Rishi Sunak’s Inside View and the future of nuclear accident protective actions

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?

covid graph

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.

ICRP 14: Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident

 This report has been made free to download by the ICRP.

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:

phases

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.

Community

Figure 2 The Optimisation Process

The standard picture to show how reference levels help reduce dose over time is reproduced below.

Optimisation

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”.

co-expertise

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).

Preparedness and
Response for a
Nuclear or Radiological
Emergency Involving
the Transport of
Radioactive Material

https://www-pub.iaea.org/MTCD/Publications/PDF/PUB1960_web.pdf

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 includes guidance on risk assessment under IRR-17 https://www.onr.org.uk/transport/irr17-reg-8-transport-guidance.pdf and Guidance on emergency planning and notification for the transport of class 7 goods https://www.onr.org.uk/transport/emergency-planning-notification-class-7.pdf

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:

  1. Evaluate whether an Emergency Plan is required
  2. Preparing an Emergency Plan
  3. Test, Review and Revise the Emergency Plan
  4. Implementing the Emergency Plan
  5. reporting requirements after an emergency

NAO on the decommissioning of the AGRs

I think that this report by the National Audit Office (NAO) is quite worrying. It seems that the only thing we know about the defuelling and decommissioning of the AGR sites is that it will cost a lot of money; almost certainly more than has been put aside for the job.

The current agreement is that as soon as EDF declare a station off the bars permanently the costs of the site transfers to the decommissioning fund, EDF are paid to defuel the site and then ownership “of all land, assets and contracts required by Magnox Ltd to commence (commence not finish!) deconstruction on the sites” transfers to the NDA i.e. it seems that EDF can maybe choose to retain the assets they fancy.

EDF estimated that the fixed costs to manage and maintain a station that is not generating electricity but still holds fuel are around £140 million per station per year, compared with around £25 million to £35 million per station per year once the fuel has been removed. It does, of course, remain to be seen how realistic these values are.

The NDA will not know the exact details of what will transfer nor have a full understanding of the associated costs and liabilities until closer to the expected transfer. The long-term success of this scheme then depends on the ability of the NDA to deliver efficiencies from combining the AGR stations with the existing portfolio. Not that they have an unblemished history.

Since 2021 the NDA has adopted what it terms a rolling decommissioning strategy for its Magnox stations. This approach, it believes, could allow reactors to be decommissioned sooner. Stakeholders the NAO spoke to with technical expertise and knowledge of the AGR stations expressed differing views on the applicability of a rolling strategy to the AGR fleet.

I find it worrying that the way in which EDF, NDA and Magnox Ltd will work together to plan for transfer of the stations is set out in a Memorandum of Understanding because they could not agree the terms of a legally binding agreement. Meanwhile the Department is reliant on there being continuing goodwill between EDF and the NDA to resolve potential differences.

The UK government has yet to put in place arrangements by which it can assure itself that the Department is fulfilling these roles and the decommissioning programme is performing effectively.

Finally, what does the statement that it should be possible to save £1 billion in an estimated cost range of £3.1 billion to £8.0 billion mean? Surely you save £4.9 billion by hitting the lower estimate rather than the higher.

Site move

This site has recently moved to a new hosting service in the UK. Some login information may have been lost and some pictures may be missing. Sorry

I’ve switched on registration so join me if you wish.

Should we evacuate elderly people in a nuclear or radiological accident?

There is an interesting talk on the ICRP’s ICRP Digital Workshop: The Future of RP by Jessica Callen-Kovtunova entitled Making ICRP Recommendations ‘Fit for Purpose’ for the Response to a Nuclear or Radiological Emergency.

In this she reports a meta-analysis of 600+ papers which reviewed the impact of protective actions and claims that for every 1000 people evacuated we may expect 7 deaths among the general public due to dislocations caused by the protective action and between 15 and 117 among residents of facilities for long stays and the elderly as well as between 120 – 220 mental health problems.

They compare this to 5 deaths prevented by evacuating 1000 people with an averted dose of 100 mSv each (this appears to be based on the ICRP-103 approximation of the overall fatal risk coefficient of 5% per sievert).

They conclude that: “Taking protective actions consistent with dose criteria used in many countries could result in far more excess deaths than hypothetical excess radiation-induced deaths prevented.  We must include these effects to protect people effectively.”

If we agree with these findings, and before doing that I’d like a closer look at the applicability of the evidence, we must ensure that the current ERL for evacuation is reconsidered and its application to homes for the elderly, in particular, given very careful thought.

If we start to think about different protective action thresholds for different age groups maybe we could also consider stopping planning to give those over 40 -50 years old stable iodine.

The potential for remote inspection in the nuclear industry – Webinar

I’ve just listened to a Webinar “How to Implement Remote Inspection in the Nuclear Energy Sector?” organised by TUV SUD (I’m not sure about the question mark!).

It introduced the idea that one person could “walk the site” wearing smart glasses, while their colleagues watch from a remote location, request the walker stop to look at anything that catches their attention and ask questions through the walker. If accepted, this could complete an inspection with fewer on-site resources and will generate an audio-visual record of the inspection from which the report and conclusions can be written.

I’m not sure this is a particularly new concept; the nuclear industry, and probably others, use remote monitoring to support operators working in difficult areas where there is a balance between having all the skills and expertise to hand and minimising the size of entry teams. The use of smart glasses may be new and maybe adds another option to body worn cameras and infrastructure mounted cameras. The application to teams of off-site inspectors may be novel. The service offered seems to be the full sweep of technology, hardware and software, from the camera to the remote inspectors; with the lessons of experience and training offered as well. This may well be a unique service for the time being but barriers to entry are probably not high.

There were several questions to do with broadband signal, band width, data protection, cyber security and safety with the conclusion that this technique is well within current technical capabilities. It has been used maybe 10 -20 times in Europe and about 50 times in China.

This is an interesting concept and an area that is likely to develop in future. Why send a team of people to a remote site and then into an industrial or contaminated environment when you can send one person, or a robot?

The regulators would have to consider the qualifications and experience required of the on-site inspector, who would be much more than just a camera operator, and the conduct of any such inspection. The industry could consider if the technology has application in normal operations and accident response that adds to the capability already offered by site sensors, including cameras, and body worn cameras that they already use.

22/9/21

Impressions of the Emergency Services Show 2021

I attended the Emergency Services Show yesterday (7/9/21). As in the past this offers access to a large number of exhibitors and a range of short presentations.  I don’t plan my visit very well and just wondered up and down hoping to find all the interesting stalls. This meant I stopped and chatted to random people rather than worked down a list and that this review is therefore rather random.

Themes include vehicles and vehicle fittings, lights (lots of LEDs!), care for responders physical and mental wellbeing, cameras on drones, people, vehicles and poles, more drones with different capabilities, handheld devices to detect and measure threats, PPE & RPE and command and control systems, kit bags, ropes, pulleys etc.

There were several IT systems that allow you to integrate information feeds from cameras and other sensors dotted around the incident, radio messages from those on the ground and geographic knowledge. I didn’t take a close at these but now wish I’d spoken to someone about them. My concern (from a far!) with these is that they disrupt the information pyramid. You need a new team of people to sift through the information and identify what is important and what is changing. Having a sit-rep from the commander on the ground available to all to listen to when they wish is great, but how do you ensure that people are not still interpreting it as hot news long after it has been superseded? Having the reports of all the people on the ground, and all the videos, is also great but again come with a time cost if everybody stops to hear them. Will the remote Gold Commanders be tempted to take time to look at the video feeds and make their own situation analysis, by passing the Command structure on the ground? Is that always good, always bad or does it depend?

There were several immersive training environments, including VR sets and tents with scenes projected onto all the surfaces. These must be helpful in certain circumstances.

Handheld radiation monitors continue to develop with new crystal materials, larger crystals and, more importantly, much more on-board computing capability. Southern Scientific were showing CBRNe handhelds while kromek were showing a range of handheld and wearable gamma and neutron detectors with Bluetooth and USB comms, including some with the ability to identify isotopes. I find some of the claims a little hard to believe but these companies have happy customers whose expertise and judgement in these matters I’d place ahead of mine.

There are also a number of training tools that are realistic looking handhelds, such as those offered by Argon Electronics, that report injected exercise data rather than live readings. Obviously potentially useful.

It was interesting to talk to the people at the Defence and Security Accelerator (DASA) stand. This organisation tries to find innovations that can be exploited by the UK defence and security services and help with their development. They do this by a combination regional “innovation partners”, who provide advice to organisations and individuals about the potential merits of their ideas and how best to develop them and through more focussed “competitions” to cover identified needs. Funds are available for promising technologies at different stages of development and for the full range of company size. Their website has interesting case studies.

A car sized fire blanket from Fire Hosetech caught my attention. This is designed to manage lithium-ion battery fires which must be contained until they burn out. These reusable blankets can withstand temperatures up to 1,600 degC and reduce the spread of toxic fumes and contamination.

I also stopped to look at Fortress Distribution’s attempt to reduce the world’s usage of disposable shoe covers with plastic “Yuleys” which you step into and out of in a hands-free manner. Their design use seems to be for trades working indoors and out to prevent treading dirt inside but I wondered if they could replace single use shoe covers in contaminated areas. One issue being that they cover the sole of the shoe and the sides to a certain extent but not the top which I suspect is an idea killer. The other questions would include how much work was involved keeping them clean and how many reuses would be required to cover their own environmental costs?

Also worthy of a mention is the National Emergency Services Museum in Sheffield which showed a few of its vehicles. Got to be worth a visit if in the area.

The Emergency Services Show is well worth a visit by emergency planning and response professionals although it is not focussed on us. It gives an opportunity to see how the Emergency Services, with whom we work, are developing and an opportunity to keep an eye on technology developments and themes.

Small Modular Reactors and Advanced Modular Reactors – State of Play

The trajectory taken by mainstream nuclear power reactors over the years has tended towards more powerful units with ever more layers of backup safety systems. These are complex and therefore difficult to build and eye-wateringly expensive (Hinkley Point C costs have risen from £18bn in 2016 to £22bn – £23bn in 2021). There have been several attempts to simplify nuclear power designs by introducing passive safety and reducing the lengths of pipes and number of systems.

The concept of the Small Modular Reactors (SMR) has a long history. In the UK the Safe Integral Reactor (SIR) proposed by Rolls Royce in the 1980s and 90s used PWR technology but with reduced size and the steam generator inside the main pressure vessel. This reduces the lengths of vulnerable primary circuit pipes and other external components which greatly reduces the chances of a loss of cooling accident. It also provides more effective decay heat removal by natural circulation leading to improved safety at reduced cost and complexity. Several other SMR designs were proposed at about this time (see ASME Symposium 2011).

Picking winners? In 2016 a report written for the UK government (SMR Techno-Economic Assessment Project 3 – SMRs: Emerging Technology) reviewed over 40 SMR concepts in 6 technology groups looking for those that could be deployed by around 2030 and contribute to the UK’s 2050 decarbonisation commitment. An important conclusion was that “A combination of a lack of technical maturity, together with the likely time and effort for licensing and deployment indicates that all Emerging Technologies except SM-HTGR are at least significantly challenged on ‘Time and Cost to Deployment’ relative to SM-PWRs”. This begs the question “is the UK in danger of missing a better long-term solution by placing undue emphasis on short deployment targets?”

At about the same time another report looked at Micro Nuclear Reactors (typically under 30 MW electrical) and concluded that there were no great technical barriers to their development and that the finances looked good. It suggested that two barriers existing were uncertainly in how the regulatory process will apply to such reactors and uncertainty in long term political commitment to manage a predictable nuclear industry environment.

It was concluded that Small Modular PWRs represent the least cost generation option for SMR technologies in the short or medium term. That these can provide low grade heat for district heating and some industrial processes was seen as an advantage despite no market penetration for UK nuclear in these areas. It was also concluded that emerging technologies, particularly the Small Modular – High Temperature Gas-cooled Reactor, could offer other advantages in UK energy futures where high temperature process heat is used directly to decarbonise industrial and/or transport activities. It appears that the government accepted these conclusions.

A RR SMR brochure (2017) claimed that “A Small Modular Reactor (SMR) programme represents a once in a lifetime opportunity for UK nuclear companies to design, manufacture and build next generation reactors to meet the UK’s energy needs”. They promised SMRs providing 220 MW to 440 MW, cheaper per MW than large scale reactors, low technical risk, high fraction of UK content, 1/10th the land requirement, running by 2028.

The brochure listed a several conditions that would be required:

Condition Apparent progress (my judgement!)
Selection of one preferred technology HM Government have confirmed that they will support SM-PWR and SM-HTGR.
A UK industrial policy that supports UK intellectual property, advanced manufacturing and long-term high value jobs in the UK Difficult to assess but the recent purchase by the Government of Sheffield Forgemasters is a good sign.
Match funding until the end of the Critical Design Review It seems that funding has now been achieved to complete the GDA process.
A Generic Design Assessment (GDA) slot to ensure the process of licensing GDA is now open to SMR and AMR designs.
A suitable site to develop a First of a Kind (FOAK) power station There seems to be a view that the FOAK SM-PWR will be built on a previous nuclear power site which seems sensible.
A policy supporting a UK electricity market of at least 7 GWe for SMRs Current declared strategy looks to demonstrator (FOAK) rather than fleet. We do not yet have a declared siting and policy framework.
Export support to reach international markets Too soon to say

 

They don’t seem to tackle the issue of who would pay for them to be built after the FOAK, who would own them, who would operate them and how they would all be paid. RR want to build and sell 7 GW electrical, they don’t want to own and operate them.

A World Nuclear Association (WNA) report (2021) discusses an aspiration for a worldwide nuclear environment where internationally accepted standardized reactor designs can be deployed without major design changes. It reports a range of different SMR designs and a wide variety of licensing processes and diversity of overall national regulatory structures. It concluded that a country’s regulatory framework is generally either heavily prescriptive and rule-driven (such as the USA) or goal- or risk-driven (such as the UK); some are a combination of both. The report seems to hold out little hope for international approval but it does provide advice on best practice on licensing reactor designs in other host countries.

A later WNA webinar about streamlining the licensing of Small Modular Reactors again spoke of the potential gains for vendors from an international approvals system but offered few ideas on how that might be achieved.

The UK Government Ten Point Plan for a Green Industrial Revolution (November 2020) suggested that the UK electricity system could double in size by 2050 as demand for low-carbon electricity in sectors such as heat and transport rises. It looked to large scale nuclear to contribute and promised to look at the future of SMR and AMRs and invest where appropriate.

A Government Energy White paper (December 2020) states that “Nuclear power provides a reliable source of low-carbon electricity. We are pursuing large-scale nuclear, whilst also looking to the future of nuclear power in the UK through further investment in Small Modular Reactors and Advanced Modular Reactors.” It reports an aim to bring at least one large-scale nuclear project to the point of Final Investment Decision by the end of this parliament (it seems to be running out of viable options with Sizewell C being based on the hard-to-build EPR, Wylfa Newydd and Moorside inactive and Bradwell B embroiled in international politics).

The White Paper also promised that “We will provide up to £385 million in an Advanced Nuclear Fund for the next generation of nuclear technology aiming, by the early 2030s, to develop a Small Modular Reactor (SMR) design and to build an Advanced Modular Reactor (AMR) demonstrator”.

The UK government has opened the Generic Design Assessment (GDA) to Advanced Nuclear Technologies and the ONR released new guidance on the process.

A public dialogue was held in early 2021 to “inform future policy development and engagement with the public”. The output does not seem to be available yet.

The UK Research and Innovation Low-cost nuclear challenge (24th May 2021) aims to develop a compact, standardised nuclear power station product based on the Rolls-Royce led SMR. It has ear-marked £215 million investment from the UK government, to be matched with £300 million investment from industry (19/11/20) with Tom Samson, the CEO of the UK SMR consortium promising “We will continue our current work and then move seamlessly into our next phase in May 2021 beyond which we can begin creating 40,000 high quality jobs, £52 billion of value to the UK economy; and targeting the £250 billion in exports”.

The government has also sought views on the potential of high temperature gas cooled reactors with the aim to have a demonstrator by the early 2030s asking if people think they have a role in the net zero CO2 target, if there is further evidence they are unaware of and how well the UK supply chain could support the programme.

A report written by the University of Manchester, Dalton Nuclear Institute supports the development of a demonstration HTGR and suggests adding hydrogen generation to the aspirations for the demonstrator. It also recommends a suitable body that is equipped and empowered to deliver the HTGR project be constituted. This, it suggests, should be complemented by an independent body “unconflicted by claims and lobbying by any particular system proposer” to maintain an ongoing UK view of developments in AMR systems, a broad-based advisory body offering the government advice on the nuclear programme.

Meanwhile Canada has a comprehensive Small Modular Reactor Action Plan resulting from a pan-Canadian effort bringing together key enablers from across Canada including the federal government, provinces and territories, Indigenous Peoples and communities, power utilities, industry, innovators, laboratories, academia, and civil society”. It comes with a statement of principles, 117 chapters written by participants and 513 tracked actions each linked back to the recommendations made in an earlier roadmap document. This is a credible programme.

In Russia Small Modular Reactors are being built for icebreakers, for floating power plant and for land-based systems. They have the KLT-40S Integral PWR which has been evolved into the RITM-200 which is smaller and lighter. This has several variants for land and floating applications (the floating applications include providing propulsion for icebreakers and providing electricity and heat for coastal communities). There are proposals for a land-based SMR at Yakutia in the Russian Far East.

China has started to build an ACP100 SMR demonstration project at the Changjiang nuclear power site in Hainan. Designed for electricity production, heating, steam production or seawater desalination the 125 MWe PWR. The plan envisages sites with 2 to 6 ACP100 reactors with a 60-year lifespan and 24-month refuelling. A floating version is also planned.

In the US NuScale power are planning to build a 6 unit site for the Utah Associated Municipal Power Systems (UAMPS) (down from the 12 units originally planned).  The first module is scheduled to be operational in 2029, and the full plant in 2030. Meanwhile funding is being collected to build a demonstration Natrium reactor in Wyoming on the site of a retiring coal power station. This is a sodium cooled fast reactor with a thermal storage device allowing load following, including electrical outputs rates higher than the reactor’s power output for periods of time.

France has announced another new SM-PWR design, the “NUWARD”TM, while saying that they are “open to international cooperation, notably to foster the harmonisation of regulation, the standardisation of design and design optimisation”. (If that really was the case then why didn’t they join an existing project rather than develop their own?).

Japan is reported to be interested in developing and deploying SMR and AMR. Their aspiration is for a SMR demonstration site by 2030 and the establishment of the technology to use high temperature reactors to generate hydrogen.

This is clearly an interesting time for Small and Advanced Modular Reactors. They are being built in Russia and China, both of which see a good market. They are being developed in the USA, Canada, the UK and several other countries, seemingly with coherent government support. They are seen as an affordable route into the nuclear industry providing an opportunity to decarbonise the energy market and reduce dependence on imported fuels. We need to see continuing progress on the design and licensing of this technology, demonstrator sites for those that have not got there yet and a siting policy, financial model and operating regime that enables the full market potential to be realised. Meanwhile we can expect to see many of the systems currently under development to fall by the wayside.

The NEI Small and Advanced Reactors event (4th November 2021) will be a follow up to their virtual event held in February 2021. It will look at the development plans and licensing activities for a range of small and advanced reactor technologies from across the world. It will cover all aspects of industry, with insight from reactor developers, utilities, regulators, supply chain, academics and the financial community with sessions covering market development, manufacturing and construction, the utility view of the role of SMR/AMR, finance and economics, Fuel and progress towards demonstration plant and beyond. One to watch.

 

 

IAEA Technology Roadmap for Small Modular Reactor Deployment

IAEA Nuclear Energy Series, No. NR‑T‑1.1

Technology Roadmap for Small Modular Reactor Deployment

We hear a lot about the potential for Small Modular Reactors, Advanced Modular Reactors and microreactors to provide reliable, affordable, low carbon energy to produce electricity, district heat, industrial heat and hydrogen, including in places where grids cannot reach but, other than in China and Russia where they are getting on with the job, generally the discussion is about getting to the demonstrator (or First of a Kind (FOAK)) rather than beyond.

The stated objective of this paper by the IAEA, drafted by an international group over a series of meetings, “is to present several model technology roadmaps to Member States which can be adapted to their specific projects”. The guidance “describing good practices, represents expert opinion but does not constitute recommendations made on the basis of a consensus of Member States”. It is notable that no one from RR, ONR or BEIS was on this group.

The authors keep interrupting the narrative about how to plan for the deployment of SMRs with seemingly random sections reviewing the state of play with various designs across the world and the history of the field.

The paper is apparently aimed at:

  • owners/operating organizations, who drive the demand and requirements for reactor designs;
  • designers, who develop the technologies; and
  • regulators, who establish and maintain the regulatory requirements that need to be met by owners/operating organizations.

Technology roadmaps, we are told, “are part of a methodology that guarantees the alignment of investments in technology and the development of new capabilities. A proven management tool, technology roadmaps are used for identifying, evaluating, communicating and promoting the development of complex technology projects”. One aim is to increase the chances of passing well known pitfalls where failure is more likely (Figure from IAEA NR-T-1.18).


The first pitfall is the potential failure of the R&D to satisfactorily addressed all technology gaps to enable the construction of a reliable prototype or the performance of an important proof of concept test. (I think that technically competent reactor designs fail at this stage due to a lack of funds to continue). The second is commercial; is the technology reliable, accepted by the regulator and cost competitive against its alternatives?

The operation of an SMR or a fleet of SMRs requires national soft and hard infrastructure such as:

  • Physical facilities for the delivery of electricity [or heat];
  • Site and supporting facilities for handling and disposing of radioactive waste;
  • Legal, regulatory and policy framework;
  • Financial resources necessary to implement the required activities;
  • Trained human resources.

In fact, the paper recognises 19 infrastructure issues (Table 2 of report). This is a useful list. Civil servants looking at government support for this technology should review this list to see if it identifies any expensive or difficult hurdles.

One of the issues with SMRs is the potential for them to be built rapidly – several a year – with the potential for deployment in countries other than those in which they were designed and built. These two factors present a challenge to site licencing which is much discussed.

For countries that already have a nuclear industry the hosting of a SMR or fleet of SMRs should not pose great legal, regulatory or infrastructure issues although the siting requirements may need further consideration as with potentially reduced emergency planning zones and less cooling water requirements these plants can go on a wider range of sites. It would also be necessary to consider the county’s ability to manage the fuel cycle and waste produced by the SMRs if they differ from the existing fleet. The paper gives an update on progress in several countries.

For countries without an existing nuclear industry the IAEA has outlined an approach in an earlier paper (Milestones in the Development of a National Infrastructure for Nuclear Power, IAEA Nuclear Energy Series No. NG‑G‑3.1 (Rev.1)). This involves stages before a knowledgeable commitment can be made to nuclear power; before they are ready to invite bids from suppliers and before they are ready to commission and operate the first power station. Each of these stages are discussed.

It is interesting to consider how this might apply to the Russian concept of floating power stations where the extreme view could be that the licensing, safety and fuel cycle issues are all managed by the Russian company to their national standards and the host country has an electric cable running into from offshore. How different is this to a French PWR providing power to the UK via a cable running under the English Channel?

Section 3 of the report is a review of the prospects for SMR technology which the IAEA rate as promising. Section 3.2.4 seems to suggest that public are certain to accept the technology because it is the only way to hit the IPCC’s decarbonisation target. I am not convinced!

Section 4 identifies stakeholders of which the keys ones are the designer/supplier, the owner/operating organisation, the technical support organisation, the investors, the regulatory bodies, the government and the public. It then discusses regulatory frameworks including the IAEA and OECD/NEA and WENRA and discusses goal setting and prescription as the two major licensing approaches before introducing the SMR Regulators’ Forum.

Section 5 concentrates on near term deployable SMR technology and provides a road map in three sections: owner or operating organisation, designer/vendor of the technology, regulatory bodies. This section is very disjointed and hard to read.

Section 6 looks at more innovative reactors designs which are further from market and highlights technical areas and R&D activities that are likely to absorb effort and funds on the pathway to deployment. This section also reviews six technologies that are being considered and takes a speculative look at the potential integration of renewable energy sources with nuclear sources.

An annex to the report reviews three designs of SMR in operation or under construction.

This could be a very interesting report but the drafting is poor making it hard to read from beginning to end. It does however give an impression of the breadth and depth of work that is required to support a nuclear power plant. I’m sure that it could be useful to a civil service providing government funding and support to the SMR industry. What would be useful is a map showing the development path for SMR and AMR reactors with a series of gates through which they have to pass, a discussion about what needs to be achieved before a reactor design can pass each gate and the technological and financial risks implied, who is responsible for the risks and an estimated cost and time for reaching each gate.