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.

Emergency Planning Society – Ripples workshop

I attended the Emergency Planning Society’s Human Aspects Group’s workshop entitled “The Ripple Effects of Major Incidents” in Cardiff on 16th November 2017. The speakers were people with first-hand experience of responding to support those affected by major incidents or of being caught up in them themselves.

This workshop was about the people affected by an event and the practical and emotional support they may need at the time of the incident and afterwards. They may need help coming to terms with their experiences and with their losses. This is a process that could take many years.

This was unusual territory for me. I used to be a responder at site or company strategic level in the nuclear industry where, in exercises, the news that a Reception Centre had been set up was a satisfying tick in a box that required no further thought. To be fair to us we had other things to keep us busy.

Why “Ripples”?

It is easy to underestimate the number of people affected in an incident. For example, in a terrorist event, there are the injured that need immediate care and some who will need continuing support to cope with “life changing injuries” – a highly sanitised term for some dreadful outcomes.

Beyond the physically injured are the witnesses. Those who experience things that most of us never will; traumatic things that can lead to severe mental scars that affect every aspect of life. People who, because of their experiences, are too scared to walk along the High Street or be in a public space. People who suffer repeated flash-backs and who feel survivor-guilt. People who can’t sleep well. These are life defining phobias and conditions. Children cannot access education, adults cannot cope in the workplace. This can result in a downward spiral of increasing anger, dependency and/or despair.

There are the families of the dead, families of the injured and families of the traumatised. All have their lives changed for the worst and have to come to terms with those changes.

There are people who narrowly avoided being a direct victim. People how didn’t catch that train for a trivial reason, people who didn’t go to that concert, people who live in the next tower block along (or indeed a tower block in a distant town or city).

There are the people who responded to the incident; professionals such as the police and medical personnel, but also the bystanders who come forward to give spontaneous help. Some of these will need emotional support to help them process their experiences.

There are the people who have lost their homes or their livelihoods, either permanently or temporarily, as a result of the event and need timely practical support.

Experiences of response

Some of the speakers reported their experience of responding in the first hours and days after serious incidents and explained the role of the Families Liaison Officer and charities.

In one event an apparent lack of coordination and leadership resulted in badly designed and managed survivor and community support which quickly resulted in anger and recrimination. Later improvements in the responders’ performance improved matters but, by then, a lot of damage had been done to the relationship between the community and the authorities.

Another report of a different response was more positive. A difficult situation requiring a lot of rapid decisions, some of which stood the test of time whereas some didn’t. A lot of learning already revealed and more to come as the analysis progresses. Interestingly and encouragingly the speaker described their recovery plan as being based on the national guidance and broadly successful.

A stitch in time saves nine

A few themes emerged from the presentations and discussion.

The support on the ground for those immediately affected needs appropriate design and competent management. In the first few hours the care needed will be largely medical for a number of people and the immediate needs of comfort, shelter and sustenance for maybe more people.

Within hours to days those affected may need wider support. They may be separated from their cash, credit cards and their travel season tickets. Without immediate help they risk an escalation of consequence – jobs, or at least earnings, lost as they can’t get to work. Education disrupted for children who can’t get to school.

Loss of other documents, such as passports and identification, can quickly become a problem for some and, without the correct support and advice, they may struggle to hold their own.

Businesses may be suffering, particularly if they are based inside police cordons.

These problems can be solved. We heard from Victim Support and from the British Red Cross on the services they offer and their experiences with things that went well and things that took longer to get right. It is possible to mobilise quickly. There are individuals and organisations with experience in supporting affected communities. Each time they are called upon they can be expected to get better, if the conditions on the ground, resources and coordination allow.

A number of big questions were posed:

  • How do you identify the needs of those affected and break through established procedures and budgets to provide help in a timely manner?
  • What do you do if a Category 1 responder is failing to cope? (or indeed any component of the response?)
  • What do you do with gifts in kind (which can be in overwhelming quantities and of a wide range of suitability)?
  • How do you coordinate and get the best out of spontaneous volunteers?
  • How do you manage social media in a positive way?

Learning points:

  • Social media is both a blessing and a curse. We heard of social media platforms being set up by individuals or organisations that attempted to help those affected but which attracted advertisements from the likes of Funeral Directors and Claims Lawyers, abusive messages or were used by journalists as source material for unauthorised articles. But we also heard of the real value of enclosed systems that could be set up on platforms such as Yammer and had a debate about who should manage them for the years that they might be needed – currently the police manage some.
  • Mobile phones allow families and friends to reunite without support. This does mean that the facilities set up to help reunite families see a higher proportion of bad news to good compared to the expectations of some years ago.
  • Nurses trained in the SWAN end of life care techniques and the police Family Liaison Officers can provide emotional and practical support for the bereaved.
  • It takes planning, experience and considerable resources and skill to set up the ideal range of support facilities for those affected in different ways by an event. Getting it wrong can quickly lead to worsening experiences, anger and lasting harm for individuals and communities.
  • The media can intrude upon facilities for survivors and family and friends. They should be controlled but helped to get appropriate material for their needs.
  • It is important to gather and understand data on the types of people affected and their needs as these change with time and there are humanitarian and reputational drivers to keep the gap between needs/expectations and delivery small.
  • Mutual support groups within those affected can be very useful to some people trying to cope in the aftermath of trauma. The ability to discuss matters such as poor sleep, anxiety, and availability of therapy with similarly affected people can be very positive.
  • People displaced from their homes and temporarily settled elsewhere benefitted from a single facility where they could access a range of help (CAB, Banks, Social Services etc.) but also greatly benefited from the opportunity to meet and chat with their neighbours (photos of sofas and coffee tables in the middle of a Sports Hall).
  • It is important to try to work with social media rather than against it – In Manchester there was a social media campaign for a vigil in support of the victims and defiance of the perpetrators. Enabling this, and supporting other such moves, was seen to be very positive.
  • Support may be required for many years after the event and includes, in addition to individual support, such things as organising ceremonies on key anniversaries and organising permanent memorials, both of which require careful attention to the wishes of those affected – which may not all be the same.
  • Donations in kind and in cash can be overwhelming, can take considerable resources to manage and can lead to incriminations and anger if not done to everyone’s satisfaction.
  • There is a need for some kind of Advocacy Service for the survivors of terrorism to ensure that they get the support they require. This includes practical help to cope with physical injuries, help with the mental injuries, financial support and help to build a life and access education and work that takes survivors’ trauma into account. (In an ideal world this would not be needed because the background social support should be managing).

Closing remarks

There were two very moving first-hand reports from survivors of terrorists’ attacks. Both exhibited anger at the inadequacies of support they have been offered in the UK, which compares badly to some other countries, and which clearly let them both down badly.

Something is broken. Survivors are not getting the support they need. It is clearly of concern to the emergency planning community and we should not think that our job is done when the final police cordon is removed. We have some level of responsibility to ensure that those caught up in an emergency are cared for in an appropriate manner.

Dealing with urgent and continuing medical needs is the remit of the emergency services and National Health Service although organisations such as CitizenAid have identified a role for prepared bystanders. The setting up and managing facilities to cope with the practical needs of those affected within the first hours and days of the event is quite clearly, I think, part of an emergency response and within the remit of emergency planning. Guidance is clear about responsibilities.

However, it could be argued that the longer term care of people with severe physical injury, with psychological harm and permanently displaced from their homes is not within the emergency planning and response remit. The UK should be doing better in these areas but our role in making it happen is, as an organisation, probably limited to raising concerns with the authorities and, as individuals, calling to account those in authority and those with responsibility in these areas – if we could only identify them.

A few of the attendees were from Social Care and Health roles in local government. It is a pity that there was no senior representative from central government or from the mental health world as defining and solving the problem is probably beyond our pay grades and their views would have been valuable.

© Keith Pearce, 20/11/2017

K.I.Pearce asserts his right to be recognised as the author of this document.

A restatement of the natural science evidence base concerning the health effects of low-level ionizing radiation.

This paper has the stated aim of restating the evidence available on the health effects of low level ionizing radiation. It reports that it is known that high levels of radiation are detrimental to the health of organisms including humans but that it is less clear at low levels (low doses or doses delivered at a low rate) with some arguing that current radiological protection standards are too lax and others arguing that they are too severe.

The authors penned a draft review of the data which they discussed at a one day workshop. Here they classified the data sets according to their view of the strength and consistency of the evidence presented. The review was revised and then circulated to a wider circle of experts in the low level radiation field for comment and further revision.

I particularly like figure 2 of the paper (available as a download) which shows a number of datasets of measured effect against dose. It is clear that there is a trend for effect to increase with dose but much less clear that this trend is well behaved at low levels. This figure and the paper summarises the issue nicely. What is happening at low dose and low dose rates?

ResmodelThe diagram shown is figure 3 from the paper. It shows a number of different potential risk models that can be compared to the data. These include the linear no threshold model (LNT), which postulates a straight line through the origin and the linear with threshold, which postulates that there is a level of dose below which no harm is experienced. The former is used by ICRP and a number of other international authorities as a plausible and conservative assumption. The threshold argument also has its proponents who believe that LNT leads to excessive spend on pointless dose avoidance.

Hormesis is an interesting one. It is based on the suggestion that small amounts of radiation can be good for you.

The caption to the diagram states that “at sufficiently low doses, all models are consistent with available datasets”.

The paper provides a brief discussion of a number of studies:

  • Variations in natural background in different places across the world;
  • Acute high level exposures;
  • Low level exposures;
  • The Japanese life span study (recognised as the “gold standard” for learning);
  • Chernobyl workers and exposed members of the public;
  • Fukushima;
  • Workers;
  • Medical exposures;
  • In-vitro studies.

It provides a number of interesting headlines for each category but, deliberately refuses to come to any conclusion.

This is a useful and interesting paper resulting from some careful and systematic work. I am grateful to the authors for producing it and I recommend it as a good read.

Reference: McLean AR et al. 2017. A restatement of the natural science evidence base concerning the health effects of low-level ionizing radiation. Proc. R. Soc. B 284: 20171070.

Protective Action Guides

In the United States the Environmental Protection Agency issues “Protective Action Guidelines” (PAGs) which satisfy the same role that Emergency Reference Levels (ERLs) do in the United Kingdom. The Protective Action Guide (PAG) manual contains radiation dose guidelines that would trigger public safety measures, such as evacuation or staying indoors, to minimize or prevent radiation exposure during an emergency.

The 2017 PAG manual is a significant document (101 Pages) which has chapters devoted to:

  • Early phase protective action guides;
  • Emergency worker protection;
  • Intermediate phase protective action guides;
  • Planning guidance for the late phase.

For the early phase it provides a PAG for shelter in place or evacuation of the public of 10 to 50 mSv projected dose over four days. This is accompanied by a note that suggests that actions should start at 10 mSv projected dose and take whichever action or actions result in the lowest exposure for the majority of the population. This is broadly consistent with IAEA advice and UK practice although the UK ERLs are based on averted dose rather than projected.

 The stable iodine PAG is 50 mSv to the infant thyroid from exposure to radioactive iodine.

Emergency workers should be limited to 50 mSv over the entire response or per year unless there are extreme circumstances (such as saving life or preventing a significant release).

The report warns that: “In the early phase, there may be little or no data on actual releases to the environment and responders may have to rely on crude estimates of airborne releases. Decision time frames are short and preparation is critical to make prudent decisions when data are lacking or insufficient.”

The report suggests that the public should be advised to cover their mouth and nose with “available filtering material” when particulate activity may be present. This advice is not given in the UK.

It is also suggested that where particulate activity is present but below the PAG level the public are advised to “stay indoors to the extent practical” to reduce their dose but make a judgement if they need to go out for any reason. Such advice is apparently given on days when air pollution is forecast to be bad. Again, this is not something I’ve heard mentioned in the UK.

 A discussion about the relative merits of shelter in place and evacuation concludes that “Sheltering-in-place should be preferred to evacuation whenever it provides equal or greater protection. Sheltering-in-place followed by informed evacuation may be most protective”. It reports that populations that are aware of the evacuation alerting mechanisms and plans are more likely to successfully evacuate than unprepared populations and further reports that many areas are improving their communications processes and public training. The need to have special plans for needy groups such as schools, institutions and those without their own transport is noted.

On iodine tablets the report suggests that minimum doses for each age (weight) group is ideal but that, if this is too challenging logistically and in terms of communication, then a full dose can be given to all without great risk.

Interestingly it suggests that adults over 40 years old would only benefit from stable iodine if their projected thyroid dose is of the order of 5 Sv where it can be used to prevent hypothyroidism.

Stable iodine given to pregnant women also protects the foetus but repeat doses should be avoided if possible to prevent foetal thyroid complications. (In the UK it is expected that a single dose of stable iodine will be adequate because either the release will have stopped or the affected members of the public should be evacuated within the 24 hours that the first dose provides protection for).

Breast feeding mothers can reduce the radioiodine in their milk by taking the usual dose of stable iodine. This is useful for reducing the baby’s dose but does not protect them from directly inhaled radioiodine for which a small dose of stable iodine can be administered.

Section 2.3 discusses the process of estimating dose projections based on source terms, atmospheric dispersion and release prognosis. Section 2.4 discusses contamination and environmental monitoring.

Subsequent sections discuss the control and limitation of dose to responders and recovery workers and doses in the later phases of the event, including from food and water, once the release has stopped. Of interest is table 4-2 which summarises a discussion about the circumstances under which people can be allowed back into an area, either for remedial work, use of critical infrastructure, to access business and homes to recover property.

On the whole the advice given in this report is similar to that given in the NRPB’s ERL documents that are used in the UK. It contains some interesting and useful discussion.

“keyhole” countermeasure zones


Experience of the environmental remediation of Fukushima

The IAEA has published proceedings which present the outcome of a conference on decommissioning and environmental remediation (D&ER) programmes, at which challenges, achievements and lessons learned in the implementation of such programmes during the past decade were shared and reviewed (here).

An interesting presentation by Tadashi INOUE, Research  Advisor to Fukushima Prefecture on Remediation (here) Session 4b No 11) which, if I understand it correctly, argues that, for the decontamination around Fukushima:

  • The lack of understanding of radiation in the general public was a barrier to the initial discussions and this helped sour the relationship between the people and the authorities.
  • The variety of players acting and publishing independently in the early stages caused confusion and insecurity. Better co-ordination of monitoring and interpretation should be sought from an early stage.
  • Target levels for decontamination and dose reduction should be set based on radiological, technical and sociological issues and within the ICRP 1mSv/yr – 20 mSv/yr band.
  • The development of a decontamination strategy is a priority. The highest contaminated areas are not necessarily the place to start rather the emphasis should be on dose reduction.
  • The acceptance of community and property owner is essential for the progress of remediation.
  • Gaining the trust of the people is made difficult by the number of different opinions being expressed in public. In Japan they seem to have more trust in academics than in officials.

Some of this learning may not apply in the UK due to differences in the behaviour of society.

The balance of centralised coordination of the monitoring and interpretation against independent work by various bodies will be hard to manage to optimise trust, understanding and joint decision making.

Finding a process where the trust of the residents can be developed through dialogue will take time and will be made difficult by the actions of some parties multiplied by the impact of broadcast abd social media. The level of anger expressed around the Grenfell Tower fire in London over shortcomings in the care offered to the survivors in the hours and weeks after the event and the media involvement in the Charlie Gard court case show how difficult the situation can get and how distracting the views of people outside as well as those inside the issue can be.

(All figures from Tadashi INOUE presentation to IAEA (Madrid, May 2016))

Costs of decommissioning UK nuclear industry

cost of decommissioining

The NDA have issued a statement on the estimated costs of decommissioning the parts of the UK nuclear industry that they are responsible for (here).

It shows total costs in the range £97 billion – £222 billion with a best estimate of £119 billion over 120 years. Discounted cost is put at £164 billion which is higher than the unadjusted cost because the NDA now use negative discounting rates as explaining in the supporting document from the Treasury (here) but more clearly in an Annex to the Annual Report (here).

The current value of £164 billion compares to £160.6 billion a year ago. This includes £1.3 billion being added to the estimated cost of completing the job. Inflation and changes to the discount rates being applied explains the rest of the increase.

So despite £3.243 billion being spent and an Annual Report talking of good progress the estimated cost to completion is more than it was at the start of the reporting period.

The Annual Report admits that £100 million was spent in compensation following the flawed contest for the Magnox contract.



The financial case for Hinkley Point C

The government have updated their contractual documents and supporting information for Hinkley Point C (here).

The decision taken by the Secretary of State (SoS) for the Department of Business, Energy & Industrial Strategy to direct the Low Carbon Contracts Company (LCCC) to offer a Contract for Difference (CfD) to Hinkley Point C was based on the Value for Money Assessment published on this site. This means that the Government will reimburse the operators if they have to sell electricity below the “strike price”.

This is based on the belief that, left to themselves, “market failures” would result in a undesirable configuration of the electrical generation and distribution system.

Businesses are more likely to invest where the return on capital is rapid and secure. In the electrical generation world this means gas turbines and other cheap and quick to install kit. The current designs of nuclear reactors under construction are far from this ideal. Expensive, with long lead times and technical and political risks involved. The investor has to put in a lot of money upfront and wait a long time for returns. A technical or political hitch could wipe those returns out at any time. A principle of the CfD justification is that the investor should get a fair return for risking their capital over a long period of time on a “first of class” power station. It is a risk sharing mechanism that saves the government from direct investment in the project.

The market does not fully take into account the real societal costs from burning hydrocarbons and by itself would not reduce the production of greenhouse gases associated with fossil fuel combustion. So subsidies are given to low carbon generators to bridge this unfairness. This is an area of controversy with some believing that all subsidies are wrong and others wanting them only for their preferred version of “green”. Nonetheless some of the CfD is to encourage low carbon generation.

Another consideration is diversity of supply. It is true that the British people and the British economy would be unhappy if their energy needs were more expensive than needed but they would be far more unhappy if their energy aspirations were not met. Imagine flicking the light switch and nothing happening. A large nuclear power station can provide base load electricity day in day out no matter what the weather and is slow to be affected by any disruptions in the fuel supply. This will be valuable in a future with more dependence on imported hydrocarbons and larger amounts of wind and solar power but where storage of electricity on the scale desired to stabilise a renewables dominated grid is technically and financially out of reach.

The case is laid out for all to read. Some say the strike price is too high, some say far too high. It remains to be seen if Hinkley Point C can and will be built and whether the investors will get a decent (or maybe indecent) return on capital invested.



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.

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.