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.
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.
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).
My latest book, an attempt to explain the Chernobyl accident to people who know a bit about physics but not a lot, placing it between the many accounts that have concentrated on the human story and some very technical reports, is now available on amazon after a professional work over by Art Works who have greatly improved the layout and type setting.
Since everybody seems to be writing about Covid-19 I thought I should as well.
Update. There is now a cacophony of Covid-19 writing. I'm not even going to try to stay up to date, let alone write anything more.
COVID-19 is the illness seen in people infected with a new strain of coronavirus not previously seen in humans. On 31st December 2019, Chinese authorities notified the World Health Organisation (WHO) of an outbreak of pneumonia in Wuhan City, which was later classified as a new disease: COVID-19. Based on current evidence, the main symptoms of COVID-19 are a cough, a high temperature and, in severe cases, shortness of breath.
On 30th January 2020, the WHO declared the outbreak of COVID-19 a “Public Health Emergency of International Concern”.
It is not yet clear how this virus will spread and the impact it will have. However, as of 4th March 2020 it is spreading widely across the world and there appears to be an exponentially increasing number of cases in the UK. Business have been advised to plan for 20% absenteeism at the peak.
The government summary of what is known about the virus may be a bit out of date – this is a fast moving event. It does say that “Although evidence is still emerging, information to date indicates human-to-human transmission is occurring. Hence, precautions to prevent human-to-human transmission are appropriate for both suspected and confirmed cases” and “We do not know the routes of transmission of COVID-19; however, other coronaviruses are mainly transmitted by large respiratory droplets and direct or indirect contact with infected secretions. In addition to respiratory secretions, other coronaviruses have been detected in blood, faeces and urine.”
“Fever, cough or chest tightness, and dyspnoea are the main symptoms reported. While most patients have a mild illness, severe cases are also being reported, some of whom require intensive care.”
When you have dyspnea, you might feel:
Out of breath,
Tightness in your chest
Hungry for air (you might hear this called air hunger)
Unable to breathe deeply
Like you can’t breathe (suffocation)
As of 3 March, a total of 13,911 people have been tested in the UK, of which 13,860 were confirmed negative. 51 were confirmed as positive (up to 85 on the 4th March).
We might expect the number of cases to rise rapidly over a period and then start to drop. The peak intensity and the duration of the disruption is hard to predict. The “social distancing” strategy is intended to reduce the height of the peak but at the expense of increasing the duration. There is a distinct possibility of repeat outbreaks in subsequent years, although these days we can hope that a vaccine will be developed. Each wave can have different inflection rates and different fatality rates. The figure below shows the 3 different waves of illness in the USA during the 1918 flu pandemic.
The overall phases of the Government plan to respond to COVID-19 are:
Contain: detect early cases, follow up close contacts, and prevent the disease taking hold in this country for as long as is reasonably possible
Delay: slow the spread in this country, if it does take hold, lowering the peak impact and pushing it away from the winter season
Research: better understand the virus and the actions that will lessen its effect on the UK population; innovate responses including diagnostics, drugs and vaccines; use the evidence to inform the development of the most effective models of care
Mitigate: provide the best care possible for people who become ill, support hospitals to maintain essential services and ensure ongoing support for people ill in the community to minimise the overall impact of the disease on society, public services and on the economy.
Contain
These phase may have run its course with an increasing number of cases confirmed in the UK. (At this stage care is needed when interpreting the rise in confirmed cases. It may be more representative of the rise in testing rather the rise in cases).
Delay
The delay phase of the response will probably be based on public information campaigns urging hygiene, social distancing and recognition of symptoms. The intention is a lower the peak incident rate but probably at the cost of prolonging the course of the epidemic.
The government concern about planning for this stage is that the proposed actions have a social impact (and an economic one).
The company would probably prefer a longer duration, relatively shallow event rather than a shorter, sharper one that compromises site safety by having too many people off at once. At company efforts should focus on delay, at least initially.
Mitigate
For an operational site or company the mitigate stage is about maintaining site safety at all times and remaining fleet of foot to achieve what production is possible.
What happens when you have a suspect carrier on site?
For contacts of a suspected case in the workplace, no restrictions or special control measures are required while laboratory test results for COVID19 are awaited. In particular, there is no need to close the workplace or send other staff home at this point. Most possible cases [currently] turn out to be negative. Therefore, until the outcome of test results is known there is no action that the workplace needs to take. (COVID-19: guidance for employers and businesses).
The Company should consider implementing a policy of “social distancing” and added cleaning.
If it is confirmed that a carrier has been on site the PHE will carry out a risk assessment and give advice to the management (We can imagine that this will only continue to happen if the number of cases remains low).
By law, medical evidence is not required for the first 7 days of sickness. After 7 days, it is for the employer to determine what evidence they require, if any, from the employee. (A) Any company should agree and promulgate its policy for sick pay if the virus hits.
Employees may be advised to isolate themselves and not to work in contact with other people by NHS 111 or PHE if they are a carrier of, or have been in contact with, an infectious or contagious disease, such as COVID-19. (A) Again any company needs clear guidance on behaviour and pay under these circumstances.
Office cleaning
Coronavirus symptoms are similar to a flu-like illness and include cough, fever, or shortness of breath. Once symptomatic, all surfaces that the person has come into contact with must be cleaned including:
all surfaces and objects which are visibly contaminated with body fluids
all potentially contaminated high-contact areas such as toilets, door handles, telephones
Public areas where a symptomatic individual has passed through and spent minimal time in (such as corridors) but which are not visibly contaminated with body fluids do not need to be specially cleaned and disinfected.
If a person becomes ill in a shared space, these should be cleaned using disposable cloths and household detergents, according to current recommended workplace legislation and practice.
Guidance to the cleaners about personnel protective equipment (water proof gloves) and cleaning chemicals to use when cleaning potentially contaminated areas should be clear and transparent. (A) Write and promulgate enhanced cleaning regime for shared areas and for areas that might be infected.
All waste that has been in contact with the individual, including used tissues, and masks if used, should be put in a plastic rubbish bag and tied when full. The plastic bag should then be placed in a second bin bag and tied. It should be put in a safe place and marked for storage until the result is available. If the individual tests negative, this can be put in the normal waste.
Should the individual test positive, you will be instructed what to do with the waste.
Regularly and thoroughly clean your hands with an alcohol-based hand rub or wash them with soap and water. Why? Washing your hands with soap and water or using alcohol-based hand rub kills viruses that may be on your hands.
How long any respiratory virus survives will depend on a number of factors, for example:
what surface the virus is on
whether it is exposed to sunlight
differences in temperature and humidity
exposure to cleaning products
Under most circumstances, the amount of infectious virus on any contaminated surfaces is likely to have decreased significantly by 72 hours.
Once similar viruses are transferred to hands, they survive for very short lengths of time. Regular cleaning of frequently touched hard surfaces and hands will, therefore, help to reduce the risk of infection.
Maintain social distancing
Maintain at least 1 metre (3 feet) distance between yourself and anyone who is coughing or sneezing. Why? When someone coughs or sneezes they spray small liquid droplets from their nose or mouth which may contain virus. If you are too close, you can breathe in the droplets, including the COVID-19 virus if the person coughing has the disease.
Avoid touching eyes, nose and mouth
Why? Hands touch many surfaces and can pick up viruses. Once contaminated, hands can transfer the virus to your eyes, nose or mouth. From there, the virus can enter your body and can make you sick.
Practice respiratory hygiene
Make sure you, and the people around you, follow good respiratory hygiene. This means covering your mouth and nose with your bent elbow or tissue when you cough or sneeze. Then dispose of the used tissue immediately.
Why? Droplets spread virus. By following good respiratory hygiene you protect the people around you from viruses such as cold, flu and COVID-19.
If you have fever, cough and difficulty breathing, seek medical care early
Stay home if you feel unwell. If you have a fever, cough and difficulty breathing, seek medical attention and call in advance. Follow the directions of your local health authority.
Why? National and local authorities will have the most up to date information on the situation in your area. Calling in advance will allow your health care provider to quickly direct you to the right health facility. This will also protect you and help prevent spread of viruses and other infections.
Stay informed and follow advice given by your healthcare provider
Stay informed on the latest developments about COVID-19. Follow advice given by your healthcare provider, your national and local public health authority or your employer on how to protect yourself and others from COVID-19.
Why? National and local authorities will have the most up to date information on whether COVID-19 is spreading in your area. They are best placed to advise on what people in your area should be doing to protect themselves.
Facemasks
Despite a further review of all the available evidence up to 30 November 2012 there is still limited evidence to suggest that use of face masks and/or respirators in health care setting can provide significant protection against infection with influenza when in close contact with infected patients. The effectiveness of masks and respirators is likely to be linked to consistent, correct usage and compliance; this remains a major challenge – both in the context of a formal study and in everyday practice. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/316198/Masks_and_Respirators_Science_Review.pdf
Employees are not recommended to wear facemasks (also known as surgical masks or respirators) to protect against the virus. Facemasks are only recommended to be worn by symptomatic individuals (advised by a healthcare worker) to reduce the risk of transmitting the infection to other people. (COVID-19: guidance for employers and business
There is an awful lot of material being published about Covid-19 at the moment. I’m helping a nuclear operator get in the best shape they can with their preparations and I’m finding a near full time job to read the literature each day.
I’m pleased to have another article published in Nuclear Engineering International. This one is about EdF’s excellent in-van gamma spectroscopy system which will improve the speed and accuracy of off-site dose estimates if there is ever an off-site release.
`The abstract to this document claims that “This report presents in a single document, the elements that make up the national radon strategy and the national radon action plan. It fulfils relevant requirements in the 2013 European Union Basic Safety Standards Directive on protection against ionising radiation (EURATOM, 2013).” I think that this statement admits the thought that occurred to me as I read the document for the first time; although labelled as the UK National Radon Action Plan it is not really a plan or a strategy, instead it is a comprehensive description of the work being undertaken in the UK to understand the extent of exposure to Radon, to identify where action should be taken to reduce Radon dose, and to take such steps and monitor their effectiveness.
The section labelled “UK radon strategy” talks about the UK strategy in the third person. It is not a strategy itself but describes a strategy that is off-stage. Where the document states that the UK strategy meets the requirements of the BSS it is really making the credible claim that the UK is already doing what it would have decided to do had it started with a blank sheet of paper and written a strategy in line with the guidance. Essentially the UK had a comprehensive Radon programme before the need was fully articulated in the BSS.
Radon appears in the BSS in a number of places (Article 54 Radon in the workplace, Article 74 Indoor exposure to Radon, Article 103 Radon Action Plan). The BSS requires that there is a national plan to address the long- term risks from radon exposure recognising that the combination of smoking and high radon exposure presents a substantially higher individual lung cancer risk than either factor individually and that smoking amplifies the risk from radon exposure at the population level.
The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 which came into force on 8th May 2018 require the Secretary of State to set a reference level for public exposure to radon. The reference level for the annual average radon activity concentration in air must not exceed 300 becquerel per cubic metre (regulation 8) in line with BSS Article 74. The BSS calls for a “basis for the establishment of reference levels”. The basis of the UK limits is not clear to me but there is probably a justification somewhere.
Further regulation is found in the Health and Safety at Work etc Act of 1974 and the Management of Health and Safety at Work Regulations 1999.
The SoS is also required to publish information about the hazards of indoor radiation, its measurement and ways of reducing it (Regulation 9). This is satisfied, at least in part, by the website at https://www.ukradon.org/.
There must be a national plan address long term health risks from radon ingress to dwellings, workplaces and buildings with public access (Regulation 10). This must be updated at intervals of no more than five years.
Annex 18 of the EU BSS gives a list of 14 things to consider when setting up a national radon plan. The use of this list is mandated by the 2018 regulations. While I don’t think that the UK is missing anything important with the current approach it is not entirely obvious where each of these topics are covered.
Public Health England have a group focused on the radon issue and they provide leadership within the UK. This document was written by the PHE group along with several other government departments covering the UK and the devolved administrations.
The UK has maps are that identify radon Affected Areas, which are defined as where at least 1% of homes are expected to be above the radon Action Level (200 Bq m-3). These can be found at https://www.ukradon.org/. This shows that my home in Gloucestershire has a “maximum radon potential of less than 1% (in the clear) but with the surrounding area going up to 3 – 5%. Since these values are “indicative” I’m maybe not entirely in the clear. This clearly shows that the need for an “approach, data and criteria for the delineation of areas” is satisfied. It is less clear that a risk assessment has been used to systematically identify the types of buildings that should be surveyed although the UK has a long standing survey programme.
The Forward plan for action on radon states that established UK infrastructure and provisions will be “maintained and supported” but not who will do this and who they will be answerable to which you may expect to find in a strategy. The New topics for consideration” explicitly mentions the annex of the EU BSS and picks up some of the missing elements and promises that they will be given attention and places actions, but not a time frame, on Public Health England.
Maybe next time the PHE will publish a document that looks more like a strategy. In the meantime keep up the good work.
References
EURATOM (2013). Council Directive 2013/59/EURATOM of 5 December 2013 laying down basic safety standards for protection against the dangers arising from exposure to ionising radiation, Official Journal of the European Union L13/1.
Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 (which came into force on 8th May 2018)
I’m pleased to have another article published in Nuclear Engineering International. This one is about EdF’s excellent in-van gamma spectroscopy system which will improve the speed and accuracy of off-site dose estimates if there is ever an off-site release.
UK National Radon Action Plan, PHE-CRCE-043