Two new pieces of advice for local authority emergency planners

Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives And A councillor’s guide to civil emergencies

The Ministry of Housing, Communities & Local Government has reissued advice to local authorities on preparedness for civil emergencies (Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives, November 2018). This document, which is not intended to be prescriptive, lists 10 aspects it would expect to see in a well prepared authority.

In the introduction Jake Berry MP states that the nature of emergencies facing us continue to increase in variety and complexity “terror attacks in London and Manchester, the use of nerve agent in Salisbury and the devastating fire at Grenfell Tower have tested the resolve of our communities and reminded us all of the importance of local authority leadership in times of crisis”.

The section entitled “are you ready” asks nine questions about:

  • the ability of residents to contact the authority including out of hours and on bank holidays;
  • the authority’s ability to communicate risks and to warn and inform people in the area, including tourists and other visitors, before, during and after an emergency;
  • the ability of senior staff and elected members to manage in an emergency, including managing the authority’s role and as a senior officer within the strategic response and recovery mechanisms;
  • the testing of plans to ensure that they address local risk and resilience standards and describe how to maintain essential services, ensure business continuity and contain agreements with other local authorities for support in a crisis;
  • the resilience of supply chains;
  • the role of the authority within the LRF and the accuracy of the role description in multi-agency plans and the ability to deliver;
  • resource plans for no notice and sustained emergencies, including over holiday periods;
  • a knowledge of the authority’s strengths and weaknesses and where support and further resource can be obtained;
  • the ability to assess the full impact of an emergency on community needs.

The report discusses the role of the local authority in civil resilience in terms of the CCA, in which the local authority is a category 1 responder.

Importantly the regulations or guidance require that the local authority “to ensure that they can continue to exercise their functions in the event of an emergency. The duty relates to all functions, not just emergency response functions”. This appears to include the ability of an authority to provide support to any population within countermeasure zones during a nuclear emergency. “Plans should be clear about what operational support the local authority will put in place for different emergencies, and how this can be activated in and out of business hours” …. “Plans must be clear about how this support will be activated and managed. This support could include on the ground community alerting, for example, door knocking, checking on vulnerable residents, operating rest centres and providing on-going welfare support for people directly affected by emergencies”.

To achieve this all business critical functions should have robust business contingency plans for the services that the authority delivers and those that are contracted out.

An example that is pertinent to nuclear authorities is “consider building ‘all-risk resilience’ into contracts (for example, how to ensure domiciliary care is delivered during petrol shortages or severe disruption to transport networks)”. Reinforcing this is the statement that “Local authorities are expected to manage the humanitarian aspects during emergencies. This requires staff at all levels to be effectively trained to deal sensitively with victims and survivors, including their friends and family. Training and exercising reserves and volunteers builds a further level of resilience in the event of concurrent or long duration incidents”.

An example of communicating with the public given is that of Calderdale Council which utilised social media during floods in December 2015. It is claimed that the council reached over 420,000 people on Facebook and received over 1 million impressions on Twitter.

On the matter of community leadership the document states that “The public, media and politicians will also look to the council to provide information and clarity on what has happened, what is still happening and what will happen next”.

The importance of training and exercising is stressed. It builds “confidence and competence to enable robust delivery of the local authority role whether it is delivered in response or recovery”.

A list of useful documents is given at the end of the document.

This is a document that should be read by the local authority manager responsible for emergency planning and by the Chief Executive of the authority fairly regularly. It might be a useful one to have on the desk when performing periodic readiness or accountability reviews. At a mere 27 pages it makes a welcome change from some of the “door stop” guidance documents that sap the will to live.

A related document, A councillor’s guide to civil emergencieshas also been updated recently (November 2018). The forward mentions that the last version was issued in 2016 but reports that a lot has happened since then with terrorist attacks, tower fires and nerve agent attacks within the UK.

This document introduces some core terms including the definition of a civil emergency, the difference between a rising tide and a no-notice event, categories of responders and levels of response.

A number of case studies are discussed.

The overview section outlines the responsibilities of councils and individual councillors and, later, the role of leaders, portfolio holders and Ward councillors. These headings are then revisited in sections devoted to “preparedness and resilience”, “response”, and “recovery”.

Appendices give suggested questions for leaders/portfolio holders (Appendix 2) and scrutiny committees (Appendix 3) to ask.

This document is a good read and a useful resource for councils and councillors.

IAEA Lessons learned from the deferred dismantling of nuclear facilities

https://www-pub.iaea.org/books/iaeabooks/12194/Lessons-Learned-from-the-Deferred-Dismantling-of-Nuclear-Facilities

This document discusses the requirements to manage sites entering the Care and Maintenance stage of decommissioning (sometimes called deferred dismantling in IAEA documents and SAFESTOR in the USA) where most of the quick wins in terms of cleaning out components have been achieved and the sites waits for several decades for radiological decay to reduce dose rates to more manageable levels before final dismantling of the reactor core and buildings in completed. It is estimated that about 50% of the nuclear facilities that have been shut down are in safe store and that learning from these sites is increasing. This document was written to allow the benefits of that experience to be shared. It was drafted and reviewed by consultants managed by the IAEA

The document discusses the length of time a site may wait before dismantling based on the half-lives of the isotopes giving most of the dose on the one hand and the deterioration of the structures and containment on the other. It concludes that 15 – 20 years is often a sensible duration provided that there is a suitable waste repository for the final waste arisings.

Section 2 of the document talks about the facilities that are required in safestore, the options to repurpose existing buildings during safestore and the removal of unnecessary buildings. It provides reports of experiences and photographs. Several of the examples are based on the experience of Magnox, which as an ex-employee, pleases me.

Section 3 is about the preparations for safestore. This includes the recording of the hazard inventory and a hazard management plan (remove it or make it safe for the duration of safe store), clean up and deplanting, decontamination, drainage and protection.

In a section on firefighting it states that the risk of fire can be reduced by removing as much of the combustible material and as many ignition sources as practical in the preparations for Care and Maintenance phase. However, it states that a firefighting plan is still required and should be developed and agreed with the local fire fighters and the regulators.

Where external firefighters are the first responders familiarisation training, fire plans, exercising and testing are recommended. For unmanned sites there is a need for automatic alarms that reach the firefighters and the site’s management and access arrangements for the local firefighters. These firefighters must have the appropriate security training and classification to enter the site unescorted.

Security measures are required to keep people off the site to avoid vandalism, damage and theft and also to reduce damage by vermin.

The continuing need for environmental monitoring of radionuclides is discussed in Section 6.6. This is likely to be a regulatory requirement but at a lower level that when the site was operating. It is suggested that it would be sensible to taper off monitoring after a period of about five years by which time a workable baseline understanding of the site would have been achieved. There is a warning that new release pathways may be revealed in time.

The interesting bit of this document for me is the section on emergency planning.

The document (Section 7.5) states that “emergency planning and preparedness (EPP) is necessary for a safe enclosure as it contains large amounts of radioactive materials due to structures, systems or components activation and contamination in various parts of the facility”.

As the risks of the facility reduce the operator should review and rewrite emergency plans to ensure that they remain fit for purpose. Off-site measuring equipment can be reduced but is still required and must be maintained. I assume this is referring to off-site radiation detection. In my experience this is sensibly reduced to perimeter monitoring equipment because of the small releases feasible from such structures do not give a sufficient signal very far downwind.

The document admits that it might be difficult to get the local authorities to agree on the need to maintain and test emergency plans for a site in safestore and suggest that the need to be able to deal with protestors and intruders might be one selling point.

There are sections on the management and regulation of sites, the costing of decommissioning activities (including an introduction to a system called the International Structure for Decommissioning Costing).

Section 12 and several of the annexes of the report give outlines and experiences of decommissioning projects around the world including Magnox’s lead and learn process which has been used to ensure that learning is shared between the different sites and that the process becomes more effective and cheaper with each subsequent site.

This publication does not represent in-depth guidance on care and maintenance of decommissioning nuclear sites. It provides a high level review of the aims of care and maintenance and some of the key considerations. Several examples are discussed. As such it makes interesting reading and may be useful as an introduction to the field for those in operating facilities that are coming to the end of their design life.

Nuclear Emergency Response for Local Authorities: An Introduction by Keith I Pearce

I’m very pleased to announce that my second book has now been published on Amazon. I’ve enjoyed writing this one. It attempts to explain nuclear emergency response to those who know little or nothing about the industry. It is based on the knowledge I’ve gained working on safety cases, dose assessment, emergency preparedness and emergency response. I hope it will help local authority and emergency services personnel in particular but be interesting to a slightly wider readership.

Buy it here:  https://www.amazon.co.uk/dp/1916465803

Visit the publishers website (http://www.katwab.co.uk/)

 

 

The Chilca Incident – industrial over-exposure

The Chilca Incident

The IAEA have published a very detailed review of this event and the learning to be gained from it. https://www-pub.iaea.org/books/IAEABooks/11095/The-Radiological-Accident-i

n-Chilca

A serious radiological accident occurred in Peru around midnight on 11 January 2012 during non-destructive testing in the district of Chilca, in the Cañete Province of Lima. An iridium-192 source in a radiography camera being used to test pipeline joints became stuck inside the guide tube, resulting in three workers being overexposed to ionizing radiation.

Pipes were being welded together and a radiography camera was being used to determine the quality of the welds. The equipment used consisted of a 192Ir source inside a shield (see picture). When an exposure is required a remote winding mechanism is used to move the source from inside the shield, along a tube and into collimator – this produces a beam of gamma rays that are used to make the measurement.

The process involves attaching the collimator and guide tube to one side of the pipe being tested and an unexposed film to the other side of the pipe, then retreating, winding

Device used to store and deploy radiation source

the source out, making the exposure and then winding the source in and repeating. The blackening of the film shows where gamma rays have been less well attenuated and can highlight defects in the weld or pipe wall. The team of three took 97 exposures during a night shift. Finishing at 02:20 on 12 January 2012.

The company provided the workers with a kit that included a set of tools and equipment for operational and personal safety. However, the two assistants, Co-worker 1 and Co-worker 2, left their personal dosimeters in the transportation vehicle; thus, Worker 1 was the only worker wearing a personal dosimeter. None of the workers used alarming dosimeters or direct reading dosimeters. They did not adequately test that the source was returning to the shield at the end of each exposure.

At the end of the shift, when the equipment was being dismantled, it was discovered that the source had not returned to its housing.

At 02.30 worker 1 was sick and he continued to be sick for the next few hours. In the course of the night co-worker1 experienced fatigue and co-worker 2 dizziness.

On investigation it was found that some of the films were overexposed.

On 15 January 2012 erythema (redness of the skin or mucous membranes, caused by hyperemia (increased blood flow) in superficial capillaries which occurs with any skin injury, infection, or inflammation and is a symptom of radiation burning) appeared on the left hand index finger of Worker 1. The company then realized that the workers had been overexposed to radiation.

The Peruvian Institute of Nuclear Energy (IPEN) was alerted and responded by recommending hospitalisation of the three workers. A formal request for assistance (the first of three as the situation developed) was sent from IPEN to the IAEA on 20 January 2012 under the Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency (the Assistance Convention) for dose reconstruction and medical advice. International support helped to understand the medical conditions of the exposed workers and determine their treatment, to understand the doses received and to consider further actions.

The prodromal symptoms of the three were carefully recorded and they were subjected to close examination and observation. The three patients were classified in accordance with the Medical Treatment Protocols for Radiation Accident Victims (METREPOL) system. This considers neurovascular, haematological, cutaneous and gastrointestinal issues and rates each person on a scale of 1 (minimum severity) to 4 (maximum severity) for each. Consideration of the symptoms displayed, the time to onset and their severity allows the doctors to estimate the dose and dose distribution received by a patient and this allows them to predict the course of their illness and to determine the most appropriate treatment.

Worker 1 was the most severely exposed to radiation during the accident. He received a significantly heterogeneous whole body dose of 1.8 Gy (with 75% of the body having received a dose in the range of 4 Gy), as well as doses ranging from 20 to 50 Gy to the extremities of both hands. He was subject to a programme of care and investigation in Peru, Chile and in France. He received reconstructive surgery and cell therapy (mesenchymal stem cells (MSCs) or MSC injections) but still had to have parts of his hand amputated on day 101 after the event.

It was concluded that the work had been badly managed. The trained radiological protection officer was not present, the equipment had been assembled by an untrained person, no attempt had been made to confirm the correct retraction of the source, there were no alarming dosimeters and two of the team were not wearing the supplied dosimeters. This shows poor application of rules and guidance and a poor safety culture.

An observation was that “significant time (6 d) was taken to recognize the radiological nature of the accident, despite the availability of substantial evidence and clinical manifestations. Consequently, as has happened in many other radiological accidents, valuable time was lost before the workers were given appropriate medical evaluation and treatment.” It is suggested that doctors should be trained to suspect and to identify the effects of radiation when patients present with the symptoms of acute radiation syndrome or their case history suggests it is possible.

It was observed that there were problems associated with the analysis of samples and with the sending samples by airline as they demanded confirmation that they were not dangerous. There were also delays with treatment, particularly treatment abroad, on cost grounds, the workers lacking insurance.

The important message here is that these accidents happen and are continuing to happen. Could it happen in the UK? We would like to think not but it only takes a few mistakes with this type of equipment to result in over-exposure. Would it be detected more quickly? We would like to think so. There is at least a suggestion that the workers involved were not open with their initial reports as they feared blame for failing to work to procedures more than they feared the consequences of overexposure and delayed treatment.

This could happen in any county in the UK. It is worth being aware of that and considering how the local authority would react to an event in their area.

IAEA Safety Report Series 93 – National training strategy

A Methodology for Establishing a National Strategy for Education and Training in Radiation, Transport and Waste Safety. IAEA Safety Report Series No. 93.

This document discusses how a country developing its nuclear capabilities should consider the needs for education and training to deliver a sufficient number of competent people in each discipline required giving the range of facilities and activities in the country. It recognises the potential need for various levels and fields of qualification including qualified expert, radiation protection officer, operator, health professional.

The guidance is stated as “describing good practices [which] represents expert opinion but does not constitute recommendations made on the basis of a consensus of Member States”.

It recommends a fairly standard training needs analysis methodology consisting of an assessment phase, a design phase, a develop and implement phase and an evaluation phase. As is usual these are arranged in a cycle to ensure the provision reacts to changes in needs and progress.

The assessment phase looks at the range of facilities in the country and the education and training requirements specified in the legal and regulatory framework, plus any requirements associated with professional qualifications.

The design phase lists the range of courses and their capacity required to meet the national needs and considers who is able to provide the training (including foreign expertise for those in the early phases of development). This can include existing universities and training colleges, national facilities and private providers.

The consideration of formal qualifications, overseen by suitable organisations, and experience leading to recognition by professional bodies is required to ensure proof of adequate knowledge and experience for some roles. This process will identify career routes and pipelines providing the required personnel.

The IAEA’s EduTA methodology is also mentioned as a way of focussing peer review on the nation’s educational and training system.

The meeting of the identified training needs may require capability development or the purchase of capability from other countries. Shortfalls in capability should be analysed and managed. Train the trainer (TTT) is mentioned as a powerful technique to develop capability.

The development and implementation of the programme requires that every identified education and training need should be matched with an appropriate methodology, such as attendance at a structured course, on the job training or distance learning and that opportunities to undertake such training are provided. These training services should be carefully specified and designed and delivered by suitable qualified and experience people.

The IAEA suggests that “the development and implementation of a national strategy for education and training will require government support and the long term commitment of all relevant stakeholders (e.g. regulatory body, governmental and other authorities and organizations in the field of radiation protection and safety, education and training providers, professional organizations). In this respect, the establishment of a high level steering committee of stakeholders will greatly facilitate the development of a policy document that outlines the rationales for the national strategy for education and training in radiation, transport and waste safety. The same committee could also oversee the development and implementation of the national strategy”. In fact, in countries with mature industries this organisation may not be needed. Legal requirements for professional qualifications for some roles, regulatory expectations of the training and experience of personnel and commercial drivers for a safe and competent workforce can achieve the same ends. Issues of supply and demand of skilled workers may occur if significant changes in the structure of the industry occur such as extensive new build programmes or decommissioning activities start.

Evaluation consists of continuous evaluation – the comparison of progress against programme, and long term evaluation of the overall efficiency and effectiveness of delivering the needs of the nuclear industry.

The remainder of the document is taken up with appendices giving examples.

It shows how the nation’s needs can be assessed by listing the facilities that use nuclear knowledge and assessing their needs for qualified people.

It provides example syllabi for courses for RPO in nuclear medicine.

It provides an appendix giving an overview of actions for establishing a National strategy for education and training in radiation, transport and waste safety. This provides a table detailing how 20 actions, distributed across 7 organisations in 5 phases leads to the outcome “The national education and training programme continues to be effective and up to date”.

I do wonder if the world really needs IAEA Safety Report Series 93. It is a fine piece of work but of limited imagination and limited application.

The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018, Regulation 4

 

The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 [Ref. 1] came into force on the 8th May.

Regulation 4 is concerned with “land [that] is contaminated as a result of the after-effects of an emergency, past practice or past work activity and the level of exposure of members of the public to ionising radiation cannot be disregarded from a radiation protection point of view”.

This is a very important aspect of emergency planning as learning how to live with the increased levels of environmental contamination that would follow from a significant accidental release of radioactivity is vital to the recovery and well-being of the local community.

The regulation requires that an appropriate minister sets a reference level for the land.

The definition of “reference” level is now different in three important documents:

  • The regulations (note: regulation not guidance) defines a reference level as
    the level of effective dose or equivalent dose above which optimisation of radiation protection for members of the public must be prioritised”
  • ICRP 103 [Ref. 2] has “In emergency or existing controllable exposure situations, this represents the level of dose or risk, above which it is judged to be inappropriate to plan to allow exposures to occur, and below which optimisation of protection should be implemented. The chosen value for a reference level will depend upon the prevailing circumstances of the exposure under consideration”
  • The EU BSS [Ref 3] has “reference level” means in an emergency exposure situation or in an existing exposure situation, the level of effective dose or equivalent dose or activity concentration above which it is judged inappropriate to allow exposures to occur as a result of that exposure situation, even though it is not a limit that may not be exceeded;”

It would be interesting to understand why those who framed the regulation felt that their definition was better than either the ICRP’s or EU BSS’s. What do the regulations mean by “prioritised”? Does it mean that the UK cannot budget any money for the schools, NHS, social care or road maintenance until the clean-up costs have been covered?

Paragraph 4 requires the appropriate minister to ensure that “appropriate arrangements are established for the on-going control of exposure of members of the public to ionising radiation, with the aim of establishing living conditions that can be considered as normal, including—

(a) the establishment of an infrastructure to support continuing self-help protective measures in the affected area, which may include the provision of information, advice and monitoring;

(b) remediation measures; and

(c) the delineation of the area.

This must be in place “before the resumption of habitation, or economic or social activities, on the land”. We need to be careful that this does not lead to people being kept away from their homes and offices for longer than is necessary as this is known to add to the social and economic stresses of the situation. We also need to avoid hasty decisions about reference levels and area delineation and, in fact, these are likely to be very fluid in the days and weeks following a serious accidental release of radioactivity.

The establishment of support infrastructure is likely to be a moving target as things become clearer and the affected members of the public become better informed of the situation and its ramifications. To say it must be in place before the public move back seems wrong.

Another major concern is that “this regulation does not apply while any part of an emergency plan is in effect in relation to the land in accordance with [REPPIR 2001]”. It is, of course very difficult to define when an emergency plan closes. Most off-site plans make provision for Recovery Working Groups which morph into the leadership of the recovery phase of the response which, it is recognised, could last for several years. Arguably, since this is a “part of an emergency plan” it stalls the application of this regulation pretty much indefinitely.

We need to understand a few things, including:

  • At what level can exposure of members of the public to ionising radiation be disregarded from a radiation protection point of view?
  • What does “prioritised” mean in Regulation 4(5)?
  • How are we to understand the clause that this regulation requires the emergency plan to cease to be in effect before the regulation comes into effect?

In summary this regulation touches on an important and difficult aspect of emergency planning; that of how do we keep the public safe, informed, healthy and at ease in areas that have been contaminated with radioactive material. The regulations require that a government minister establishes areas that have been significantly affected and defines reference levels, infrastructure, information streams and remediation plans to support these aims in those areas. There can be no argument that this is the right level for these decisions to be made.

Whether this regulation provides the appropriate regulatory tool is questionable. Hopefully we will never find out.

References

  1. The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018, http://www.legislation.gov.uk/uksi/2018/482/made.
  2. ICRP, 2007. The 2007 Recommendations of the International Commission on Radiological Protection. ICRP Publication 103. Ann. ICRP 37 (2-4). http://www.icrp.org/publication.asp?id=ICRP%20Publication%20103.
  1. 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, and repealing Directives 89/618/Euratom, 90/641/Euratom, 96/29/Euratom, 97/43/Euratom and 2003/122/Euratom, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013L0059.

Human Medicines (Amendment) Regulations 2018

The Human Medicines Regulations 2012 have been amended from the 1st April (Human Medicines (Amendment) Regulations 2018) to clarify the legal position of nuclear off-site plans that rely on the speedy distribution (or pre-distribution) of stable iodine tablets and provide advice to the public to take them. This is a useful step forward.

According to the explanatory note attached to the regulations “Regulation 12 amends Schedule 17 to the 2012 Regulations so that pharmacy medicines containing Potassium Iodide or Potassium Iodate can be supplied in the event of a radiation emergency by persons acting in accordance with an off-site emergency plan or by persons listed in Part 1 or 2 of Schedule 1 to the Civil Contingencies Act 2004.”

My understanding of the situation is now that for fixed nuclear reactor sites: (Based on Sizewell off-site plan and Highland Council’s Highsafe submarine plan).

  • The Director of Public Health determines the areas that pre-distribution of stable iodine should take place in.
  • The tablets are distributed (“supplied”) by a body such as NHS England or Navy (now permitted under the revised regulation if the radiation emergency has occurred or an event has occurred that could reasonably be expected to lead to a nuclear emergency has occurred although the legality of pre-distribution could be clearer).
  • On the day the Operator (who is likely to be the first to know that there is a serious release of radioactivity) alerts the public and advises them to take the pre-distributed tablets, having prior authorisation from the Director of Public Health to do this.
  • If tablets are indicated beyond the pre-distribution range then “PHE would be responsible for coordinating the delivery of additional tablets and NHS England would be responsible for arranging distribution to the public”.

How best to respond to a nuclear emergency; shelter, evacuation or relocate?

See FT article here.

There are two quite separate themes going on here: evacuation and relocation. The former is about running away from an airborne plume and is an urgent action. The later is a longer term issue.

For prompt evacuation the debate is about what dose do you have to avert for it to be worth running. For an elderly or infirm person, where evacuation may cost their life, the averted dose would have to be well up in the range where deterministic effects kick in hard (but there is a added complication if their carers all want to run). For an infant, able to see evacuation as an adventure if the adults around them are not too visibly stressed and with longer for stochastic effects to hit, the trigger level of avertable dose is much lower. It is not easy to put numbers to these trigger levels, not easy to estimate avertable dose in the heat of the moment and not easy to reassure a population being hit with both radiation and media outpourings.  Decision makers are in a hard place!

For relocation, there is more time to take measurements, more time to talk to the people affected and more time to reach a decision. Still a hard place to be. The balance is between the disruption to people’s lives if they have to move permanently, particularly if they cannot recover their belongings and if the receiving population is negative in any way, and the worry about living in an area with elevated contamination levels. Experience shows that either way some of the people affected are going to need support for a long time to come.

There are no easy answers.

Brexit, Energy Security and the Nuclear Industry

An interesting paper has been issued by the House of Lords, European Union Committee (10th Report of Session 2017–19, HL Paper 63, Brexit: Energy Security). This looks at the potential impact of the UK leaving the EU on the supply of electricity and gas. It finds that we may lose some of the market efficiencies we enjoy as a member and may have to make political concessions to retain some benefits, may have a accept higher prices for using interconnectors, and may be in a poorer position in the event of a continent-wide energy shortage.

There is a big uncertainty about the influence the UK will have on European energy policy when outside the EU and further debate about how, if at all, this will affect us. This theme was summarised by the statement that “Brexit can have severe long term implications for UK’s energy security if economically rational outcomes are not sought by both sides”.

From the point of view of trading electricity the EU does not seem to be a very good option for a trading partner. The report looks at the experiences of Norway and Switzerland. The EU seems to want to impose its own rules, not just the current rules but all future ones. To use the Norway model would be to lack any say in the rule making but to be a member of the EFTA, which the UK has rejected. Switzerland sits at the centre of Europe and has 40 interconnectors between it and the EU. Despite this it does not have the ease of trading electricity with the EU. Meanwhile, we are told that, “a study requested by the European Parliament’s Committee on Industry, Research and Energy concluded: “With or without the UK, the EU will be able to complete its market, to achieve its climate and energy targets with feasible readjustments, and to maintain supply security.”

On the energy security front, the committee worried that we would cease to benefit from “EU solidarity” so, if energy was in short supply the EU members would be more likely to share what was available between themselves rather than allow it across interconnectors to the UK. The report concluded that: “Post-Brexit, the UK may be more vulnerable to supply shortages in the event of extreme weather or unplanned generation outages. While we note the Minister’s confidence in future UK energy security, we urge the Government to set out the means by which it will work with the EU to anticipate and manage cross-continent supply shortages that will affect the UK”.

There is an important section on Euratom. It is stated that: “not only do nuclear power stations supply a significant amount of low-carbon electricity [20%], but the continuity of that supply helps balance less predictable renewable sources, providing further assistance to the UK in meeting its decarbonisation objectives”. I’m not sure that this is entirely true if you take it to mean that a nuclear reactor will immediately take up the load if the wind drops. Nuclear energy provides “baseload” supply. Nuclear power stations work best when providing a constant level of output – load following is possible but is not one of their strengths. What really balances the unpredictable renewable sources are the rapidly variable generators such as hydro, gas turbines and diesel units. Not all of these score highly on the decarbonisation test.

It seems widely agreed that leaving Euratom will have no effect on nuclear safety – that is covered by UK regulation and the ONR. However, without replacement of the controls on the import and export of nuclear material, including fuel, and the free movement of skilled workers becomes more difficult. Without at least some of the Nuclear Co-operation Agreements held by Euratom being replicated trade becomes harder.

ONR have been given the task of Safeguarding but have stated that “Establishing a system that seeks to replicate all aspects of the current Euratom regime by March 2019 is unlikely to be achievable. A system that seeks to meet our international reporting obligations, and which can then be further developed over time is a more realistic starting point and is what we are aiming to achieve by March 2019

In summary. We are leaving a club that distinguishes between “them” and “us” and we don’t know how much difference being a “them” rather than an “us” will make to our relationship with the EU or its member states. The European energy markets are not necessarily going to be open to us in the transparent way they are now. This means that the price of energy flowing between the UK and EU becomes a political question as well as a market question. The market becomes less efficient. Our place in the queue when the whole of Europe is lacking energy also changes for the worst.

Britain should have an energy policy that ensure that our lights stay on. The role of the EU member nations in that policy must not be taken for granted.

The obscure definition of Control in UK Cabinet Office parlance

My understanding of the history of emergency planning in the UK nuclear industry was that we adopted the management tool we call “Command and Control” after the Piper Alpha accident. In that disaster a fatal fire on a North Sea rig was prolonged while the responders sought somebody with authority to stop pumps feeding the fire with gas from neighbouring fields.

Following this lesson we ensured that our emergency arrangements unambiguously identified one role on site who would have unquestioned authority over all resources and actions on site after an emergency had been declared and another who would have similar unquestioned authority over the rest of the Company in support of the emergency response. We then gave people in these roles suitable training and a letter of authorisation promising them the full retrospective support of the Management Board for any actions they initiate when in post in response to an emergency.

An important set of components of the emergency scheme ensured that the person in this role was as fully aware of the changing situation as could be achieved and provided with the full range of technical advice that might be needed (situational awareness) and that their instructions (in terms of strategic foci) were converted to actions (orders) and every effort was made to complete the actions and report back in the time allotted. In this way the crisis is managed.

For many years I’ve worked with the Cabinet Office definitions of Command and Control.

I’ve just been reading the output of a New Zealand ministerial review Better Responses to Natural Disasters and Other Emergencies in New Zealand and I was struck by the completeness and clarity of their definitions of command and control:

  • Command (authority within an agency) is executed vertically, and includes the internal ownership, administrative responsibility, and detailed supervision of an agency’s personnel, tasks, and resources. Command cannot normally be exercised outside an agency.
  • Control (authority across agencies) is executed horizontally, and is the authority to direct tasks to another agency, and to coordinate that agency’s actions so they are integrated with the wider response. Control authority is established in legislation or in an emergency plan. This is control to task a certain agency towards a certain outcome (achieve a managed evacuation for example). It is not control over the actual resource – personnel and vehicles.
  • Coordination: bringing together agencies and resources to ensure unified, consistent, and effective response. 

    Command and control assists with coordination by defining authority between and within agencies.

These definitions can be compared to the UK Cabinet Office definitions as given in Cabinet Office Glossary

  • Command and control – The exercise of vested authority through means of communications and the management of available assets and capabilities, in order to achieve defined objectives.

Note: Command and Control are not synonymous terms – see the separate glossary entries.

  • Command – The exercise of vested authority that is associated with a role or rank within an organisation, to give direction in order to achieve defined objectives.
  • Control – The application of authority, combined with the capability to manage resources, in order to achieve defined objectives.

Further research quickly yielded the US and UK Department of Defence definitions

US Department of Defence, Dictionary of Military and Associated Terms

  • Command and control — The exercise of authority and direction by a properly designated commander over assigned and attached forces in the accomplishment of the mission.
  • Command — The authority that a commander in the armed forces lawfully exercises over subordinates by virtue of rank or assignment.
  • Control — Authority that may be less than full command exercised by a commander over part of the activities of subordinate or other organizations.

MoD, Joint Concept Note 2/17 Future of Command and Control

  • Command – The authority vested in an individual of the armed forces for the direction, coordination, and control of military forces.
  • Control – The authority exercised by a commander over part of the activities of subordinate organisations, or other organisations not normally under his command, that encompasses the responsibility for implementing orders or directives.

UK doctrine for civilian multi-agency working is based on co-operation of the Emergency Services rather than the control of all relevant resources by a Commander from a selected service (see Emergency Response and Recovery Non statutory guidance accompanying the Civil Contingencies Act 2004). This is consistent through the JESIP programme and the development of the Joint Decision Model.

I get the impression that historically our definitions of Command and Control may have been fudged so that it could be claimed that the concept is at the heart of multiagency response when, in fact, it clearly isn’t. We exercise Command and Control (or at least Command) within our own company or service structures and coordination between companies and services. Generally it seems to work in emergencies. If that is accepted then we don’t need to mangle the definition of control and “The application of authority, combined with the capability to manage resources, in order to achieve defined objectives” can be replaced with something clearer. If we feel that command and control across all the responders is more likely to achieve success than coordination (I’m certainly not in a position to judge this) then we should move in that direction. Either way better definitions of these key terms would be helpful.