response with the resuit that the actions taken to NOT PROTECTIVELY MARKEDNOT PROTECTIVELY MARKED protect the public were not well-informed and grossly over-pessimistic. Some corrective action was eventually undertaken to recover the situation by NABUST personnel. (There vas widespread recognition ofthe excessive aver-feacton by a numberof agencies al the vast-up,) ‘+The BAE NARIMS link et SCECC cauld not be estotlished uni late in the momina, apparenlly because cf operator rather than system errors. Thereafter thesystem was wel utlised, with key information also being input on the National Resilience Extranet (NRE) system. The MOD team lacked aocess to both NARIMS end NRE. ‘While the two teams do work closely together, separate MOD NARIMS access is regarded as essential. (This was provided by the NABUST following thet arrival but Is required from the star.) ‘© Afull NABUST was deployad by HMNB Clyde, which presented its own dificutiesin providing in-briafs for evoryone and indoed workspace. Kaleo appeared 10 be sulbstanicl overs in relation to what is required fo suppor the local carat, ‘and fast he shift-change. Accordingly, the NABUST support required for Barrow needs further consideration. A key person within he NABUST is the MOD public relotions represeniative as there Is not ane on site, this ensures that the VOD are ‘not out ofthe loop wlth regard to press bricfingsireleases. ‘This Objective was not assessed in deta by the external Regulators (Outs Holed under Objective & the conmmutestons team appeared tobe ffectvaly integrated into the of ste response), NOT PROTECTIVELY MARKEDNOT PROTECTIVELY MARKED APPENDIX B TO BAETOOOSN, ‘TRIM 20101402559 DATED 9 September 2010 NIJONSR OBSERVATIONS AND COMMENTS ON BRIEFING OF INTERVENTION ‘TEAMS DURING EMERGENCY EXERCISE “INDIGO 2010", 13 JULY 2010, Proparation for REPPIR Intervention for MOD Personne! “Two Royal Navy (RN) volunteers were obteined, At the request of the Health Physica ‘Supervisor (HPS) they signed a ?permit lo enter and emergency exposures authensatlon for before they had received any briefing. The HPS briefed the voluntears using 2 pink [prompt card snd mop on the wall. This was delivered very quickly. Advice was given on howto minimise dose uptake, for example, by ine use ofthe diesel engines to prove shielding, keeping tme in the area to a minimum by moving out of the area fo discuss problems etc. Personnel were issued wilh Electronic Personal Dosimeters (EPDs)for this Intervention. They were advised on the alarm setings for the EPDs and the requirement to leave the area al the 4S0mSv dose alarm in order fo keep the lotal dase to <500 mS “They were adhised ofthe increased risk of cancer as a resull ofthis intervention, staled to bbe from 2.5% 0 2.8% Observations 7, The use of the map to ilustrate the route to the intervention slte was good, as nas the ciscussion on practical metnods to keep doses ALARP. 2. Consideration should be given lo providing te pink prompt card to the volunieers for tiem to readin aadion to a verbal brief to ald aecurate presentation ofthis data €.9 the setual risk as istee on tne cara was an increase of 2.5% on the current 25% nsk, 3. These persons signed fo accept the HP brie before it was delivered ar the for had ’been completed vith information such as ine PPE/RPE required. The signelues should anly be oblained once the briefing has been completed 4. Flas it been determined that an alarm selling of 90% of the dose leve! ill alow Sufficient time fo ext the area and maintain doses less than the species dase level? Preparation for REPPIR Intervention for Cumbria Fire & Rescue Personnel Curia Fire and Rescue Service (CFRS) have an agreed intervention dose level of *100mSy. CFRS personnel were identified fo this intervention along with paramedic support and it ook 15 minutes fo brie thern nd iin the paperwork. Observations 5. Inthe case of both interventions, he Emergency Controller did not authorise the intervertton untl te paperwork had been completed. This s as it should be. 5. CERS personnel should have been briefed and ready to 90 into the area beferethe tentry by RN personnel. The inl interaction was to miligaa the Imeact af the incident ‘and hence an adllonsl delay to brief CFRS personne! should not have been an issue. Inthe even, since CFRS were needed to rescue personne! onboard the submarine, NOT PROTECTIVELY MARKEDNOT PROTECTIVELY MARKED brief should have bean expedited to minirise the dose uatake to the inured RN personnel. Consideration should be given to briefing intervention teams befoe they are needed so that only a task-speciicbreling (aking cognisance of te radiological and ‘otter hazards al that point inthe development ofthe incident) is needed once a ‘decsion to ntervana has bean taken, 7. Advice Was provided on minimisation of dose uptake utlising large items of plant for shielding. This is probably less sigrficant in a lie saving interveniion and lcok up valtable ime to delves. Handling of Information from Interventions (On retum, the dose inforration from the EPDs wes communicated tothe heath physics area, willen on the board by the HPS and checked. RN personnel received (fr exercise purposes) 330 mSv agains dose level of $00 mSv and CFRS personnel recelved 142 mSv agains! dose level of 100 ms. Obsenations. 8, The facl that CFRS personne! iad (Tor exercise purposes) exceeded thar dose level was nat questioned by HP staff or communicated to the RPA or their emalover. NOT PROTECTIVELY MARKED