The Nuclear Free Local Authorities (NFLA) has submitted its views to the UK Government and the devolved Scottish and Welsh Governments on significant proposed changes to nuclear emergency planning arrangements in England, Scotland and Wales. (1)
The Governments have to implement the Euratom Basic Safety Standards Directive 2013, and in this area of policy need to make changes to nuclear emergency plans in order to incorporate learning points from the Fukushima disaster. (2) In transposing the Directive to UK law, the Government have acknowledged that significant change is required to the Radiation Emergency Planning and Public Information Regulations (REPPIR), and some minor change is required to the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDGs). These govern offsite emergency plans at fixed nuclear sites and the transport of radioactive materials.
Whilst the UK has decided to leave the European Union, the Government has said it will still implement the Directive as it comes into place before 2019, and it will maintain consistency with the European Union in this policy area after ‘Brexit’ has been completed.
The UK Government also see the opportunity to use the Directive to ‘strengthen’ the nuclear emergency planning regime in a number of areas:
- Moving from a prescriptive form of emergency planning to embrace ‘outcome-focused’ planning in order to concentrate on dealing with the most severe impacts of an emergency. Duty holders will be expected to demonstrate to the Office for Nuclear Regulation (ONR) how they intend to meet requirements in light of local conditions.
- The Directive encourages proportionate planning to deal with a wider area of emergencies.
- The Government plans to introduce a graded approach to emergency planning to target emergency preparedness and response to the most hazardous activities.
- Flexible planning will also be encouraged to allow local emergency planners to make pragmatic and effective decisions. For example, the Government will remove regulatory obstacles for the timely distribution by local authorities and other emergency responders of stable iodine tablets to assist the population in the event of a radiation release.
NFLA welcome the broad direction of these changes, which come from European best practice rather than internal policy development. NFLA has been concerned for many years that existing nuclear emergency planning has been too narrow in scope, and welcomes a wider approach arising from the Directive.
Other conclusions the NFLA make include:
- NFLA is disappointed that the UK Government has implemented various parts of the Directive and not consulted on it in its entirety. It has also given just a relatively short amount of time to receive responses from stakeholders to what is a very detailed consultation document.
- The considerable changes required to the existing REPPIR regulations arising from the Directive gives NFLA a sense of concern that existing regulation is not completely fit for purpose.
- NFLA is somewhat concerned that the changes will increase the burden on local authorities at a time when emergency planning units around the country have been contracting due to spending cuts. Moving the ONR from prescribing the likes of the detailed emergency planning zones to become more of an advisor and auditor needs to be considered very carefully.
- A wider concern remains around the consistency of plans around nuclear sites. REPPIR was by no means perfect, but it did create some level of standardisation and generic planning. Whilst there are distinct advantages to outcome planning, proportional planning and graded planning, they are significant and considerable changes to the current norm that require significant training and preparation for.
- NFLA would like to see some guarantees for a follow-up consultation on the final edition of a Code of Practice that will embed the new arrangements.
- In terms of nuclear material transportation, NFLA would like to see a more pro-active educational planning process for all local authority emergency planning units, to be added to the reactive manner of the current guidelines.
- NFLA would like to see the Ministry of Defence not just fully implement new regulations in the same manner as for civil sites and transports, but to be much more open and transparent about it.
- In the area of nuclear weapon convoys, NFLA argue the Ministry of Defence need to bring local authorities, fire and ambulance services more closely into the planning process.
NFLA also include detailed annexes in its response which outline its long-standing concerns over REPPIR, recommendations from Fukushima community groups on the emergency planning learning points from that disaster, and detailed points on pre-distribution of stable iodine tablets by Dr Ian Fairlie, which the NFLA fully agrees with.
NFLA Chair Councillor Ernie Galsworthy said:
“The NFLA broadly welcomes the transposition of the Euratom Basic Safety Standards Directive into UK law. Nuclear emergency planning has been too narrow in its existing form and has been ripe for change to bring it to European norms. While the Government is proposing a number of welcome changes NFLA remains concerned on the additional burden it will place on local authorities. The change in the role of the nuclear regulator also needs to be carefully considered. More resources needs to be provided to local authorities and a genuine move towards increased engagement with the public should also take place. With increased numbers of nuclear transports there also needs to be a move towards more pro-active as well as reactive emergency planning. NFLA will monitor these important changes and support its member authorities as they are implemented.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 0161 234 3244.
Notes for editors:
(1) NFLA Policy Briefing 168, giving its submission on proposed changes to UK nuclear emergency planning, is attached with this media release and is on the homepage of the NFLA website http://www.nuclearpolicy.info
(2).BEIS, Revised Requirements for Radiological Protection: Emergency preparedness and response, October 2017 https://www.gov.uk/government/consultations/revised-requirements-for-radiological-protection-emergency-preparedeness-and-response