This is to improve the effectiveness of the consultation and to avoid potential confusion of the public.
There has been regional media coverage on this issue. To help clarify the reasons for our recommendation, here’s the letter we sent on 6 August 2012 to the head of the Suffolk Joint Emergency Planning Unit.
Subject: Sizewell A and B Power Stations Emergency Preparedness and Response
Radiation (Emergency Preparedness and Public Information) Regulations 2001
Thank you for the recent meeting at Endeavour House, Ipswich, held on the 30 July 2012, with myself and my colleague Paul Smith. The meeting proved to be very useful in terms of discussing the way forward with respect to your forthcoming and welcome public consultation upon emergency preparedness and response associated with the Sizewell nuclear licensed sites.
The Office for Nuclear Regulation is responsible for ensuring local authorities have plans in place to deal with the off-site consequences of nuclear emergencies. We understand that Suffolk County Council has stated its intent to review its Sizewell plan by the end of April 2013.
To improve the effectiveness of the consultation and to avoid potential confusion of the public, we recommended rescheduling the consultation process until more clarity has been achieved in respect of the four issues below, which are still in progress:
- ONR is currently reviewing, as it is routinely required to do on a regular basis, the risk evaluation for Sizewell and will use the findings to consider whether the detailed emergency planning zone for Sizewell (currently 2.4km) remains appropriate. Our assessment is ongoing.
- There is an ongoing review, co-ordinated by UK Government (the Department of Energy and Climate Change), of ‘Consolidated Guidance’ – the accepted national-level guidance provided to all organisations required to have plans in place for dealing with nuclear emergency in the UK. This review will cover ‘extendibility’ – which will have particular relevance to your public consultation and should provide clarity for local authorities and multi agencies in their planning.
- The regulations that legally require you to plan for a radiation emergency – the Radiation (Emergency Preparedness and Public Information) Regulations – are based on BSS 96/29 and a review of this basic safety standard, led by the Health and Safety Executive, is ongoing.
- An extraordinary meeting of the Convention on Nuclear Safety, co-ordinated by the United Nations’ International Atomic Energy Agency, will be held in late August to gather international learning from the accident at Fukushima Dai-ichi. This is expected to inform and shape UK nuclear emergency planning basis – aligning the UK to relevant international good practice.
ONR will of course keep you fully informed of any relevant developments in this topic area as relevant information becomes available.
I thought it may help if I explained some of the terminology used in my letter and have provided some text to this end as an annex.
Mr Paul Dicks HM Inspector
Detailed Emergency Planning Zone, REPPIR and BSS 96/29
Where there is a potential for off-site release of radioactivity within the UK that would require implementation of countermeasures, detailed emergency planning zones (DEPZ) are designated. The Office for Nuclear Regulation determines the size of DEPZ in the UK. They are defined based on the most significant release of radioactive material or radiation from an accident that can be reasonably foreseen. The size of DEPZ differs site by site in the UK, with due consideration given to individual factors associated with each site. The DEPZ for Sizewell is currently 2.4km. Under Radiation (Emergency Preparedness and Public Information) Regulations 2001 – also known by the acronym REPPIR – the local authority has a legal duty to produce an off-site emergency plan. In this case, the duty falls to Suffolk County Council. REPPIR is founded on the principles of BSS 96/29. This is a European directive. BSS stands for ‘basic safety standard’ and, in this case, sets a uniform basic safety standard to protect the health of workers and the general public against the dangers arising from ionizing radiation.
The REPPIR guidance notes that radiation emergencies could have consequences beyond the boundaries of DEPZ. This could be for a number of reasons – for example, the weather conditions at the time of the incident. Planning for such eventualities is incorporated within REPPIR and is known as ‘extendibility’. The Department of Energy and Climate Change (DECC), the lead government department for civil nuclear security and safety, chairs a Nuclear Emergency Planning and Liaison Group (NEPLG), which brings together various organisations, including local authorities, who would be involved in the response to a nuclear emergency in the UK. This group has an established ‘Consolidated Guidance’ aimed at those involved in preparing plans, at the local level, for dealing with nuclear emergency. This guidance is currently being reviewed. It includes a chapter which deals with extendibility.