Contingency Planning for Marine Pollution – Revised Guidance

thumbnail_OPRC_Guidelines_for_Ports_-_final_Sep_16This new guidance, from the Maritime and Coastguard Agency provides guidelines on pollution response planning for Ports. As is usual for government body advice it seems to be longer than you would have thought necessary (76 pages).

The editing is not great, a footnote on page 7 tells us that new regulation is expected in 2002.

Paragraph 2.18 is interesting to the nuclear industry “Contingency planning for events that have a very low probability of occurrence may be unjustified. The consequences would need to be extremely high to justify contingency planning for events that have a probability of occurring, say, only once every three hundred years or more”. ONR current define “reasonably foreseeable” for nuclear accidents as in the range 0f once in 100,000 to a million years.

The role of the Secretary of State’s Representative (SOSREP) is interesting. According to the National Contingency Plan for Marine Pollution The SOSREP is empowered to make crucial and often time-critical decisions, without delay and without recourse to higher authority, where such decisions are in the overriding United Kingdom public interest”. I’m not sure there is an equivalent in nuclear emergency planning. The GTA role provided “Authoritative Advice” but has been discontinued. The Gold or Strategic Coordinator merely “coordinates”.  It is interesting to consider whether such a clearly empowered role would be useful.

Approved plans are valid for 5 years compared to 3 for REPPIR. Another penalty paid by the nuclear industry for “nuclear dread”?



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