I listened to a very interesting talk organised by the Emergency Planning Society, a Lunchtime Learning Session – Plymouth Unexploded Ordinance Device Incident.
A 500 kg unexploded bomb from an air raid between 28th and 29th April 1941 was found when digging out the foundations for a house extension.
The on-call emergency responder took the initial call just before 11 am and at 13.30 the Police declared a Major Incident. An initial 214 m evacuation cordon was put in place with the National mobile phone warning system used in anger for the first time and teams from multiple organisations going door to door. The zone evolved with time.
More than 4,200 properties were evacuated involving more than 10,300 people. While many made their own arrangements more than 1000 attended Rest Centres over the three days and more than 1000 calls were received on the 24/7 helpline and 73,000 hits on the website.
The bomb was later moved and destroyed at sea. The move entailed a temporary evacuation of the area either side of the route.
Of particular interest:
A few people were reluctant to leave their homes. Major concerns seemed to be about pets (RSPCA helped) although there were some health issues to manage. These all take resources to work through.
There is a reluctance to use gyms for overnight stays. Preference is to put people up in B&Bs or hotels.
The National Emergency Notifier System worked well with the message out within 30 minutes of the decision to use it. With prepared messages this could be speeded up. Unsurprisingly the system “leaks” in that the message is received beyond the intended footprint so it is important to consider the wording of the message – not “please evacuate” but “please evacuate if you are in this area”.
The council rejigged their “when are my bins emptied” website to show the intended evacuation area in detail. Which was a quick process. Well done Council GIS team.
The area followed the REPPIR process of zigzagging along streets rather than cutting through lines of houses. Good practice.
The local football ground was used as a briefing centre for the boots on the ground.
Supply of sand was successful but not needed in the end (If bomb had been detonated in-situ it would have been surrounded by sand to manage the explosion).
Vulnerable people were identified by door knockers rather than by comparison of agency lists. This was not what the plan expected.
A very interesting talk about the day in a life of a council emergency responder and a good example of multiple agencies working together well. The response would probably not have been so successful without the careful planning and exercising that takes place.
Sheltering in place is thought to be an effective protective action in the case of releases of radioactive dusts and gases from nuclear sites because it reduces gamma radiation dose by a combination of shielding and distance and it reduces the inhalation dose while the airborne levels are higher outside than in. If you are going to stay in shelter for any length of time with elevated external levels it is obviously better to reduce air exchange between the inside and outside.
The UK national advice on the topic has “Key factors affecting the effectiveness of sheltering-in-place include: the air permeability of a building used for shelter; the meteorological conditions; the particle size distribution; the effectiveness/timing of opening windows and doors; and the release duration, all of which could vary significantly from one scenario to another (or even within a single scenario). Some of these factors such as meteorological conditions are time dependent, and therefore the DRF may vary as a function of time.” (PHE-CRCE-049)
Advice to the public in the UK is provided by REPPIR Prior Information leaflets and websites for those near to nuclear sites. These tend to have the advice to close doors and windows and will then say something about other steps that can be taken to reduce air exchange. Examples: Barrow: “Switch off fans, heating systems, air conditioning and put out open fires”. Capenhurst: “Switch off all heating systems. Ventilation fans and air conditioning systems to avoid drawing in outside air”. Devonport: “Put out fires and boilers and shut off air conditioning units. Fans, air conditioning units, boilers, gas fires and heating systems draw in air from outside. You should switch off these things (and damp down open fires) to stop radioactive material from outside coming inside”. EDF sites “close all outside doors and windows, switch off any ventilation or extractor fans”. [No mention of heating!] AWE “Turn off boilers and air conditioning units and put out fires or woodburners. Fans, heating systems, boilers, gas fires and air conditioning all draw in air from outside so these should be shut down to minimise radioactive particles entering buildings”.
While the physics suggests that air exchange between the outside world and the inside of a building is affected by the temperature difference most of the historic concern, I suspect, is with systems that burn hydrocarbons in-situ and are designed to draw in air to support combustion. Not everybody uses such systems these days.
Are there forms of heating that we can use safely while in shelter – electric panel convection heaters or air source heat pump serving underfloor or ceiling mounted fan coil units that don’t obviously rely on external fresh air or do we all have to freeze while waiting for the all-clear or evacuation instructions?
This article is a brief synopsis of an NHS England paper looking at how it relates to nuclear licensed sites. Please refer to the original paper rather than this article if preparing plans. Katmal Limited can provide advice on planning should you require it.
“Members of the public who may be contaminated, especially following large incidents, may leave the scene and subsequently seek assistance at a nearby healthcare facility. All healthcare facilities are required to have arrangements in place to manage self-presenting patients. These plans need to recognise that people concerned about the health impacts of a HazMat/CBRNE contamination incident, but not necessarily affected by it, may also attend healthcare facilities and other NHS sites even though they do not require treatment.”
Timely alerting – are all NHS facilities alerted to a local incident?
Planning risk assessment
“The risk assessment should also take account of the need to protect healthcare facilities, staff members and uncontaminated patients and the provision of timely and appropriate care to people self-presenting from a HazMat/CBRNE incident”. This risk assessment is likely to conclude that anyone self-presenting following an accident at a nuclear reactor site may be contaminated with fission products (other licensed sites have their own specific hazards – for example plutonium, uranium or tritium for AWE) but, actually this remains unlikely and the levels of contamination if they were to be contaminated would not be sufficient to affect the health of staff members, uncontaminated patients or other persons on site. What remains is a presentational issue. How do we assess and reassure the self-presenter and how do we maintain confidence that the facility is fit for purpose against rumour that it is badly contaminated?
The paper does not mention it but for those NHS facilities near a licensed site it would be sensible to understand the type of contamination that is possible and how it could be identified and measured on people. This is easier for sites that might release beta/gamma active materials rather than sites that might release pure alpha emitters. But either way, an understanding of how to detect and measure plausible local contaminants should be pursued and suitable instruments maintained.
“Organisations may wish to identify areas of their premises where IOR [Initial Operational Response] activities can take place. This would include access to clean running water and be considerate of patient modesty. Such areas could be marked with zones for patients to disrobe and then move to, making communication easier”.
Ideally the facility would be able to move the self-presenters to a remote area where they can be processed without the potential to contaminate busy areas of the facility. Initial screening might be by questioning where the person was and what they were doing during plume transit.
“An incident of this nature has the potential to be disruptive and may result in the affected premises being compromised for a period of time. The plan will need to link to the organisation’s business continuity arrangements to mitigate this.”
Section 3.6 of the paper reviews the potential psycho-social impacts of the event stating that the public are likely to be orderly, will respond better in a well planned and executed response with clear information, efficient, polite and caring handling of self-presenters including respected the need for privacy and modesty during decontamination. It is important to plan and train to get this aspect of the response right.
“Available evidence suggests public behaviour will be orderly and there will be no panic.”
“These arrangements and the Remove, Remove, Remove model do not require staff members to wear specialist protective equipment[1] nor does it require specialist decontamination equipment for the patient to use. Instead the model utilises any absorbent material such as blue roll or paper towels which can be retrieved from most building’s toilets or kitchen facilities”.
Lock-down procedures might be required to control access and egress to the facility to minimise confusion and the spread of contamination. “It should be noted, however, that healthcare organisations cannot physically prevent people from leaving their premises (even if the hazard or threat is outside the building which is locked down)”.
The NHS has a STEPS 1-2-3 protocol:
“The Emergency Services use the STEPS 1-2-3 plus process as a recognition and risk assessment tool. If one incapacitated patient is encountered with unexplained symptoms then they are treated using NHS universal precautions. If two incapacitated patients are encountered together with unexplained symptoms they are treated with caution and a high index of suspicion of contamination using NHS universal precautions. When three or more incapacitated patients are encountered together with unexplained symptoms the staff withdraw to a safe distance and call for specialist resources and advice. At the same time the plus element indicates the instigation of IOR.”
This is very unlikely to be triggered for a nuclear accident at a licensed site as the dose rates are likely to be too low to trigger symptoms. It could be triggered if a powerful source is left in a public space (See Cochabamba bus incident 2002) or if a powerful source is dismantled and distributed among a population (See Goiania orphan source incident 1985).
The remove, remove, remove Initial Operational Response then comes into play.
Tell those affected to:
Remove themselves … from the immediate area to avoid exposing others. Fresh air is important.
Remove outer clothing …
Avoiding pulling clothes over head if possible;
Do not eat, drink or smoke
Do not pull off clothing stuck to skin
Remove the substance …. from the skin using a dry absorbent material to either soak up or brush it off.
Again, it is unlikely that skin will be itchy or painful as a result of radioactive contamination. Care should be taken not to break the skin and allow contaminants a route into the body.
Under the remove themselves banner it is suggested that the self-presenters should be isolated from other patients and staff members in a safe area, preferably outside. Continuous clear communication would be key so that the worried person does not feel abandoned.
The advice for removing outer clothing (which is expected to remove most of the contamination) suggests that “Undressing should be systematic to avoid transferring any contamination from clothing to the skin”. It recommends cutting clothes off rather than pulling them over the head. The important thing is to avoid touching the outer surface, particularly avoiding the outer surface coming into contact with the mouth, nose or eyes.
Modesty and warmth may become an issue when asking members of the public to disrobe outside.
Removed clothing should be bagged and labelled but this process should not be allowed to slow the undressing process unduly.
Dry decontamination, blotting and lightly rubbing skin with any dry absorbent material such as paper tissue, clean cloth etc is the preferred for of decontamination.
Hair may need careful wet decontamination. In the meantime potentially contaminated hair should be covered and away from the face.
If there is an incident a dynamic risk assessment would be expected from those in charge.
“When conducting a dynamic risk assessment there are five principal stages to be followed:
Stage 1 – Identify the hazard
The first step is to look for hazards. Consider the location that the activity or process is carried out and check for potential dangers. Concentrate on anything with the potential to cause serious harm to employees, members of the public and the patient(s).
Stage 2 – Decide who might be harmed and how
Decide who and how many might be at risk
Stage 3 – Evaluate the risks and identify suitable and sufficient control measures
Implement the Remove Remove Remove procedures
Stage 4 – Record and implement findings
The findings of the risk assessment must be brought to the attention of those at risk to harm and appropriate training and instruction given on the implementation of the control measures.
Decide who and how many may be at risk; is it those undertaking the activity or may it also affect members of the public and staff.
Stage 5 – Review the assessment
All risk assessments should be reviewed at a frequency proportional to the risk.”
Section 5 states that there might ne a requirement to seek specialist advice. This may come from UKHSA or the operator of the facility that is the source of the issue.
There is more discussion about PPE (Section 6) and Quarantine (Section 7) and a larger section on Recovery (Section 8).
This is a refreshingly short and focused advice sheet with sensible sounding advice.
[1] Direct physical contact with the patient(s) should be avoided.
Daisy Ray, Innovation Programme Lead – Advanced Nuclear, Department for Energy Security and Net Zero.
Juan Matthews, Visiting Professor in Nuclear Energy Technology, Dalton Nuclear Institute.
Tom Purnell, Business Development Director, Nuclear AMRC.
Robert Exley, Superintending Inspector, ONR.
Mike Crawforth, Business Development Manager, Rolls Royce.
My enjoyment of this meeting was slightly reduced by the difficulty in hearing some of the speakers, notably the Chair.
The first speaker Mike Crawforth, RR stated that his Company is trying to be at the forefront of deploying nuclear solutions. He was concerned about the day’s budget and whether Government money is available for development (RR spend a lot of time demanding state handouts). No worries about the size of market, just de-risking the first build. (Actually, while they seem to be making steady progress they are quickly falling behind their international competitors particularly Russia, China and Canada).
They admit that they need to prove that they can drive down the costs by mass production (this needs a mass market) and by modularisation. Need to not over promise (but rather cocksure about the lack of technical risk). They are interested in district heat (which has a poor history in the UK) and synthetic fuels (which are important to RR’s other industries).
Second Speaker. Tom Purnell, AMRC. Lots happening in the market and internationally. AUKUS will take up resource as will British submarine build and power station decommissioning. Government investment decisions will be important. The declaration of nuclear as “clean energy” is good news. Quite a lot of positivity. Need confidence to invest in new processes such as new PV welding processes which reduce the weld time from 10 days to 2 hours which saves CO2, and programme time/costs.
Prof Juan Matthews. Worked on SIR in 1989 but could not build it because the price of gas was so low. He pointed out that only 20% of energy used in the UK is electricity so there is more market for nuclear in heating and transport.
He thinks we need dedicated SMRs for hydrogen production (for which we’ll need a market for hydrogen which does seem to be developing), thermal energy storage (to cope with intermittency of renewables), and high temperature reactors for industrial use and more efficient hydrogen production.
Robert Exley (ONR) leading GDR of RR-SMR. Explained roles of the three main regulators (planning Inspectorate – impact on community) Environment Agency (Discharges etc), ONR (nuclear and conventional safety, security, safeguards) and the role of the 36 site license conditions.
Spoke a bit about the Generic Design Assessment (which has approved four types of reactor, only one of which has proceeded to construction so could be seen as a poor use of resource).
Dr Ray spoke about AUKAS as a showcase for British Nuclear and suggested that a nuclear renaissance was due or underway. The ambition of her department is a demo reactor by the end of the 2030s.
Lots of thought being put into how AMRs might be used in industry (I’m sceptical of the model that has a foundry, or whatever, having its own reactor. Too many eggs in one basket and issues about load following that are only partly answered by molten salt energy stores. If Companies find it easier to outsource their office cleaning, why would they take running a nuclear reactor in-house? It does make some sense in the far north which is why Russia and Canada are more likely to progress the model than the UK ). Much better to have companies that sell electricity on to the grid and customers who take energy off the grid. But maybe I’m old fashioned).
She mentioned the potential issue with the availability of skilled workforce in the future with so many branches of the industry dreaming of good times ahead. Some good work with Universities and Colleges heading in the right direction.
When asked about the technical risks facing the RR SMR Mike Crawforth was confident (over confident? – remember Admiral Rickover https://whatisnuclear.com/rickover.html) that there weren’t really any and the project would stand or fall based on funding, market and manufacturing and assembly innovation. The current cost estimates are made assuming boring technology and boring manufacture in the expectation that innovation will drive costs down over the build time of the fleet.
There was a suggestion that we need bigger reactors than the current RR-SMR design opening the possibility of the initial design being very conservative but later iterations pushing the boundaries more.
There was a question about fuel supplies availability given a worldwide surge in nuclear and the international situation. Confidence was expressed about the near future but the need for a closed cycle was mentioned.
There was a brief discussion about Countries working together to assess and approve the designs of reactors. The ONR representative thought it possible but the UK would retain the final say on reactor designs for the UK. (I’ll only believe international licensing when I see it).
There was a brief discussion about engaging with local communities where a reactor is suggested. Seems to be considered a good idea.
It is a pity that a question about whether or not ONR would license a reactor design and admit that no off-site plan was required was not answered as we ran out of time.
This was an interesting collection of expertise and an interesting topic of discussion. Given that, one hour was probably too short to make the best of the assembled team and while remote attendance is far better than no attendance it does not match the experience of being there and being able to interact more strongly.
My thanks to the organisers for the invitation to the event.
The following article was written by a guest writer, ChatGPT given the prompt “tell me about the Radiation (emergency Planning and public information) regulations 2019”. It is not at all bad. This technology is going to change the way we work!
The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR 2019) are a set of regulations issued by the UK government that provide guidance on emergency preparedness and response in the event of a radiation emergency.
The purpose of these regulations is to ensure that there is a coordinated and effective response to a radiation emergency in the UK. They apply to a range of activities involving radioactive substances, including nuclear power plants, hospitals, and research facilities that use radioactive materials.
Under the REPPIR 2019 regulations, operators of sites that use radioactive materials must conduct regular assessments of the risks associated with their activities, and they must develop and maintain emergency plans that specify how they will respond to a radiation emergency. These plans must be regularly reviewed and tested to ensure that they are effective and up to date.
The regulations also require operators of sites that use radioactive materials to provide public information about the risks associated with their activities, as well as information on how to respond in the event of an emergency. This information must be easily accessible to the public and must be regularly reviewed and updated.
In addition, the regulations establish a framework for coordination and cooperation between the various agencies and organizations involved in responding to a radiation emergency, including the emergency services, local authorities, and national government agencies.
The REPPIR 2019 regulations build on the previous Radiation (Emergency Preparedness and Public Information) Regulations 2001, and they reflect changes in the technology and practices associated with the use of radioactive materials.
Overall, the Radiation (Emergency Preparedness and Public Information) Regulations 2019 represent an important step forward in ensuring that the UK is prepared to respond effectively to a radiation emergency, and that the public is adequately informed and protected in the event of such an emergency.
A policy paper that predates this report stated that “The National Resilience Strategy will specifically consider the roles and responsibilities of CNI owners and operators to ensure high levels of resilience across our most essential sectors. The strategy will also consider how to integrate the roles of CNI owners and operators within a wider framework that also incorporates all levels of government, the wider private sectors, civil society and the public”.
It also said that:
“Much of what is needed is already in place, but improvements can still be made:
government should publish a full set of resilience standards every five years, following advice from regulators, alongside an assessment of any changes needed to deliver them;
infrastructure operators should carry out regular and proportionate stress tests, overseen by regulators, to ensure their systems and services can meet government’s resilience standards, and take actions to address any vulnerabilities;
infrastructure operators should develop and maintain long term resilience strategies, and regulators should ensure their determinations in future price reviews are consistent with meeting resilience standards in the short and long term”.
It recommended that government should introduce a requirement for Secretaries of State to publish (among other things) “clear, proportionate and realistic standards every five years for the resilience of energy, water, digital, road and rail services”. These seem more about the continuity of service (business continuity) with targets “which cover 12 key service areas, including supply restoration, connections and voltage quality” rather than the protection of the public so may not have a great effect on emergency planning as I know it.
It is claimed that “Setting agreed standards is key to effective assurance regimes that ensure that the UK’s most critical systems and organisations are resilient across a broad range of risks, that operators, regulators and stakeholders have confidence in that assurance and have clarity on what further resilience improvements are necessary and desirable” whereas I would argue that correctly identifying the level of preparation that is sensible and then meeting and policing appropriate standards make the difference not setting standards alone, but then I’m not a Civil Servant.
While talking about a “National Strategy”, written and managed by the UK Government, the paper admits that it has no control over the actions of the devolved administrations and seems to suggest that this will continue.
[Para 64] “The UK Government remains fully committed to working closely with the devolved administrations to ensure integration of respective approaches, share best practice and learning, and ensure strong cross-border collaboration – delivering on our duty to protect citizens in every part of the UK. The devolved administrations have their own established and effective local resilience partnerships, and these will not be impacted by the planned strengthening of English LRFs”.
Given that this did not work during the Covid response, what happened to learning from experience?
Early in the resilience framework report it states that “This framework focuses on the foundational building blocks of resilience, setting out the plan to 2030 to strengthen the frameworks, systems and capabilities which underpin the UK’s resilience to all civil contingencies risks”. It is seen as a “long term commitment to systematic changes” [Para 3].
The introduction to this current paper refers to the war in Ukraine, Covid, climate change and “cyber challenges” which makes a change from flu, flood, animal disease, terrorism and industrial accidents which have been the headline risks for many years. Who can remember being told that the government, local authorities and NHS were ready for a severe flu pandemic but watched it fold like a playing card castle in a hurricane when Covid, which shares many of the attributes of flu, hit the world? Apparently “Although there was an understanding of the risk of pandemic flu, treating it as a health emergency meant that there was limited planning outside of the healthcare sector”. So that’s alright then.
We are told that we now have “bold and comprehensive plans to build resilience to specific risks”, personally I’d settle for appropriate and adequate rather than bold which according to my Oxford dictionary means “confident and daring or courageous” or “audacious; impudent”. Confidence in plans too often turns to hubris. Emergency planning is a career that should be reserved for pessimists and worriers once you think that you have comprehensive plans you are on a slippery slope.
The Government’s approach to resilience is to develop a shared understanding of the civil contingencies risks we face; prevention is better than cure and resilience is a whole of society endeavour. This all sounds reasonable.
The weakness is that no matter how many committee hours we spend gazing into crystal balls life can hit us with something we hadn’t considered or something we had considered but with a slight variation that throws our plans out of the window. “No plan survives first contact with the enemy”[1]. However, plans can be flexible and plans can be exercised. Having a framework in which different disciplines work together coordinated by agreed mechanisms and sharing information and expertise should allow a better response to events. The history of the British Government response to major events has included events where a the carefully prepared plan was not used (Fukushima – initially seen as a humanitarian issue so the nuclear plan emergency plan was somewhat bypassed) and where the carefully prepared plan had fallen into disrepair (Flu/Covid where stocks of PPE had been run down on the promise of just in time acquisition and had not really followed through on consideration of the impacts).
As the paper admits “But, while prevention is a key principle, it cannot replace careful and effective management of emergencies as they occur”.
The paper talks about a new “Resilience Directorate” [para 53 and 54] but I cannot find any other mention of it on Government websites. This will work alongside COBR.
On the National Security Risk Assessment (NSRA) the report states that: “The UK Government’s ambition is to create an NSRA process which readily invites external challenge from experts, academia, industry and the international risk community. Relevant information from the NSRA, sensitivity permitting, will be openly available to the public”. This is good to hear and it hasn’t fallen too far short of that target in the past although the public facing National Risk Register has recently been dumbed down to make it “more accessible to the public” but has reduced its usefulness to the preparedness professional.
It also talks about “multiple scenarios” which is encouraging. I’ve previously found that some other countries publish a range of scenarios for each threat against which their plans are prepared and tested. I’ve always thought this good practice provided the system does not become too rigid.
The UK Government could learn from the US 2019 National Threat and Hazard Identification and Risk Assessment (THIRA) which
reports a literature review of existing government response plans and academic studies to develop a preliminary list of 59 threats and hazards.
Consulted with subject-matter experts (SMEs) and reviewed a preliminary list of threats and hazards to select nine scenarios—consisting of both natural and human-caused incidents—that would most challenge the Nation’s capabilities.
Developed a set of 29 standardized impacts, based on in-depth research and stakeholder feedback. These standardized impacts represent key metrics that emergency managers use to understand the magnitude of a disaster, such as fatalities or number of people requiring shelter.
Finalized 22 specific, quantifiable capability targets, representing the most critical and measurable elements of selected core capabilities.
These are used to develop and test plans and confirm that adequate resources, including trained personnel, are available.
Also mentioned is a National Situation Centre [paras 39 – 42] which was new to me. This can be found elsewhere on the Government websites “The National Situation Centre (SitCen) was established to bring data, analysis and insight together, boosting the government’s ability to identify, monitor and manage risks. For example, during the period of extreme heat in July, the SitCen worked with partners to identify vulnerable groups and locations, enabling responders to target support effectively”. This sounds like a useful asset. [see also job advert for Technology Head].
Under the title “Social Vulnerability” [Paras 43 – 48] the paper talks about data sharing before and during crisis and stating an aspiration to improve this that squeezes in a suggestion that additional problems meet ethnic minority and low-income groups which must be reflected in plans and preparations. See also para 32 with regard to communications to these groups and an annual survey of public perceptions of risk, resilience and preparedness.
An expressed intention is to develop a measurement of socio-economic resilience and vulnerability to “provide a snapshot of the key characteristics of local areas”. In my work with them, I have found that LRFs have a very good understanding of their area; being able to make educated guesses about how easy it would be to evacuate areas based on an impression of household size, car ownership and transport links and what proportion of the affected people might use reception centres rather than make their own arrangements for accommodation. To attempt to make this more rigorous and data based may not be easy nor cost effective although in the era of big-data it may be easier than I suspect.
The UK Government will continue to use the Lead Government Department model to guide risk ownership, but there will be further clarification of roles and responsibilities for complex risks. In addition, “Government will create a new Head of Resilience role to provide leadership for this system. This new role will guide best practice, support adherence to resilience standards, and test planning in a meaningful and proportionate way to support the LGD model”.
A commitment [para 31] is given that “The UK Government will improve its communication of risk, focussing on personalisation (for organisations and individuals) as a means to ensure that organisations and individuals have access to relevant, actionable information. We will work closely with both national and local partners to develop and deliver these messages, as well as supporting partners to develop and deliver their own communications campaigns”. Always easier said than done successfully.
The proposed Annual Statement to Parliament on civil contingencies risk and performance and any debates within the House will be one to watch.
The paper reiterates the commitment that “local level will continue to be the building block of the UK’s resilience” and to “significantly strengthen LRFs (in England)” but most of the development seems to be at central government level. Changes at LRF level seem to concentrate on accountability and “clear mechanisms for the assurance of the multi-agency activity”.
Paras 79 – 88 discuss the CCA. This reiterates the central government view that enhanced accountability combined with moving the current advisory resilience standards to a statutory footing will sort any local weaknesses. In addition, they recommend making the Met. Office a Cat 2 responder (sensible) as well as the Coal Authority (I have no view on this).
“The armed forces will continue to play a vital supporting role to the civil authorities in resilience but will not be asked to take on an enhanced role” [in para 93].
Page 33 marks the start of an Action Plan.
Para 110 talks about engaging the private sector (mainly considering CNI) and includes “Raising private sector resilience standards may mean that the UK Government asks more of some parts of the private sector, but it will provide the guidance and information on risks that organisations need in order to be able to meet the standards that the UK Government sets”. The Government providing guidance and information and then asking private industry to put significant effort into something they may not see as a benefit might be a hard sell. Industry needs to know “What’s in it for me?” Again, I hear the voice of Civil Servants living in a world of their own.
To achieve this promulgation of standards “The National Infrastructure Commission has recommended that the UK Government should publish a set of standards for energy, water, digital, road and rail services, to be reviewed and updated every five years” and the Government has committed to do this (“to create common but flexible resilience standards across CNI”) and to develop an action plan to deliver the standards[Para 114]. The CNI standards will be stress tested.
It is intended that there will be a review of the existing regulatory regimes on resilience [Para 119] and regulation may be extended to cover the highest priority sectors and risks that are currently not subject to regulation.
P.131 UK Resilience Forum (UKRF) was established in 2021. The UKRF brings together representatives from the UK Government, devolved administrations, emergency services, responder organisations, the private sector and the voluntary and community sector. This advisory board is aimed at aligning efforts across the system, strengthening relationships between partners, and informing the government’s work on its resilience commitments under the Integrated Review.
P146 “the UK Government will continue to deepen and strengthen its relationships with the VCS (Voluntary and Community Sector) in England. The capabilities of the VCS will be better understood and integrated, as appropriate, strengthening resilience at local and national level in England”.
The Department for Digital, Culture, Media and Sport is also funding the Voluntary and Community Sector Emergencies Partnership (VCSEP) in England with up to £1.5m, to 2025.
Page 49 onwards – Investment
There is a commitment that by 2030 the Government will
“Have a coordinated and prioritised approach to investment in resilience within the UK Government, informed by a shared understanding of risk.
Consider options for funding models for any future expanded responsibilities and expectations of LRFs in England.
Offer new guidance to community organisations and individual householders, to help those people to make more informed decisions about investing in their own resilience and preparedness”.
Some interesting statistics:
Where there is a risk of flooding, the Environment Agency has helped ensure homes are built in a flood safe way. Every £1 spent advising on flood risk matters in spatial planning applications has saved £12 in future flood damages.
During Storm Christoph, 49,000 properties were protected from flooding, with fewer than 1200 inundated.
Improved response arrangements ensured that a Foot-and-mouth outbreak in 2007 caused much less damage (£150 million) than the outbreak in 2001 which cost the UK around £8 billion.
There could be increased funding of LRFs. “DLUHC (Department for Levelling Up, Housing & Communities) agreed a £22m three-year funding settlement or LRFs in England starting in the 22/23 financial year” [Para 174]. This does not commit the additional funding of LRFs to extend beyond the third year leaving the Government to “consider options for funding models for any future expanded responsibilities and expectations of LRFs” [Para 175]. The Government preference is unsurprisingly to spread the cost among responder organisations and businesses.
Page 58 onwards Skills
There is an intent to set up a UK Resilience Academy built on the Emergency Planning College to deliver new training and skills and create a professional pathway. This “will be a physical and virtual campus delivering the scoping, design and delivery of training, wider education, learning and development and exercising for resilience professionals” [Para 195].
Annex B summarises the Framework actions.
Summary
This is a comprehensive document suggesting a step change in the Government’s view of resilience. It is a surprise that it totally ignores Business Continuity Management which seems to me to be closely related to resilience in the sense it is used here and is well imbedded in most businesses and responder organisations.
There is a tendency for the government to consider that improvements require new toys at Central Government level and more standards and accountability at the local levels. This is seen to be true in this report to a certain extent with a new Resilience Directorate, a newish National Situation Centre (SitCen), a new Government Head of Resilience role, a CNI knowledge base, a measurement of socio-economic resilience and vulnerability and the Resilience Academy for central Government on the one hand and a set of standards for energy, water, digital, road and rail services, to be reviewed and updated every five years on the other.
But there is new funding for the LRFs for at least three years and moves to build accountability into the Central Government roles with the proposed Annual Statement to Parliament on civil contingencies risk and performance.
In a recent Spectator article Mr Rishi Sunak complained that the scientific advice that was used in COBR and SAGE was of poor quality in that it did not clearly outline what was known and what was assumed and the impact of assumptions on the output.
‘I was like: “Summarise for me the key assumptions, on one page, with a bunch of sensitivities and rationale for each one”,’ Sunak says. ‘In the first year I could never get this.’ The Treasury, he says, would never recommend policy based on unexplained modelling: he regarded this as a matter of basic competence. But for a year, UK government policy – and the fate of millions –was being decided by half-explained graphs cooked up by outside academics.
Would the nuclear industry fall into this trap if advising people to shelter or can we do better? Can we explain why we might ask people to stay in their home during a nuclear accident that is releasing radioactive material to the atmosphere? Here is my attempt.
I think that one page is optimistic if briefing those new to the subject. Covid was a little different in that a couple of weeks into the crisis COBR and their customers would be better up to speed. So here is my attempt at a one page brief for a hypothetical situation and introductory annex.
Advice brief
(This is what the one-page advice summary may look like)
Advice given to STAC/COBR on 12/12/22 with regard to public protective actions
The default automatic public protective action of recommending everyone in the DEPZ take shelter was promulgated using the automatic phone system (reach estimated to be 50% of those in the DEPZ) as well as on broadcast and social media starting at 10.15 on 12/12/22 following the raising of the alarm by the Operator at 10.00 on 12/12/22.
Evidence suggests that compliance has been [good/indifferent/bad].
The situation at 11.30 is that the release is continuing but gradually reducing as temperatures and pressures reduce. Attempts to stop the leak are also continuing. Plan A has an estimated 50% chance of succeeding by 12.00 and a 70% change of succeeding by 12.30. Independently Plan B has an estimated 90% chance of succeeding by 13.00. Irrespective of these plans the release is expected to end by 14.30.
The dose estimates are based on the NAME computer model with best estimate parameters, a source term estimate from the operator, weather forecasts from the Met. Office and the advice based on the Lower Emergency Reference Level of dose for evacuation from the PHE (now UKHSA). Deviations of the actual dispersion from the modelled dispersion may lead to different dose distributions. In particular, deviation of the weather conditions from those forecast would change the distribution of potential dose off-site.
It is assumed that shelter reduces dose by 40% compared to being outside. This is the default recommended by PHE (now UKHSA). Delays in achieving shelter or shelter in a less capable building will reduce the gains in terms of averted dose. Conversely better than expected performance will increase the dose averted.
Considering that the most likely outcome to be the success of plan B at 13.00, it is estimated that sheltering if applied immediately, or is already in place, will avert dose equivalent to the lower ERL for shelter to 2.3 km downwind. This reduces to 1.8 km if plan A succeeds by 12.30.
Considering the weather forecast, particularly the wind direction, we recommend that Sector B be asked to shelter out to 2.5 km, or somewhere beyond, because estimates show that it is in this region that the lower ERL for shelter is likely to be exceeded.
Thought should be given to sheltering sectors A and C to the same distance in case the predicted direction of plume travel proves to be slightly inaccurate.
The other sectors could be asked to remain in shelter as a precaution against the dispersion estimates (notably wind direction) being very wrong or released from shelter if there is confidence in the dispersion estimates and the benefits of doing so outweigh the risks.
If the accident develops in unexpected ways leading to an increase in the release rate or a longer duration release this provision may be found inadequate after the event. Conversely, if the release is terminated sooner, they may retrospectively be thought of as excessive.
Subject to the caveat about the release not being significantly greater than currently estimated, there is confidence that the off-site doses will not exceed the Lower ERL for evacuation therefore evacuation is not recommended as a prompt protective action for the public.
Annex
Radiation is to be respected not feared.
Radiation has many positive benefits to modern society particularly in medicine, engineering and, of course, power generation. I am aware that post-accident we probably wouldn’t include this automatic PR padding.
We know that radiation in large enough doses (over 1,000 mSv) over a short period of time leads to injury (known as deterministic effects). The literature contains enough gruesome pictures of radiation burns and stories of injury and death following radiation exposure to take this as fact.
There are also longer term effects, such as the potential for cancer induction, to take into account (Stochastic effects). The probability but not the severity of these effects, which may take years to express, are believed to be proportional to the radiation dose. ICRP-103 states that “in the case of cancer, epidemiological and experimental studies provide evidence of radiation risk albeit with uncertainties at doses about 100 mSv of less”. It is assumed, but generally also widely accepted, that in the range from 1 mSv to 100 mSv the risk of harm in this manner is directly proportional to dose.
A lot of research has been undertaken and the currently accepted model (from ICRP Publication 103, 2007) assigns detriment-adjusted risk coefficients (see note) of 5.5 10-5 per mSv for cancer and 2.0 10-6 per mSv for heritable effects in the whole population (including infants, children and adults). This means that each mSv of dose increases your risk of cancer by 5.5 x 10-5 which is low compared to your overall risk of cancer (Cancer research UK is claiming that “1 in 2 UK people will be diagnosed with cancer in their lifetime”) but arguably worth avoiding if possible and cost effective.
Note:
Detriment-adjusted risk is defined as “The probability of the occurrence of a stochastic effect, modified to allow for the different components of the detriment in order to express the severity of the consequence(s)”. It is an attempt to summarise in one number the harm that radiation may do to you in the years after exposure.
Radiation Protection is a well-developed science and our ability to reduce radiation doses is good and improving. In an accident (and in planning for accident response) we aim to reduce dose well below the thresholds for deterministic effects (aiming to keep doses below 100 mSv) and the reduce dose further, if possible, to reduce the risk of stochastic effects.
Given that there is an average background radiation dose of about 2.7 mSv to the UK population, putting significant effort into reducing additional doses that are much below this range is rather pointless.
You may receive a radiation dose in a nuclear accident.
Highly radioactive material is an unwelcome by product of the energy generated in nuclear reactors. Great effort is taken to ensure that this dangerous material is kept within several layers of containment and is unlikely to get into the environment in damaging quantities.
However, in the event of a nuclear accident that releases radioactive material (dusts and gases) to the air the radioactive material will drift downwind and spread out as it goes. If we know the rate at which radioactive material is being released and the weather conditions, particularly the wind direction and speed, we can estimate the concentrations of radionuclides in the air at any point downwind as a function of time.
From this we can estimate the radiation dose that a person standing at that point will be exposed to. This radiation dose is composed of dose due to inhaling the radioactive material (inhalation dose), dose due to being near the radioactive material (cloud dose and ground dose) and dose due to eating the radioactive material as contamination in food and water (ingestion dose).
We can also estimate the dose averted (saved) if we move that person out of harm’s way or put them in a shelter at some time before or during the release.
Inhalation dose is usually the dominant component. Inhalation and cloud dose occur during plume transit. Ground dose (due to radioactive material deposited on surfaces) and ingestion dose (due to contaminated food and drink) occur for some time after plume transit depending on circumstances. It is possible for deposited activity to be kicked up in the air again, but the doses (resuspension dose) resulting from this are a very small fraction of the original dose (see box).
Box
When a plume of radioactive dust travels across an area, a fraction of the activity is deposited onto the ground. Of this fraction, a further fraction is resuspended. Taking plausible values for these fractions from the literature (1 x 10-2 Bq.m-2 per Bq s m-3 for deposition and 0.75 Bq s m-3 per Bq m-2 for resuspension over a year), it follows that the dose over one year from resuspension is likely to be about 1% or less of the plume transit dose (1 x 10-2 x 0.75 = 7.5 x 10-3 Bq.s.m–3).
Sheltering, evacuation and stable iodine may be used to reduce your radiation dose in certain circumstances.
If you are given adequate warning of a nuclear accident, or the release might be expected to continue for several hours, there are simple steps that can be taken to reduce the potential radiation dose to the public.
Going into a building (shelter) reduces the inhalation dose because, for a period of time at least, the airborne concentration inside the building will be lower than that outside. The building also provides physical shielding that reduces cloud and ground shine.
Leaving the area before the plume arrives or before the release finishes (evacuation), reduces dose by removing the person away from the hazard. Evacuation is more difficult to organise and achieve than shelter and can be very disruptive. Some vulnerable groups can be harmed in evacuations (Fukushima experiences) and psychological impacts can be significant (Chernobyl and Fukushima experience). Because it is more difficult than shelter, we initiate evacuation at a higher dose saving threshold than shelter.
Stable iodine tablets can be used to saturate the thyroid gland to prevent it taking up radioactive forms of iodine that might be released in a reactor accident. This reduces thyroid dose and therefore the probability of thyroid cancer in later years.
The latest government sponsored advice on these “Protective actions” is given in CRCE-049. This justifies and restates Emergency Reference Levels which it defines as the “dose criteria that apply to the justification and optimisation of sheltering-in-place, evacuation and administration of stable iodine”. ERLs come in pairs. The Lower ERL gives the value of averted dose below which a protective action is unlikely to be justified. The Upper ERL gives the value of averted dose above which the protective action is strongly recommended. Between the two values is an area where the difficulty of implementing the protective action on the day comes into play in the decision-making process.
We advise people in some areas to shelter because we think the dose saving in those areas makes it worthwhile and do not advice people to shelter in those areas where the costs outweigh the benefits.
In the event of a nuclear accident urgent attempts will be made to reduce and stop any release of radioactivity to the environment. Judgements will be made about how long the release will continue and how the release rate will vary with time.
This information and forecasts of the local weather conditions will be used to estimate the dispersion of radioactivity in the environment and its dose implications to members of the public in different locations off-site. These dose estimations, and estimations of the dose that could be saved by implementing protective actions will form part of the decision-making process.
Responders with local knowledge and the information collated in the off-site plan will consider the expected dose distributions and the ease at which protective actions could be put in place to determine which areas to include in protective action advice and which areas not to.
Areas subject to protective actions will be those where the avertable dose seems likely to be above the relevant Emergency Reference Level (protective action is likely to do more good than harm) and areas where the advice is given not to implement the protective action will be those where the costs (in the broadest sense) of implementing the protective actions exceeds the likely benefits.
Uncertainties
They are considerable uncertainties in this chain of argument.
The detrimental impact of radiation at these levels of dose and dose rate. We use the international consensus models of radiation harm. Source: ICRP.
The values that should be chosen for the ERLs. We use current national advice which is consistent with current international advice. Source: UK HSA.
The radiation doses the public may receive in the event. We use models that consider all the data available (situation on site, any measurements that might imply the release rate on site, release prognosis (possibly worst reasonable outcome and best estimate outcome), off-site measurements of radiation and radioactivity levels, weather forecast). These models give answers that depend on the assumptions made in the input data (most sensitive to the source term and weather conditions), the assumptions in the model itself (the physis of dispersion and how it is conceptualised) and the uncertainty in implementing the model on a computer. Source: Operator, UK-HSA and Met. Office and potentially with ONR oversight at each stage.
This data will be sparse, time will be short and considerable professional judgement will be utilised so the dose estimates will be subject to considerable uncertainty.
The avertable dose depends on how quickly the alert can be promulgated, how quickly and how well the public respond, and how effective the protective action will be. Again, there are some uncertainties in these parameters.
Summary
The impact of these uncertainties is that the advice to implement protective action over a particular area will, itself, be uncertain. A different set of assumptions may lead to a larger area, a smaller area or a different area.
There is a tendency to err on the side of overestimating dose and rounding up predictions so the protective actions are likely to be recommended over a wider range than the underlying science and situational awareness might suggest.
Afterword
The “costs” of short-term shelter are not considered to be great. Initial overstatement of the area that would benefit from shelter would not carry a great cost burden providing it can be withdrawn in a timely manner. Over enthusiastic emphasis on strict shelter (for example, preventing emergency services and essential carers into the area in cases of need) over a wide area and a prolonged period would begin to accrue disproportionate costs.
Evacuation and the subsequent care of a significant number of people has its problems in terms of organisational complexity and resource requirements so more care is required to ensure it is not used indiscriminately.
The taking of stable iodine tablets is not expected to result in many health impacts but if advice is given to take them too soon there may be a need to issue a second round of tablets which has resource and dose-to-responder issues.
The real psychological problems related to nuclear accident seem to result from the stresses of living in a post-accident area with environment contamination leading to social and economic disruption and stress. Management of this is very important and starts soon after the accident but generally after the prompt stage.
We are living in a period when the costs of the Covid lockdowns seem to be noticeable if not quantifiable; disrupted education for our children with increased attainment gaps between the rich and the poor, even longer waiting lists in the NHS, a rise in the late detection of cancer, excess deaths from all causes and economic dislocation.
There is an interesting article in the Spectator magazine from a few weeks ago in which Rishi Sunak says that these effects could have been predicted, which seems sensible, and that, if they had been given proper weight, we would have spent less time in lockdown, which is less clear.
We must remember that we feared that Covid would leave many thousands of people struggling to breathe and a lot of them dying an uncomfortable and avoidable death because of lack of medical facilities. We must also remember that there were many voices calling for stricter rules to be applied for longer.
Before we attack the costs of lockdown, we should maybe estimate how many peoples’ lives it saved. I don’t know if that estimate is available. Would the UK deaths from covid (currently standing at 171,048 as of 5/9/22 according to coronavirus.data.gov.uk) have been a few times higher or orders of magnitude higher? The first lockdown on 23rd March 2020 was two weeks before the first peak and rapid decline in cases – coincidence?
The lockdown came when the scientists advising the government reported that the Covid deaths could reach 500,000 if no action was taken but could be below 20,000 if Britain locked down. That is quite a range of outcomes. It is not often someone has the chance to save 480,000 lives.
There then came a period of “following the science”. Rishi Sunak states that any attempt to discuss the downside costs were brushed aside and a “fear narrative” launched to increase adherence to shut down.
He also reports that he could not get his hands on an explanation of the assumptions, uncertainties and sensitivities behind the headline numbers and he says that “UK government policy – and the fate of millions – was being decided by half-explained graphs cooked up by outside academics” (it is not clear to me if he was talking about millions of people or millions of pounds).
The real problem, and Rishi Sunak identifies it, is that a lot of weight was put on the scientific educated guesses about the possible fatality tally and maybe not enough thought into considering the full range of costs. Whether or not that would have, or should have, changed the lock-down strategy is unclear.
What does this mean for the nuclear industry? We have arrangements to move people into shelter, evacuate them from their homes and provide them with thyroid blocking drugs in the short term and food controls and, possibly, area controls in the longer term.
We have scientists advising the Strategic Co-ordination Group via STAC or directly (I used to be one when I worked for Magnox). We have another set of scientists advising SAGE, who feed into the national response.
The Strategic Coordinating Group is composed of senior representatives of the emergency services, local government and health bodies. Do they have the ability and confidence to put the estimated doses and avertable doses into context and make clear judgments on the need for protective actions? What should we do with playgroups, schools, hospitals and care homes within the areas potentially affected by a severe nuclear accident? Do we shelter the population for 2 days or 2 weeks or do we drop the shelter advice once the remaining avertable dose is below the lower ERL for shelter? How will the public and media react? Do we have better answers now than we had three years ago?
The nuclear industry should look at the deliberations that went into lockdown and other counter-covid instructions and at the public response to them in the short, medium and long term to see if there are any lessons to learn.
Rishi Sunak has given us his inside story. There are many more to hear and balance.
This report discusses the emergency preparedness we may wish we had put in place if we find ourselves responding to a severe nuclear accident that has resulted in very high doses to some members of the public and has rendered some areas uninhabitable and others problematic. It argues that in that situation you need mature systems to share complex information with individuals and communities, the ability to retain their trust and allow them to make important life-choices while also having in place polices and resources to support the business, social and family life in areas blighted by radioactive contamination. It then discusses the problem in some depth and with clarity while skating over the difficultly with providing solutions.
This publication updates and supersedes Publications 109 and 111. It also supersedes the recommendations published previously in Publications 40, 63, and 82.
The executive summary starts “Large nuclear accidents result when there are significant releases of Radioactive material into the environment, impacting widespread areas and affecting extensive populations. They are unexpected events that profoundly affect individuals, society, and the environment. They generate complex situations and legitimate concerns, particularly regarding health, for all those affected by the presence of undesirable sources of radioactivity”.
I wonder if the use of “legitimate concerns” is fully justified. The two big accidents we all know about, Chernobyl and Fukushima, have had societal and individual impacts well beyond those suggested by our understanding of harm radiation causes to living tissue. It is either the unreasonable concerns about radiation that are causing the problems or our understanding of radiation and the basis of our use of the art of radiological protection in emergency planning that is faulty.
Interestingly the executive summary also states “The Commission recommends that plans should be prepared in advance to avoid severe and long-term consequences following a nuclear accident. Such preparedness plans should comprise a set of consistent protective actions, adapted to local conditions at nuclear sites, taking into account the societal, environmental, and economic factors that will affect the impact of the accident and its response”. I believe that this is suggesting that you go beyond the preparation to rapidly introduce shelter, evacuation and thyroid blocking and that you use locally set trigger points rather than the national ERLs.
The Commission see the response to a large nuclear accident in three phases and relate them to exposures situations thus:
Figure 1 Phases and exposure situations
The report states that a “Large nuclear accidents affect all dimensions of individual and social life” with concern about the health effects of radiation being the major concern but the situation is complex and includes “social, psychological, environmental, educational, cultural, ethical, economic, and political factors associated with the consequences of the accident”. It asks for particular attention to be paid to the needs of “some vulnerable groups, particularly pregnant women, children, people with regular/ specific medical care, and elderly people”.
You could argue that the wide range of impacts listed above would not occur if it were not for the contamination and the concern about health effects. Do you tackle the excessive concern or the results of that concern? In the real world, you probably need to do both.
The report takes a couple of pages to review the effects of radiation on human health.
On societal consequences it opens with “The sudden presence of radioactive contamination is perceived as undesirable, illegitimate, and dangerous, and generates a desire to get rid of it. This presence in the living environment of humans profoundly upsets the well-being of individuals and the quality of life of affected communities. It raises many questions, concerns, and fears; generates numerous views; and worsens conflicts. Some residents will choose to stay in affected areas, when this is allowed, and others will leave. Among those who leave, some will return and others will relocate permanently. This can significantly affect community life and demographics, with a notable decrease in the number of inhabitants, especially young people, as illustrated after the Chernobyl and Fukushima accidents”.
And later “Beyond the widespread fear of radiation in all sectors of the population, sociological studies have also revealed: a collapse of trust in experts and authorities; disintegration of families and social ties; apprehension about the future, particularly for children; and a progressive feeling of loss of control over everyday life. All of these consequences affect the well-being of people and pose a threat to their autonomy and dignity”.
The negative image of the affected areas, a reluctance to visit and a rejection of the people living there and any goods produced there continuous to blight the affected area and constrain social dynamics.
The economic impacts can be profound. Local agriculture is likely to suffer. Radiological contamination may affect critical infrastructure. All this has an impact on local businesses and employment, as well as key public services such as government services, security institutions, medical facilities, financial systems, public health services, and education facilities. For local companies their staff, workplaces, products, and image can all be affected. Change in the local demography, as the young and anxious abandon the area, is another factor influencing the overall economy of affected areas.
People are destabilised by the complexity of the situation, both in the immediate response and in the longer term and may have many questions. “People affected by a nuclear accident can feel anguish, dismay, discouragement, helplessness, dissatisfaction, frustration, and anger. Many affected people report feeling a lack of control over their individual living and working conditions, and this is linked to a high level of psychological stress”. This can result in psychological and psychosomatic disorders.
Almost as an aside the report states that “Studies reported an elevated rate of depression and post-traumatic stress disorder among the responders who were directly confronted by the disaster scene, potentially inducing a threat to their lives”. I think the report could have aided clarity by better splitting the discussion about responders from that about affected members.
“Studies have also reported that people who are confronted with radioactive contamination in their daily lives, even if only a small amount, and evacuees facing poor living conditions with no clear view about their future are more vulnerable to anxiety, stress, and depression”.
Parents with young children, especially those in contaminated areas, are particularly vulnerable to anxiety with negative impact on their health and the on the family unit.
Change in lifestyle and reduced circumstances are also stressors.
Experience has shown that “shortly after an evacuation, vulnerable populations such as patients in hospitals and the elderly in care homes are particularly susceptible to hypothermia, dehydration, and the worsening of pre-existing conditions. These can lead to increases in mortality. Meanwhile, children living in evacuation centres are more prone to infectious diseases due to overcrowding and stress caused by inadequate facilities. They can also be affected psychologically, with the subsequent development of emotional problems. Verbal abuse and bullying of evacuated children can form an additional source of stress”.
“In the intermediate and long-term phases, those who remain in the contaminated areas, as well as those subject to temporary relocation, can experience a range of long-lasting physical health effects due to their changes in lifestyle, including obesity, diabetes, cardiovascular and circulatory diseases, hypertension and chronic kidney disease due to poor diet (e.g. lack of fruit and vegetables), lack of exercise, substance abuse, and restricted access to medical facilities or opportunities to seek treatment. Furthermore, restrictions on outdoor play due to the presence of radiation can lead to higher levels of obesity in children”. None of these effects are directly due to ionising radiation.
Figure 2 The Optimisation Process
The standard picture to show how reference levels help reduce dose over time is reproduced below.
Figure 3 The role of RLs in the optimisation process
The concept is that you set a reference level and then try to identify those people whose predicted dose is above that level and concentrate on measures to reduce their dose. This is expected to further reduce the doses to some of the people already below the reference level and the dose distribution shifts to the left. It is suggested that after time the reference level is reduced and further steps considered.
What this cosy picture misses is that each engineered reduction in the dose distribution, as opposed to reduction with time as the radioactivity decays or weathers, is accomplished by the imposition of another protective action or by a decontamination exercise that affect people who already experience low doses. Each these have costs; financial costs and lifestyle costs. How can we be sure it is worth it?
The Commission recommends including, where feasible, the views of all relevant stakeholders to decide the level of ambition to be achieved by selecting a given reference level. A laudable but difficult ambition.
The report has a long section (Section 3.2) on the need to understand the dose uptake of the public in the short, medium and long term which entails an understanding of the initial distribution of deposited radioactivity, the migration of radioactive material in the environment and food chains and the habits of people before and after the event. Understanding this, and the limitations of the results, is a major undertaking and requires specialist experience and knowledge.
The effort and resources required to triage the public to identify those that would benefit from medical treatment, decontamination or counselling might be significant (and the process may be a significant stressor of the population).
The report states that “Measurement data should be collected centrally and made available as soon as possible to all relevant organisations in charge of managing the early and intermediate phases in order to assist them in making decisions on protection. For the sake of accountability and transparency, the Commission recommends that this information should be shared with members of the public, accompanied by a clear explanation, while respecting the protection of personal information”.
In section 3.3, the report identifies that “Individuals who may be involved in the response to an accident are diverse in terms of their status: emergency teams (e.g. firefighters, police officers, medical personnel), workers (occupationally exposed or not), professionals and authorities, military personnel, and citizens who volunteer to help”.
The report suggests treating non-responders on-site in the same manner as the off-site population (shelter, evacuate and thyroid block) but “those who are involved in the early-phase response should be managed as responders, applying the principles of justification of decisions and optimisation of protection.
“The justification of decisions that may affect the exposure of responders should be taken in light of the status of the damaged installation and its possible evolution, as well as the expected benefits in terms of avoidance or reduction of offsite population exposures and contamination of the environment”.
“Overall, these decisions should aim to do more good than harm; in other words, they should ensure that the benefit for the individuals concerned and society as a whole is sufficient to compensate for the harm they may cause to the responders”
The report recognises that it may be hard to predict the doses to responders in situations where sources are out of control, particularly in the early stages where there is very little dose characterisation. It suggests that a reference level of 100 mSv may be appropriate for responders but “would be justified only under extreme circumstances”. Levels above this would be exceptional, reserved for life saving and to prevent further degradation of the facility.
This section is adequately covered by any organisation working within the REPPIR-19 regulations.
The report also suggests that those likely to be involved in the off-site response such as emergency services. Medical staff and bus drivers should be identified in advance and trained to appropriate levels of understanding.
Section 3.4.1 describes and justifies the early phase protective actions of shelter, evacuation and temporary relocation, thyroid blocking, decontamination of people, precautionary foodstuffs restrictions and those in the intermediate phase; temporary relocation, foodstuff management, management of other commodities, decontamination of the environment, management of business activities. It is a clear and competent description of the situation but does not add greatly to the body of knowledge.
Section 3.4.3 “The co-expertise process” is more interesting. It recommends a “process of co-operation between experts, professionals, and local stakeholders aims to share local knowledge and scientific expertise for the purpose of assessing and better understanding the radiological situation, developing protective actions to protect people and the environment, and improving living and working conditions”.
“From an ethical point of view, the co-expertise process focuses on the restoration and preservation of human dignity, which is one of the core values of the system of radiological protection (ICRP, 2018). More particularly, the process can be seen as reflecting inclusiveness, which is the procedural value behind the concept of stakeholder involvement. Beyond that, it allows the implementation of empathy (i.e. it provides the experts with opportunities to immerse themselves in and to reflect upon the experiences, perspectives, and contexts of others), which in turn helps find suitable and sustainable protective actions”.
Figure 4 Working with the community
The report suggests that being transparent about the monitoring programme, what is measured, why and what it means in terms of dose paths helps people by “taking into account radiological criteria and comparison with other situations of radiological exposure”.
This openness and discussion can then extend into the realm of identifying, implementing and managing protective actions with those directly affected feeling some ownership and understanding of the decision-making process rather than being on the receiving end of “expert” pronunciations.
“Protective actions implemented during the early and intermediate phases should be lifted, adapted, or complemented when authorities and stakeholders consider that these actions have achieved their expected effect, or when their continued application is no longer justified (i.e. cause more harm than good in the broadest sense)”. This is now known to be harder than expected and needs the coordination and support of various organisations and, of course, the public.
At high levels of residual contamination there may be difficult decisions to make about preventing populations returning to the area. A slightly gentler outcome would be to allow people back to collect valuables and precious materials but not to stay. Paragraph 175 discusses the conditions that might need to be mat before you allow people to live in a highly contaminated area.
The report (Section 4) suggests that the long-term phase has started when you’ve agreed that the facility is secured and decisions have been made about the long-term future of the area. At this stage the rehabilitation of the living and working conditions and the interaction of individual and community is complex. Management based on radiological principles and criteria was not sufficient to respond to the challenges.
“Experience has shown that large differences in levels of exposure may exist between neighbouring communities; within families in the same community; or even within the same family according to diet, lifestyle, and occupation. These differences generally result in a skewed dose distribution where a few individuals receive a larger exposure than the average”. This requires people in the area to be supported and informed of the factors that contribute to their radiation dose “not only to ensure adequate protection against the radiation, but also to guarantee sustainable living and working conditions, including respectable lifestyles and livelihoods”.
Section 4 covers the radiological characterisation in the long term and the protective actions that might be appropriate.
“The protective actions available for the long-term phase are many and varied, ranging from removing the contamination present in the environment (decontamination and waste management) to implementing collective and self-help protective actions to control external and internal exposures (management of food products, dietary advice)”.
“To restore individual well-being and the quality of community life in the affected areas where people are allowed to reside, there is a need to develop accompanying measures beyond the protective actions themselves. A first objective is to re-establish technical networks (water, electricity, telephone, etc.), infrastructure (roads, railway lines, etc.), and the services necessary for public life (schools, hospitals, post office, banks, shops, social activities, etc.). It is also important to ensure the overall socio-economic development of the territories concerned (establishment of industrial zones; support for the maintenance and establishment of agricultural, industrial, and commercial activities; etc.).”
“In the long-term phase, exposures of people, fauna, and flora are reduced gradually over time due to the combined effects of protective actions and natural processes. As a result, years after a nuclear accident (or even decades in the case of a severe accident), it is advisable to consider whether to maintain, modify, or terminate protective actions.”
Section 5 discusses preparedness planning for a large nuclear accident. It suggests that “For the long-term phase, preparedness aims to identify the societal, environmental, and economic vulnerabilities of potentially affected areas, and to develop guidelines that are sufficiently flexible to cope with whatever happens in reality”.
It further suggests that a prerequisite to preparedness is acknowledging the possibility that a nuclear accident could occur and seeking representation of all stakeholders in preparedness. I think that here the Commission should acknowledge that local, regional and national resilience teams have risk assessments that tell them that, that for example, floods and animal or human disease are far more likely and would be extremely disruptive and that that is where they should devote their preparedness resources rather than on extremely rare (we hope) severe nuclear accidents.
REPPIR-19 does require that severe accidents be considered, albeit in outline, and maybe tested occasionally. This will raise awareness within the responding organisations but is unlikely to push preparedness significant further forward with regard to interacting with an alarmed community.
“Practically, preparedness plans should contain a set of appropriate protective actions and arrangements for implementing them, including reference levels. Provisions for the deployment of necessary equipment for the characterisation of the radiological situation and the implementation of the co-expertise process should also be considered. In addition, specific communication schemes to inform the public and other stakeholders, as well as provisions for the training of those to be involved in the response, should be developed. These plans should be subject to regular exercises involving the various stakeholders”. This looks more like the detailed planning that is undertaken for what used to be called design basis accidents.
Importantly, and realistically, the report states that “The preparation of detailed plans for accident and post-accident management is a national responsibility”.If there were to be a severe accident the aftermath would involve difficult discussions. These would include discussions about which areas to abandon, which areas to allow to return to a controlled usage and which could be returned to normal. Further discussions would then be needed about how much decontamination to attempt and where (children’s playgrounds and schools, public areas, peoples’ gardens and homes?) and about how to avoid economic blight and stress.
The report concludes that “For this purpose, experts and professionals should adopt a prudent approach to manage exposures, seek to reduce inequities in exposures, take care of vulnerable groups, and respect the individual decisions of people while preserving their autonomy of choice. Experts and professionals should also share the information they possess while recognising their limits (transparency), deliberate and decide together with the affected people what actions to take (inclusiveness), and be able to justify them (accountability). The issue at stake is not to make people accept the risk, but to support them to make informed decisions about their protection and their life choices (i.e. respect their dignity)”. That sounds really difficult!
Central government should maybe look at this report closely and see what preparations might be appropriate against the very unlikely severe nuclear accident. The report suggests “for the long term phase, preparedness aims to identify the societal, environmental, and economic vulnerabilities of potentially affected areas, and to develop guidelines that are sufficiently flexible to cope with whatever happens in reality”. This appears to be suggesting applying the tools of Business Continuity Management and Business Disaster Recovery to communities.
Central Government may, for example, decide to have briefing materials ready to educate community influencers such as GPs, local council members, MPs, church leaders, media and teachers so that they can cascade knowledge and understanding and report back the views of the community. This might help kickstart the transparency and inclusiveness and reduce the stage at which the population loses trust in “experts”.
They may decide to produce guidance about what to do if homes, streets and schools are contaminated to a range of levels working out how to allow life as near as normal as possible. A world in which children cannot play in the open will never be a healthy and happy one.
There is no doubt that if such an accident happens we will wish that we had done more work preparing for it (or more work preventing it).
Transport packages are designed with a graded approach, meaning that the higher activity and more mobile forms of radioactivity get transported in more robust containers. This is designed to ensure that most emergencies during transport have limited radiological consequences and can be resolved in a relatively short period. However, there are always the low probability, high consequence accidents to keep us awake.
The objective of this publication is to provide recommendations on emergency preparedness and response for the transport of radioactive material. These recommendations form the basis of achieving the goals of emergency response described in GSR Part 7.
The recommendations in this Safety Guide are aimed at States, regulatory bodies and response organizations, including consignors, carriers and consignees.
Section 2 covers national arrangements which should integrate and coordinate the capabilities of responders and ensure that their roles and responsibilities are clearly specified and understood.
“The government shall make adequate preparations to anticipate, prepare for, respond to and recover from a nuclear or radiological emergency at the operating organization, local, regional and national levels, and also, as appropriate, at the international level.”
There is a lot of detail, 14 pages of it, including a description of what the consignor’s and carrier’s plan should contain (para 2.57). These are not a-plan-on-a-page.
Section 3 is about preparedness and response. It talks about a concept of operations as “a brief description of an ideal response to a postulated emergency, used to ensure that all the personnel and organizations involved in the development of emergency response capabilities share a common understanding”. It also discusses the objectives to consider.
The report then goes through the urgent response phase where those on the scene and first responders are determining the situation and, in particular, looking for evidence of failure of containment or shielding and acting accordingly. It gives an aide-memoir for reporting the situation (3.14), the priorities for response (3.19) and protective actions to consider (3.30).
A transition to either a planned exposure situation or an existing exposure situation, depending on the circumstances might be required if the environment is contaminated. We are told that “the transition phase commences as early as possible once the source has been brought under control and the situation is stable; the transition phase ends when all the necessary prerequisites for terminating the emergency (these are given in 3.34) have been met” (3.38).
There is a section on Training, Drills and Exercises (3.43 – 3.53).
Section 4 focuses on road, rail, sea, inland waterway and air in turn, talking about how and why these modes are used and any special features to consider.
Section 5 looks at transport events initiated by nuclear security events and the extra considerations put into play, including the requirements for crime scene preservation.
Appendices give advice on (1) developing national capability and (2) types of events that might lead to a transport emergency (useful for setting scenarios).
Annex 1 reviews IAEA advice on transport regulations, including classification, signage and packages.
Annex 2 is a model event notification form.
Annex 3 is a template carrier or consignor emergency response plan.
Annex 4 provides 7 scenarios to consider.
Note:
The ONR have a considerable body of reference material relating to the transport of radioactive material which can be found at https://www.onr.org.uk/transport/
This states that “CDG09(19) require duty holders (both the consignor and the carrier) to have a plan where they have reached the conclusion that a radiation emergency might occur. The emergency plan must detail the arrangements to restrict, so far as is reasonably practicable, the radiation exposure of any person that may be affected by a radiation emergency before the carriage of radioactive material takes place. This includes the vehicle crew, the public, attending emergency services and any persons exposed to ionising radiation as a result of a loss of radiation shielding, release of all or part of the contents of a package or an uncontrolled criticality when transporting radioactive material”.
It also notes that “Provision of information in the event of an emergency to those likely to be affected is placed on local authorities through Regulation 22 of REPPIR19.”
In their November 2020 document Five Steps to Transport Emergency Planning ONR outline five steps:
