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.

Author: Keith Pearce

Emergency Planning and Health Physics consultant and author

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