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.

REPPIR 2018 delayed?

The SRP tell me that “BEIS has advised that it is its intention to publish the Government response to the REPPIR consultation and the draft REPPIR regulations in late Spring 2018 with a view to laying the regulations before Parliament in Autumn 2018”.

I thought that the new regulations had to be in place in February of this year but didn’t think they were anywhere near enough to completion.

I can’t yet find a BEIS press release on the subject.

Decline or fail – When the nuclear planning local authorities cannot match expectations.

I was interested to learn that the American system has a mechanism to respond to a situation where a nuclear power station cannot get adequate support from the local responders for their off-site plan. Their rules define “decline or fail” as a “situation where State or local governments do not participate in preparing offsite emergency plans or have significant planning or preparedness inadequacies and have not demonstrated the commitment or capabilities to correct these inadequacies in a timely manner so as to satisfy NRC licensing requirements”. (44 CFR 352.1)

An Executive Order enacted by Ronald Regan in 1988 summarises the situation. Chapter and verse can be found in Code of Federal Regulations 44 Emergency Management and Assistance (dated 2002).

The licensee seeks Federal assistance by submitting certification that a decline or fail situation exists to the host FEMA Regional Administrator explaining why assistance is needed and providing documentary proof that they have tried to rectify the situation themselves.

This is reported to FEMA Headquarters and the involved off-site organisations. The State and local governments have 10 days to submit a written report of their views and position and FEMA make a determination about whether or not a decline or fail exist within 45 days of the original communication.

The FEMA Deputy Administrator for the National Preparedness Directorate shall make a final determination as to whether Federal facilities and resources are needed. This process identifies what resources could be called on, the extent and purpose for which they can be called and the limitations on their use.

Interestingly it is assumed that the State and local authorities will contribute their full resources and exercise their authorities in accordance with their duties in a real event.

The Federal resources are to take care not to supplant State and local resources and only make good the impact of the decline or fail. FEMA will attempt to recover the costs incurred from the licensee and from the nonparticipating or inadequately participating State or local government.

In the UK REPPIR requires co-operation from various bodies and requires that the off-site plan be reviewed and tested but makes no mention of what happens if off-sites are deemed inadequate.

Communicating the risks of particulate and chemical air pollution and air-borne radioactivity.

There is an interesting article “Cutting through the smog” by Nic Fleming in the 6th May 2017 New Scientist. There are some scare statistics given – “it is estimated to be behind 200,000 untimely deaths each year”. But, as the author points out quantifying the impact of air pollution is a more complicated and uncertain business than the headlines admit.

There are parallels with the issues of environmental radioactivity and distrust of the nuclear industry.

Air pollution and radioactivity do not kill in the same way as being hit by a London bus might. Air pollution may aggravate other problems you have and has been linked to respiratory and pulmonary diseases and stroke. A UK committee has estimated that the anthropogenic PM2.5 released at 2008 levels would shorten the average person’s life by six months. This is morphed into costing 29,000 deaths a year in the UK, which is the major headline carried by the media.

Similarly radiation, in low doses, does not lead to instantly noticeable effects but rather is suspected of leading to an increase in the incidence of cancer in later years. Quantifying the additional cancer risks posed by different types of radiation at different doses, different dose rates and on people with different inherent cancer risks is complex and usually, by necessity, over simplified when attempting to explain it to the public. ICRP states that the linear no-threshold hypothesis “remains a prudent basis for radiation protection at low doses and low dose rates” but there is also an increasingly strong insistence that there is some kind of a threshold at 100 mSv. (See IAEA EPR Communicate).

In the UK it is the local authorities that are tasked with implementation of the national air quality strategy. The Lancet  fears that this will lead to a fragmented approach “as hundreds of local authorities (tasked with implementation) attempt to follow central government guidelines” and they doubt the “the ability of the government to measure progress and hold failing local authorities to account”.

Unfortunately the steps taken to reduce air pollution, particularly in cities, have always struggled to keep up with increased road usage and, particularly, increased use of diesel engines. The New Scientist report questions the effectiveness of the London Low Emission in reducing levels of pollutants or related respiratory and allergy problems in children despite its wide scope. Encouraging more people to walk or cycle and providing low emission public transport would seem to have just reduced the rate of increase of vehicle mileage in cities. Well worth doing but not enough. It is noted in the article that emissions of a number of key pollutants in the UK are dropping, for some quite dramatically. But more progress is desired.

The report claims that face masks vary from about 80% to 30% effectiveness at filtering particles from the air but it depends on the nature of the mask, the nature of the pollution and, importantly, the quality of the fit to the face of the mask. Unless they are treated with appropriate chemicals the masks have no impact on gaseous pollutants such as NO2 and SO2. Face masks are not recommended in the UK as an effective countermeasure against inhaled radioactivity in the event of a reactor accident because of concerns about their effectiveness without face fitting and training and because the principle component of concern are the radioactive iodine species. The preferred approach is to remove the person from the threat by sheltering or evacuation. For a non-technical discussion about face masks see an article by the survival mom and the comments attached to it.

A difference between air pollution and environmental radioactivity is that the public do not seem to fear air pollution to quite the same extent. Shunichi Yamashita reflects on the situation around Chernobyl and Fukushima following the two severe accidents in those places in the New Scientist of 13 May 2017. He reports that the big surge in non-thyroid cancers and genetic effects in the areas affected by Chernobyl that some predicted have not been detected. His advice to people in Fukushima in the early aftermath of the accident there, which was to try to relax and to try not to worry about the enhanced environmental radioactivity, was widely condemned but he still contends that he would expect no apparent health effects when the exposure was below 100 millisieverts a year. (I’m not sure about the “a year” bit, it might be a misunderstanding. ICRP advice is that a one-off residual dose of 100 mSv is probably not harmful but that the dose-rate thereafter should be no more than 20 mSv a year. (See ICRP letter to Fukushima residents).

The article concludes that psychological effects from the trauma of evacuation and the fear of radiation are now the biggest health consequences of the nuclear accident at Fukushima. Adults are experiencing depression, sleep loss and anxiety. There have been more than 80 suicides linked to the accident to add to the 60 people who died due to poor medical support during the evacuation. But there have been no deaths or sickness from direct exposure to radiation.

The conclusion from comparing the articles on air quality and post-Fukushima health concerns is that understanding the impact of airborne pollutants including ozone, particulates, NOx and SOx and radioactivity is very difficult. Communicating those potential impacts to the public is also very difficult but also very important. Without an understanding of the relative impacts of different aspects of modern life it is not possible for the public to understand the absolute and relative risks posed or for governments to sensibly prioritise policy and funding.

Notification of Withdrawal Bill and Euratom

One paragraph of the European Union (Notification of Withdrawal) Bill Explanatory Notes states that “The power that is provided by clause 1(1) applies to withdrawal from the EU. This includes the European Atomic Energy Community (‘Euratom’), as the European Union (Amendment) Act 2008 sets out that the term “EU” includes (as the context permits or requires) Euratom (section 3(2)).”

It would be interesting to know what the impact on the UK nuclear industry might be if the UK were to withdraw from Euratom. It would give us more freedoms to run the industry as we see fit but that may not be such a great idea and it might reduce public and world confidence in us. There are, of course, many other international nuclear organisations such as IAEA and WANO that we can use for guidance and bench marking.

The revision of REPPIR

With the Radiation (Emergency Preparedness and Public Information) Regulations 2001 due to be reissued in line with the 2013 EU BSS (See HSE note), interest turns to the discussion about how to determine the appropriate level of emergency preparedness for nuclear sites.

Currently REPPIR requires that the risks posed by the site are assessed, reported and periodically reviewed. If there are identified potential fault sequences that exceed thresholds of both probability and severity then off-site plans are required.

The threshold for probability is “reasonably foreseeable”. In the REPPIR guidance (para 50) it is stated that “In the context of a radiation emergency, a reasonably foreseeable event would be one which was less than likely but realistically possible”. ONR have avoided accepting a numerical value for the threshold of reasonably foreseeable (see, for example, para A20 -A22 in an ONR TAG).

ONR’s description of safety cases tells us that (Para 607) Design basis analysis (DBA) leads to an understanding of the plant and a design proven “so that safety functions can be delivered reliably during all modes of operation and under reasonably foreseeable faults”. Combining this with (Para A.9) “only faults with an initiating fault frequency (IFF) greater than 1 x 10-5/yr need to be considered for DBA” suggests that a frequency of 1 x 10-5/yr could be proposed as the limit of a “reasonably foreseeable” initiator.

1 x 10-5 per year is also implied in the ONR Tolerability of Risk Document ToR and in the national risk assessment policy sponsored by the Cabinet Office as a boundary between events that should be prepared for and those that are too unlikely for detailed planning.

The threshold for severity used in REPPIR 2001 is that of a Radiation Emergency. This is defined as a situation in which a member of the public could receive an additional radiation dose of 5 mSv in the year following initiation. There have been difficulties interpreting this requirement as the public dose assessment depends on the individual habits assumed.

There is a general principle in radiological protection and emergency planning that any action taken by authorities should to do more good than harm. In the UK we use the Emergency Reference levels (ERLs) to decide if a countermeasure is warranted by comparing the avertable dose with the relevant ERL. We can therefore state that the imposition of a countermeasure is not necessary, indeed not appropriate, where the avertable dose is below the ERL and a detailed plan to implement a countermeasure is therefore not needed where it is not reasonably foreseeable that the threshold will be exceeded. Thus the severity threshold for requiring a plan can be based on whether or not the existence of a plan would enable the imposition of prompt countermeasures which could avert an ERL’s worth of dose that could not otherwise be averted.

Concern about faults too unlikely to appear in the DBA but more severe than the reference accidents leads to the demand for the ability to extend countermeasures beyond the detailed plan if required. However, it is realised that spend to enable this quickly becomes grossly disproportionate to the potential gain.

While the situation analysis and decision making process provided by the detailed plan can consider a wider area or longer duration fault, the question is whether or not countermeasures can be applied rapidly enough over a wider area to be effective. This would depend on the nature of the fault including the amount of activity released and the time structure of that release.

Again the question of the probability of the limiting fault to use in extendibility scenarios arises. In various safety methodology documents IAEA talks about a “screening probability level” (SPL) of probability below which there is no point analysing faults. So far as I can find IAEA fails to suggest a value. There is a claim in the literature that the US DOE suggest 1 x 10-6 for aircraft crash onto nuclear facilities. It is suggested that future UK guidance on emergency planning recommends a SPL for emergency planning (extendibility) and that this value should not be lower than 1 x 10-6 or, at a pinch, 1 x 10-7.

Emergency planning then becomes a question of having detailed plans to implement those countermeasures that might avert more than an ERL of individual dose for the set of reasonably foreseeable faults – defined as being more frequent than 1 x 10-5 per reactor year (making allowances for reasonable cliff-edges) and outline plans for faults down to maybe 1 x 10-7 per reactor year. Estimations of avertable dose against downwind distance can determine a sensible limit to the countermeasure zone (which regulators may then choose to inflate within reason for non-technical purposes).

Major step towards decommissioning Magnox’s emergency plan

The ONR has recently agreed to a major revision of the Magnox Limit’s emergency plans. In a Project Assessment Report available on the internet they approve the removal of the Central Emergency Support Centre (CESC) from the Magnox emergency plans.

The CESC is a large control room in EDF’s headquarters in Barnwood. It provides for the off-site support for a nuclear power station in an emergency situation. Command, technical, health physics and support teams are available at short notice during working hours and within an hour or so out of hours. The technical team helps to understand the situation on the site and provide advice on how to rectify the situation and on the release prognosis. The health physics team takes over the off-site survey and combines the knowledge gained about off-site doses with the predictions of the changing situation from the technical team to provide estimates of the public avertable dose to support the countermeasure decision process in the Strategic Coordination Centre.

With no operating reactors and most of the fleet defueled the changes of Magnox using this facility is greatly reduced. They have developed a new simplified system that is more in line with the evolving Company risk profile and tested it to the satisfaction of the ONR.

EDF-Energy, with their fleet of operating reactors will continue to use the CESC.

Removal of the CESC from the Magnox plans is an important step and was a complex process. Magnox and the ONR should be congratulated on the success of this project.

SRP meeting on BSSD implementation

 

I attended the SRP one day meeting on the Implementation of BSS: Ionising Regulations (IRR) and Other Regulations held on 19/1/17 in London. The aim of the Basic Safety Standard Directive in question (Directive 96/29/Euratom – ionizing radiation) is to establish uniform basic safety standards to protect the health of workers and the general public against the dangers of ionising radiation…”.

It was explained that the 2013 Basic Safety Standard has to be implemented in UK law by February 2018 but there were issues relating to registration and dose records that made 1/1/18 a more practical starting date for some clauses of the regulations. Before then there would be a consultation period (which should have started by now), a review of the draft based on the consultation, a final consultation with lawyers and then the draft would be put to the Ministers. The impression was given that the Ministers have a greater ability to change the draft than the consultees. The regulations should be submitted to the EU in autumn and become law in early 2018. It was not explained why so much activity is compressed into the last year of the implementation period given that the BSS was published in 2013 and had been widely consulted on before that.

The graded approach to regulation to be used in IRR17 was described. This balances the requirements of the BSS against the desire for minimal change to UK law and as light a touch as is appropriate. The system of Notification, Registration and Licensing of practices of increasing potential harm will require the user to enter the details of their practices into a web-site database and answer a series of questions to confirm that they have met the requirements of the regulations in terms of risk assessment, contingency planning, training and consultation of an RPA. This system seems very sensible although a number of questions were asked about the number of entries that users of multiple systems and multiple different practices would have to make – one per practice apparently.

The section on REPPIR was very disappointing. It seems possible that the drafting of these regulations and associated guidance are further behind schedule than the IRRs. There was either a reluctance or inability to answer fairly predictable questions from the audience which does not bode well. There are a number of contentious issues with regard to emergency planning regulation in the UK and very little time to adequately consult and get this regulation right. It is important to decommissioning sites, generating sites and new build operators and to the local authorities in whose patches the nuclear sites are found.