IAEA EPR-Medical Physicists 2020 – Guidance for Medical Physicists Responding to a Nuclear or Radiological Emergency

IAEA EPR-MED

https://www.iaea.org/publications/13483/guidance-for-medical-physicists-responding-to-a-nuclear-or-radiological-emergency

In the event of a nuclear or radiological emergency hospital medical physicists may find themselves providing front-line response to the event or supporting their hospital’s efforts to triage and treat potentially contaminated casualties.

The objective of this IAEA publication is to guide the trained clinically qualified medical physicists (CQMP[1]) to act appropriately in a nuclear or radiological emergency and ensure that an efficient and coordinated contribution is made to the management of such an emergency. The knowledge of the CQMP can be vital in the preparedness and response to nuclear or radiological emergencies.

The report is accompanied by a pocket guide which summarises most of the concepts given in the full report and is designed as a working aid. But at 78 pages it would require an unusually large pocket. Rather than be an on-the-day aide-memoir the pocket guide covers a lot of preparedness information from the main report. EPR_Pocketbook_web.pdf (iaea.org)

The main report starts with an introduction to emergency planning giving various definitions of emergencies and then a quick overview of the roles the medical physicist might occupy in the local and nation emergency response plans. The noted roles are:

  • Radiological assessor (RA) requiring a qualified expert in radiation dosimetry;
  • Scientific and technical advisor giving advice on matters related to a nuclear or radiological emergency;
  • Trainer in radiation protection providing training within their own clinical environment and, possibly, within and beyond their hospital. During the emergency the trainer will be able to provide quick briefings on radiation protection to the emergency teams.

The medical physicist may serve in a pre-hospital function supporting triage teams and decontamination actions or in the hospital providing advice and training to medical staff.

I think I would have preferred the report to start with what a nuclear or radiological emergency might look like to hospital staff: many people turning, some injured, some contaminated (some both injured and contaminated), many worried well. This may better grab the reader’s attention.

The concept of a scalable incident command system, allowing multi-agency coordination and rapid decision making over a range of scale of event and the medical physicist’s position in the chain of command are discussed. The importance of each player knowing who they report to and to whom they are responsible in a crisis organisation and the understanding that this may not align with normal management is stressed. The diagram given here, cut and pasted from another document, is not helpful. Showing the medical physicist’s position in a chain built round them might have been better.

In section 4, the report runs through the preparedness phase tasks of risk assessment, training, criteria for exposure, potential roles and responsibilities, personal protection and radiation monitoring, procedures for donning protective clothes & monitoring. This section is not a model of clarity and covers material that a medical physicist might be expected to know.

Section 5, which covers activities related to the response, sees the medical physicist implementing the hospital emergency response plan and ensuring that the facility is protected. They will provide briefings on radiological protection and what may occur during the handling of contaminated patients and they will ensure that proper arrangements are followed to minimise the impact on the hospital resulting from the presence of contaminated patients. This section comes with a useful flow chart tracing the possible pathways to treatment for casualties with different combinations of needs, a list of equipment that might be useful and a list of possible actions (including a flow chart showing different actions assigned to different roles in a coordinated manner).

There is also a section labelled the radiological control of areas which is cut from another document and outlines the demarcation of areas for different purposes and the control of people moving through the system to minimise the spread of contamination. Maybe this material should be in the planning section.

Section 6 is entitled early dose magnitude estimation and decontamination. It suggests that accurate dose assessments are unnecessary in the response phase of an emergency; what is needed is a magnitude assessment: is there a problem with either external radiation or contamination that must managed along with the casualty’s clinical needs?

The report discusses how to assess external radiation dose and reviews the gamma ray constant and inverse square law which will probably not be new to many medical physicists. It also mentions a few computer tools such as the Rad Pro Calculator and the Radiation Emergency Medical Management (REMM) dose calculator which are useful to have available.

There are some tables showing how radiation dose can be deduced from observations about which symptoms show and how long after the exposure they show. Versions of these tables should be in the hospital’s emergency data set.

The report suggests that “Internal radiation doses can be extremely complicated to determine” and that “The aim of the assessment of internal contamination is to quantify the incorporation of radioactive material into the body and to estimate the committed effective dose and, where appropriate, the committed equivalent dose to demonstrate compliance with dose limits”. I think that this is appropriate for individual cases of internal contamination following operational mishap but is wrong in the context of responding to a nuclear or radiological emergency. Here the purpose would be to determine what, if any, medical care the casualty might require because of the exposure.

There is a short section on decontamination of casualties. I am sure I have read better.

In the section on the protection of the public (Section 6.2) the report mentions using plume models etc. to estimate deposition levels but gives no clue about how to manage the results. It also talks about determining isodose curves around sealed sources to help the determination of public external exposure.

The collection of excreta for radionuclide analysis is mentioned but no details of the assay methods or reference to dosimetry models used to estimate dose.

After the initial crisis stage there may be a requirement to improve dose estimates. Section 7, which discusses this area has some “key considerations” and some equations but little in the way of practical advice. Maybe following the references quoted may prove more helpful.

In Section 8 it is argued that Medical Physicists should “enhance their communications skills, so that they can contribute to the timely dissemination of relevant information and contribute, all with the response team, in managing individuals and professionals involved in nuclear or radiological emergencies”. You might have thought that these skills, as opposed to speaking to worried members of the public, came with their job.

The psychosocial aspects of nuclear or radiological emergencies gets a sub-section but this does little more than point to further references.

The rest of the section is a very brief overview of communications skills.

Section 9 is a more helpful section on the contents of a “grab and go” bag. This includes dosimeters (EPD and badges), survey instruments, protective equipment, data sheets and forms and miscellaneous tools.

Section 10 gives a very detailed suggested syllabus for training medical physicists and reading lists which are predominantly IAEA publications and would need a fairly large bookshelf to hold and some considerable time to read.

Appendices provide more detailed advice on reception area layout, tags and forms and summary of OILs and reactions to their exceedance.

This is a potentially useful document for hospitals when considering their plans to cope with a nuclear or radiological emergency and considering how to use their radiation specialists. However, it is not only very uneven in the level of detail given but also does not seem to have considered what skills and knowledge the radiation specialist already has and where they might need some training.

It could be better.

[1] See IAEA Human Health Series No. 25, “Roles and Responsibilities, and Education and Training Requirements for Clinically Qualified Medical Physicists”

FEMA – Key Planning Factors and Considerations

What would you do?FEMA report

…if a dozen dead birds are found near a truck accident site?

…if 20 people complain of tingling in the mouth after eating at a fast-food restaurant?

FEMA have some answers. They have published a new 324-page document discussing key planning factors and considerations for response to and recovery from a chemical incident August 2021).

https://www.fema.gov/sites/default/files/documents/fema_chemical-kpf_060321.pdf

The report shows the potential complexity of responding to a chemical event. Unlike radiological events, chemical events could result in overwhelming numbers of acute casualties, some of which require urgent medical attention with the correct treatments and anti-toxins for the chemical involved – which may not be identified at the start of the event. First responders may be in immediate danger from the contamination themselves, something that is not likely to be true to the same extent for radiological emergencies.

There are broad similarities between the response to a chemical event and to a radiological event (a dangerous substance that can move with air and/or water movements, the need to make decisions with weak information, a complex issue to explain to the public while needing them to urgently take heed of advice, a potentially complex recovery process) but also important differences (rapid onset of medical crisis, wider range of substances to understand).

The FEMA report provides brief details of several chemical accidents, showing the range of events that are included in this class and the complexity of response. It also identifies and discusses the characteristics that are common to chemical accidents which includes the fact that their on-set can be rapid, a quick and effective response is required to save lives, first responders can become exposed, decisions need to be made quickly with a limited understanding of what has occurred, large areas can be affected, communications with the public and between responders is important, medical facilities can be overwhelmed and recovery may take a long time.

It then lists seven Key Planning Factors (KPF), each of which is then given a chapter:

    1.   “Prime the Pump” Pre-Event Planning;
    2.   Recognize and characterise the Incident;
    3.   Communicate with External Partners and the Public;
    4.   Control the Spread of Contamination;
    5.   Augment Provision of Mass Care and Human Services to Affected   Population;
    6.   Augment Provision of Health and Medical Services to Affected   Population;
    7.   Augment Essential Services to Achieve Recovery Outcomes.

It justifies pre-planning with the observation that “A large-scale chemical incident with mass casualties is a realistic threat facing both urban and rural communities nationwide. The risk of misuse or accidents involving toxic industrial chemicals (TIC), which are widely stored in large quantities and are routinely transported by rail, waterway, highway, and pipeline, is substantial”. They also believe that a terror attack using chemicals is credible.

Multiagency planning and preparation are required to face this threat and enable a prompt and effective response. A “whole community” concept of operations is suggested.

The report suggests a systematic approach to planning and preparedness with several discrete steps recommended, each of which is explained in detail with lists of suggested consultees, reference documents, check lists and resource requirements.

It stresses the importance of agreeing how decisions will be made suggesting a process whereby stakeholders agree which decisions will need to be made, the minimum information needed to make them and the potential sources for that information. Decision making processes should be established to select among available options for evacuation, shelter-in-place, decontamination and waste management balancing political/social priorities and public health protection against time and cost constraints, and, therefore, should include discussion of reimbursement/ compensation for resources provided and contingencies if resources are damaged, destroyed, etc.

Another important area for discussion is medical resources. The planning process should establish protocols and procedures for the prioritization of medical resources.

There are a range of ways in which a chemical event can become known – this varies from automatic alarms on chemical plant, reports of smells or gas clouds, reports of unexplained illnesses or collapses of people or animals, active monitoring of public spaces and food. The quicker these signs can be picked up the better. The report discusses possible indicators, what they might mean and how best to use them. By considering what signs might be available and what they might mean in advance the planners increase the likelihood that an event can be detected earlier allowing a better response.

The next step is to characterise the release and its extent with the safety of first responders as a high priority. This requires equipment, training and coordination.

There is a nice discussion about atmospheric dispersion and modelling.

The third KPF refers to communication with external partners and the public. It stresses the importance of communication to enable a coordinated response across multiple agencies, jurisdictions and levels of authority and to inform the public providing key information and advice on self-preservation while countering misinformation and misperceptions.

The section discusses how communications can support a coordinated response, how to inform the public, how to provide time-critical messaging, strategies for effective communications, and best practice (the latter being a useful checklist of 13 elements).

Controlling the spread of contamination (KPF 4) may save lives and will protect the environment. Depending on the nature of the incident, controlling the spread of contamination may involve environmental containment and/or remediation efforts; decontamination of people, goods, or property; and interventions such as evacuations and food recalls. A lot of important decisions may be needed, and considerable expertise and resource bought to bear.

The support of the affected population (Augment provision of mass care and human services to affected population) (KPF-5) provides life-sustaining and human services to disaster- affected populations, including feeding operations, emergency first aid, distribution of emergency items, and family reunification. Additional resources and services may need to be mobilized to support individuals with disabilities, limited mobility, limited English proficiency, children, household pets, and service and assistance animals. Mass evacuations result in a varied group requiring a range of support services.

The basic objective for Emergency Mass Care is to provide for basic survival needs including food, water, emergency supplies, and a safe, sanitary, and secure environment but hopefully it would go beyond that and cater for other needs, reducing the potential for psychological harm.

The report discusses the support that sheltered and evacuated populations might have and the multi-agency strategies that might be considered to prepare to meet these needs, the facilities that may be required to manage evacuations, provide respite, assistance and shelter.

KPF 6 is concerned with augmenting the provision of health and medical services to the affected population. A chemical event could result in a rapid build-up of casualties requiring specialist assistance, including determination of the active agent, the appropriate medical care and the steps required to protect the responders and medical facilities from contamination.

The report discusses medical treatment for chemical casualties which may require that the symptoms presented are treated while the active agent is unknown i.e. provision of oxygen to those exposed to a lung irritant.

The report mentions “CHEMPACKS” which are containers of nerve agent antidotes placed in safe locations around the country (the USA). I do not know if this system is replicated in the UK. The report recognises limitations to this system.

The Tokyo nerve agent attack in March 1995 was serious – 12 people died, 54 were severely injured, and around 980 were mildly to moderately affected. However, most of the 5000-seeking help, many of them with psychogenic symptoms, were understandably worried that they might have been exposed. This demonstrates the value of rapid information dissemination via the media in reassuring the public. It also shows the importance of effective triage at receiving centres in ensuring that medical resources are reserved for those who really have been exposed.

The final KPF is “augment essential services to achieve recovery outcomes”. This section suggests that recovery begins during the planning and response phases. It divides the recovery into three overlapping stages: short term (days), intermediate (weeks – months) and long term (months – years).

Activities and resources needed to attain recovery outcomes will vary depending on the scenario, context, and location of the chemical incident as well as the incident’s impacts on the local infrastructure, economy, and workforce.

The overall objectives of recovery plans and prioritizations are to restore critical services as quickly as possible to limit cascading effects, and to return the affected community to a sense of normality.

After discussing each of the KPFs the report discusses federal preparedness, response and recovery, outlining the four escalating tiers of federal response. These are (1) an on-scene coordinator assessing the situation and watching the response (2) escalation to invoke the National Oil and Hazardous Substances Pollution Contingency Plan (3) a request to the Department of Homeland Security for coordination capabilities and additional federal agency support (4) a Presidential Disaster Declaration under the Stafford Act. These are discussed in turn with examples.

The report provides links to a wide range of additional information and both planning and response tools. Appendices provide a wealth of information including an overview of nine common toxidromes (syndromes caused by exposure to dangerous levels of toxins), a review of US chemical incident policy, legislation and regulation and chemical planning and notification requirements for responsible parties, environmental containment and remediation options, a flow chart showing how medical attention can be targeted and coordinated.

This is a detailed document covering a wide range of material. For a person with responsibility for planning for, or responding to, a chemical incident in the US it is probably a must read. For people with similar responsibilities elsewhere it is a recommended read – read it and compare your level of readiness with that described.

 

 

 

IAEA Handbook on the Design of Physical Protection Systems for Nuclear Material and Nuclear Facilities

IAEA NSS 40TA new IAEA publication has been published (May 2021) (link here) . This has the objective to provide comprehensive, detailed guidance for States, competent authorities and operators to assist them in implementing the recommendations from the IAEA on the Physical Protection of Nuclear Material and Nuclear Facilities. This area is subject to the Convention on the Physical Protection of Nuclear Material (link here). The UK signed on to this, with some reservations as a member of the EU. I cannot establish the current position.

A Physical Protection System (PPS) is an integrated system of detection, delay and response measures. It should comprise people, procedures and equipment to provide defence in depth, with a graded approach, to address the range of threats identified in the applicable threat statement and to protect against both unauthorized removal and sabotage. The PPS comprises interior and exterior intrusion detection sensors, cameras, delay measures, access controls devices and response measures.

The handbook recommends a systematic design and evaluation of the PPS with requirements identification, design, and evaluation phases. These stages are each explained in some detail. This process is fine if you are starting afresh on a new site but, with an old site, you are more likely to be trying to combine systems with a range of ages and technologies into a workable and justifiable system. The principles need to be modified a bit for this circumstance.

The handbook advises on how to deter an attack on a site by making potential adversaries think it an unattractive target because of low probability of success or high risks to themselves.

There are detailed sections on physical protection systems (design, evaluation, testing and technology options) and the management systems required to keep it all operating effectively.

This handbook would be a good read for any security manager and security systems designer.

Improved public messaging for evacuation and shelter in place.

FEMA have just published on the internet a very interesting paper entitled “Improving Public Messaging for Evacuation and Shelter‐in‐Place Findings and Recommendations for Emergency Managers from Peer-Reviewed Research” (April 2021) (link here). It reports the findings of a comprehensive literature review on the factors that affect the level of compliance with advice on personal protective actions (Shelter in place and Evacuation) in the event of a storm, flood or wild-fire. While these situations are not entirely analogous to radiation emergencies and there may be differences in the behaviour of UK and US populations when faced with an external event, there may be some important messages for UK planners to be gleaned from this work.

The work is related to the Protective Action Decision Model proposed in the literature (see figure) which attempts to identify the cues people may be sensitive to, the level and nature of prior consideration, and the on-the-day perception of the threat, possible responses and how others are responding which may influence decision making.

The key advice to those planning systems to warn and inform the public is to understand the potential impediments to action and take steps to address these barriers in advance, provide consistent advice through multiple trusted channels and to provide frequent updates.

Among many observations, those that seemed most relevant to the UK nuclear industry include:

  • Individuals find environmental cues such as sights, sounds or smells that indicate an impending threat an aid to decision making. This puts the nuclear industry at a disadvantage because we cannot show pictures of storm clouds, fast flowing rivers about to burst their banks or raging forest fires. On the other hand, we have the dread many people feel about radiation helping to focus minds.
  • It was noted that, in response to a wildfire, individuals could be categorised into three broad groups:
      • Wait and see (the largest group);
      • Stay and defend;
      • Likely to evacuate.
  • Seeing neighbours evacuate or other leave was a predictor of increased evacuation across a number of hazard types. This is a well-documented response to an alarm and most people will have observed it where they have been in a building when the fire alarm is tested; many people look to others and copy their behaviour.
  • Receiving messages from family and friends in addition to the local authority influenced decision making. Many people will seek confirmation of the preferred path of action from their social circles before acting.
  • Local governments and businesses provide important social cues that can impact on risk perception. Advice to evacuate an area, or even to shelter in place, could be undermined if council employees continued activities such as cutting grass and collecting waste in those areas.
  • Receiving several consistent warning messages from multiple, credible and trusted sources increases the rates of compliance.
  • People tend to use social media as a complementary rather than their primary source of information. Social media was also often used to amplify or share information with others.
  • As mobile phone ownership is now more prevalent than home landlines, public alert and warning calls to landline phone numbers are becoming less effective. The increased reliance on mobile phones may also result in bandwidth congestion during an incident. In the UK where fraction of homes and offices with land lines is falling while the procession of mobile phones is increasing. (See Table A45 in ONS report here which implies that 82% of households have land lines and 90% have mobile phones).
  • Households with multiple vehicles evacuated in multiple vehicles often with staggered leaving times. This is in the context of an impending storm but is plausible in a radiation accident if only as a mechanism for protecting their vehicles. This would add to traffic congestion.
  • There is strong agreement across studies and hazards that women are more likely to take appropriate protective action (SIP or evacuate) than men.
  • Parents with children in the household tended to have more difficulties with making the decision to stay or to leave for hurricanes and flooding. While some of their concerns may be similar to those of other households (e.g., traffic congestion, fuel availability, uncertainty regarding destination, cost), children in the household, especially younger children and larger numbers of children, raised the anxiety level and increased logistical challenges, which caused delays in decision making. Again the dread of nuclear may balance these concerns.
  • Having a pet, especially where there is a strong attachment to the pet, decreased the likelihood of evacuation. Many studies highlighted concerns about shelters accepting pets, the added cost of evacuating with pets and the logistics of having a pet at a shelter as impediments to evacuation.
  • Adults who have dementia or other cognitive disabilities and a caregiver(s) who would evacuate with them have evacuation rates that are the same as, or lower than, others. Caregivers were concerned with the potential for those in their care to be exposed to stigma and lack of privacy in a shelter. They were also concerned that unfamiliar settings would exacerbate their symptoms. Family and friends (the social network) tended to play an important role in determining whether to evacuate or not.
  • Adults with dementia and their caregivers who did go to shelters experienced a range of difficulties, including increased agitation, emotional distress and disorientation. It was challenging for caregivers to provide normal levels of care and comfort in this environment.
  • Care facilities and their caregivers were challenged in making the decision whether to evacuate or not, given their sense of responsibility to their residents. This research also indicated the importance of care facility residents and their families deciding (and documenting) who would care for them in a disaster (e.g., whether or not they would evacuate to a family’s residence) and then not changing that decision as the threat neared.
  • Having a household plan increased the likelihood of taking the appropriate Shelter in Place protective action for a tornado. This may be presumed to apply for any threat, underlining the importance of prior information that encourages preparation.
  • Studies found that individuals grapple with many concerns when deciding to evacuate. According to these studies, the following concerns delayed or negatively influenced the decision:
      • Traffic congestion and the availability of fuel;
      • The ability and cost of evacuating with pets;
      • Costs of evacuation, including travel costs;
      • Potential issues around the legal status of undocumented immigrants;
      • Individuals faced with a public shelter as their primary destination had more reluctance to evacuate. Their concerns include crowding with strangers and being located farther away from social networks.

On the basis of the observations a number of recommendations were made:

  • Use websites and social media platforms and work with local media to provide authoritative, time-stamped, geo-tagged photos and videos of hazards such as rising waters and wildfires. Encourage individuals to share those visuals with friends and family, including via social media. Again, there are differences between these events and radiation emergencies to take into account but there is something to take away from this recommendation.
  • Warning messages should be clear, consistent and strong but not overly dramatic. Mandatory evacuation orders had more weight than voluntary ones and also carried increased media coverage.
  • Changing the geographic areas subject to advice can cause confusion and a resulting drop in compliance. This should be minimised where practical.
  • Messages that clearly described the probable personal impact of the hazard helped individuals realise that they would be personally impacted which motivated protection action.
  • Visuals such as maps and photos improve message comprehension and support decision making.
  • Authority figures acting as role models and being seen to comply is helpful.
  • Tourists who sought information from tourist offices rather than hotel staff were more likely to evacuate (this was in the context of a major storm brewing).
  • The current event should be compared to those that have posed similar threats. Hopefully nuclear industry will ever have a good back catalogue.
  • In the preparation stage relationships should be built with television and radio forecasters and other journalists likely to cover the story should it arise.
  • People should be encouraged to sign up to relevant alert and news feeds, including during the event.
  • There should be a mechanism in place to follow and monitor the social media of authoritative sources to keep information consistent and address inconsistencies and inaccuracies if they occur. In the UK we also try to coordinate the media lines taken before media releases are issued.
  • Communications strategies should be tailored to gender differences. For example, given that women are more likely than men to take protective actions, messaging on preparedness should consider the use of outreach channels geared toward women.
  • Include individuals with disabilities, access and functional needs, and associated advocacy organizations in developing and reviewing community plans for evacuation.
  • If an evacuation may be called for then consider breaking the news at a time that allows the travel to be completed during daylight hours.
  • When issuing evacuation orders, explain the risks that led to the decision to evacuate some zones and why other zones are not evacuating.
  • Provide information about public shelters, including items associated with comfort (e.g., availability of power, air conditioning, rest rooms, and space for families and pets) as well as services for individuals with disabilities and access and functional needs.

The slide library available here is a very good way to assimilate the information given in this report.

IAEA Nuclear Security Series No. 41‑T

Technical Guidance Preparation, Conduct and Evaluation of Exercises for Detection of and Response to Acts Involving Nuclear and Other Radioactive Material out of Regulatory Control

The IAEA’s Nuclear Security Series provides international consensus guidance on all aspects of nuclear security to support States as they work to fulfil their responsibility for nuclear security. The IAEA states that “The overall objective of a State’s nuclear security regime is to protect persons, property, society, and the environment from the harmful consequences of a nuclear security event. With the aim of achieving this objective, States should establish, implement, maintain and sustain an effective and appropriate nuclear security regime to prevent, detect and respond to such events. The nuclear security regime covers nuclear material and other radioactive material, whether it is under or out of regulatory control, and associated facilities and associated activities throughout their lifetimes.

The steps on the way to achieving this include the development of a national detection strategy, the development of detection systems and the processes to monitor and act upon alarms. The response to a genuine event includes notification and confirmation/assessment, location and categorisation, recovery of sources and collection and preservation of evidence. These are explained in detail in IAEA Nuclear Security Series No. 15.

There is an expectation stated in paragraph 6.21 that “The State should carry out exercises under the plan using credible scenarios. Competent authorities should perform exercises and drills at regular intervals, in order to evaluate the effectiveness of the plan. When possible, States should consider participating in regional and international exercises and drills.” IAEA Nuclear Security Series No. 41‑T gives a comprehensive account of how these could be managed.

Exercises can be based on a structured and moderated discussion (a table top exercise) or on activities performed in an operational or field situation to enact a realistic scenario in a manner that simulates, to some extent, the stress and practical constraints of an actual incident (a drill or field training exercise).

The steps taken to plan an exercise include:

  • Determination of the key activities to be exercised – the scope and objectives of the exercise;
  • The format and type of exercise, identifying the constraints that these impose;
  • Agreeing a planning timeline with the key stakeholders;
  • Developing and approving an exercise scenario;
  • Identifying the exercise participants and their roles and determining how any gaps where organisations are not playing will be filled;
  • Developing evaluation criteria.

The report goes through these steps in more detail giving useful advice and warnings as it does. It defines the roles of Exercise Director and exercise planning team; controllers and facilitators, evaluators and players and the support from media spokesperson, observers, safety officer, qualified expert in radiation protection and the rapporteur.

Section 4 of the report discusses: setting up the exercise and preparing for exercise safety; providing exercise briefings; conducting exercise play; and holding debriefing activities and section 5 evaluation.

Appendix 1 gives a useful list of example key activities and actions while Annexes give templates for exercise planning, exercise documentation, assessment and feedback forms and exercise reports as well as an example exercise scenario.

This report is a useful read and contains useful resources for anyone planning such an exercise.

Learning for nuclear emergency planning from COVID-19?

The model of the UK response to a nuclear emergency that results, or may result, in a plume of radioactive material spreading across populated areas of the countryside is to get the local responders, notably the local authority, emergency services and health services, in one place to discuss, decide, coordinate and respond.

Within the model is a unit called the Science and Technical Advise Cell (STAC) with the mission “to ensure timely coordinated scientific and technical advice during the response to an emergency”. We were told that “The STAC should bring together technical experts from those agencies involved in the response and who may provide scientific and technical advice to the Gold Commander. The purpose of the cell would be to ensure that, as far as possible, scientific or technical debate was contained within the cell so that the SCG (and others involved in the response) received the best possible advice based on the available information in a timely, coordinated and understandable way.”

Implicit in this process is the assumption that in any event there is an objective truth and that if scientists chat about it for a while they will determine and understand that truth and be able to explain it to the decision makers who have been too busy on other aspects of the response to explore the science for themselves. The decision makers will be jolly grateful to the STAC and, armed with the scientific consensus, will go on to make the right decisions. They might even say time after time that they are being driven by the science.

In this ideal world, these decisions will be reported to the public and to the media, will be implemented and the crisis will be bought to a close. Also in this ideal world the decisions turn out to be the “right” decisions and the only decisions that could be considered to be “right”, all other options, explored and unexplored, being “wrong”.

One thing we have definitely seen with the coverage of Covid-19 is that the media will not just forward your advice to the public as you might hope. Instead they will turn out an army of interpreters who, fearful that Mrs Miggins and her neighbours will not understand that those in a defined area are being asked to shelter and those outside the area are not, will explain at length what they think “shelter” means and why it has been recommended. They will then find a talking head to explain it again and then another to say that the previous interpretation was wrong and that the public should be being advised to do something else entirely. They will summarise by saying that there is a lack of clarity in what the advice is and who it applies to before cutting to a member of the public who will confirm, in response to a loaded question, that they don’t understand the advice and that they are very worried.

Returning to the decision making, the major issue is that the science does not give all the answers. We may be able to estimate radiation doses to the public, with and without protective actions, but these will be educated guesses rather than accurate. The amount of dose saved (benefit) that makes a protective action (with a cost) worthwhile is debatable and probably different for different people in different situations. The decision to interrupt the lives of people and ask them to stay in their homes knocking back stable iodine tablets is therefore a judgement call not the outcome of a neat equation. This is particularly true when you realise that the estimates of future doses are horribly dependent on assumptions made about what is happening, and what is going to happen, in the bowels of a damaged nuclear facility, what the weather will be when the activity gets out and where the members of the public will be and what they will be doing. Again the media will bring out an army of “experts” to discuss the technology, the science and the decision making process and will argue that the science is debatable, the process flawed and that any of the decisions made are dubious.

Maybe what should happen is that advisors advise and decision makers decide. The spokesperson issuing the advice should state that the decisions have been taken by the Strategic Coordination Group who took into account scientific advice, advice about the incident and how it could develop and the concerns of and for the people affected.

The media should be asked to transmit the advice as given and to resist reheating and reinterpreting it.

That will work.

What are the lessons for the nuclear industry from Covid-19? How do we ensure that our protective action decision making process is robust, transparent, unambiguous and trusted to ensure a high level of public compliance and optimum dose reduction?

REPPIR 2019 Transition

The REPPIR 2019 regulations come into force on 22nd May 2019. http://www.legislation.gov.uk/uksi/2019/703/contents/made

REPPIR 2019 cover

Any person who had a duty under REPPIR 2001 can continue to use these older regulations until May 2020 when they must be fully compliant with the newer regulations.

So what has to happen within the next 14 or so months?

Regulation 3 (application) is fairly straight forward. The operator must compare their holdings of radioactive material with schedules to determine if the regulations apply to them.

A written “hazard evaluation” is required for sites that pass the regulation 3 test (regulation 4). Preparing this from scratch could be onerous for a complex site but most will already have done a lot of the preparatory work in their safety cases. For licensed sites, in particular, a lot will depend on how the regulators want the work presented. If they are content that the safety case is the written hazard evaluation then little work is required. If they want a special document to cover the regulation then a great deal of work may be required to extract information from the safety case, present it and have the document verified and approved. A document of this nature may have to go to the Safety Committee at least once. A time and resource consuming process.

If the hazard evaluation concludes that there is the potential for a radiation emergency then regulation 5 requires a consequence assessment to “consider and evaluate a full range of possible consequences of the identified radiation emergencies, both on the premises and outside the premises, including the geographical extent of those consequences and any variable factors which have the potential to affect the severity of those consequences”. This could be a lot of work and since it all boils down to “how far out should we be prepared to implement prompt countermeasures” it is largely wasted effort as this result can be achieved with far less work.

Regulation 6 requires the hazard evaluation and consequence assessment be kept under review and updated if anything significant changes. This is no different to the old regulations.

The results of the consequence assessment must be reported to the local authority in the form of a “consequences report” (regulation 7). A meeting between the local authority and the operator should be offered to discuss this report and the operator must comply with any reasonable request for more information.

The local authority then has two months to decide on the extent of the DEPZ and to report it to the operator and regulator. This seems to be a bit ambitious since the regulators, who had more expert resource and a deep understanding of the sites’ safety cases could take several years from receipt of a Hazard Identification and Risk Evaluation document (a required document in REPPIR 2001) to determining a detailed emergency planning zone.

Regulation 9 provides the rules for setting an outline planning zone, a new feature. This is set by a series of rules but only time will tell if these rules result in clear answers.

Regulation 10 requires the operator to produce an emergency plan based on guidance about principles, purpose and content given in schedules. It is likely that operators will have to review their on-sites plans to ensure compliance but not at all clear that this effort will lead to better emergency preparedness. This review will probably fit comfortably within the one year transition period but it will require resources.

Regulation 11 sets the requirement for a local authority off-site plan. Again this will already be in place for most sites but a review against the new guidance would probably be called for. There are a number of changes to dose control and limitation (regulations 18, 19 and 20) that will need to be thought through. Local authorities may find this hard to resource.

A new element of the regulations is the concentration on keeping doses below 100 mSv. There are good reasons to propose this (the IAEA support for the statement that no harm occurs for exposures below 100 mSv, for example) but it may be difficult in some cases, particularly for unlikely severe accidents. The operators may need some time to think through this issue.

The review and testing of plans (regulation 12) is little changed from REPPIR 2001. The only issue might be the disruption to the review and testing programme caused by the introduction of new regulations.

The new regulations demand a lot of consultation, co-operation and agreement (regulations 7, 9, 10, 11, 12, 13, 14, 15, 18, 20, 21, 24). Consultees include other local authorities, category 1 responders, health authorities, public health organisations, regulators, employers, employees. This is well meaning but it takes time and resources and takes the consultees away from their day jobs.

In summary. Within a year of May 22 2019 the operators of nuclear sites are expected to produce a consequence assessment and a consequence report based on their safety cases, the local authority are expected to use this information to determine the extent of planning zones, the operator and local authority are to produce emergency plans compliant with the revised regulations and a significant number of groups are to be consulted, informed or trained.

Writing significant reports in the nuclear industry tends to take a while. They need to be drafted and verified. Reports with the importance of the two related to these regulations would normally go to the site’s nuclear safety committee for review and approval. This is a time consuming process, particularly if the committee wish to see changes and resubmission, which is not an uncommon result particularly for novel reports, as the first of these will be.

The local authority are allowed two months to consider the information provided by the operator and the layout and demographics of their area to decide upon the extent of the planning zones. They will need a process to brief their chief executive and get the conclusion endorsed within this timescale.

Emergency plans may have to be updated if the detailed emergency planning zones have changed (and if they haven’t then pretty much all of the work leading up to this stage has been pointless). Plans will have to be updated to account for the differences in expectations between the 2001 and 2019 regulations, in particular the outline planning zone, the 100 mSv reference level and changes to emergency dose terminology.

It is going to be a busy year chasing tight timescales for some in the local authority and nuclear industry emergency planning world.

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.

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”.