How realistic are the UK’s nuclear emergency plans?

In the wake of the Fukushima nuclear disaster in March 2011, awareness about the need to swiftly and safely evacuate a potentially large number of people from around a stricken nuclear power plant has been dramatically heightened. In Japan, the evacuation area for local citizens was quickly extended as the seriousness of the emergency became more apparent and required a 20 km radius to define the evacuation area on the questionable assumption that removing people to such a distance would  protect  them from the effects of exposure to radiation.  The USA required its own nationals in the area to remove themselves to an 80 km distance due to uncertainties about the level of radiation exposure and the health consequences of that exposure.  

Despite three years of deliberations based on an evaluation of the Fukushima event,  it remains unclear whether current arrangements in the UK can protect the public in the event of a low probability/high consequence nuclear accident or deliberate release of radioactivity as might result from a terrorist attack.  The dilemma the  authorities face is this:  the more extensive the potential evacuation zone, the more prepared a larger number of people will be, and therefore the less chaotic will be any evacuation, but is it in the interests of the nuclear industry or a government determined to foist a nuclear renaissance on the UK to alert tens of thousands of people to the possible need to evacuate their homes, possibly never to return?  Why court the antipathy of those living in sublime ignorance of their potential fate in the wake of a Fukushima scale accident when the event which could cause them to be uprooted is 'highly unlikely', as was Winsdcale in 1957, Three Mile Island, Chernobyl and Fukushima? Consequently, the principle adopted has thus far been to keep the immediate evacuation zone as small as is acceptable to the local population and, only as a result of an accident which demonstrably would affect those further afield, alert and act to protect  to residents deemed to be at risk in zones where radiation is expected to exceed safety limits.  

Nuclear facilities in the UK are normally situated in remote areas due to the dangerous nature of the technology and the need, in the case of nuclear power plants, for cooling water which is generally taken from the sea.  Their remote locations mean that the sites are generally badly serviced by transport infrastructure.  An evacuation of any reasonable scale would be difficult to conduct without panic, chaos and general pandemonium breaking out along narrow and often single track roads which characterise rural areas.  Many observers contend that any evacuation beyond a few dozen people is simply impossible and despite all the reassurances given by local authorities to the contrary, many people living around nuclear facilities live in fear of the day when the emergency plan is tested for real.

In addition to these inadequacies, the process by which the size of the evacuation zone is determined is itself opaque and deeply flawed.  It relies upon the nuclear operator setting out to the Office of Nuclear Regulation (ONR) what it considers to be its 'worst reasonably foreseeable nuclear incident', a scenario which the ONR then evaluates.  If ONR agrees with the operator's assessment, it will make a 'determination' on the size of the area within which the local authority must prepare an offsite emergency plan – the offsite planning area  Despite the fact that Sizewell B power station has over 300 tonnes of spent fuel on site, Sizewell's operator argues that the worst foreseeable accident would be trivial.  The ONR agrees and has set the radius of the offsite evacuation zone at 1 km – just 600 yards and much smaller than the 20 km Fukushima evacuation zone.  This covers an area in which just 23 individuals live.  

So the ability for any evacuation involving anything above those living in a single street or two would seem to be highly problematic, if not impossible, to accomplish and the accident prediction on which the emergency plans are predicated would appear to be entirely unrealistic.  But how do these failings impact the ability of the authorities to comply with the law?

Emergency planning for a radiation incident is covered by the Radiation (Emergency Preparedness and Public Information) Regulations 2001, usually known as REPPIR.  REPPIR requires local authorities which cover nuclear sites to prepare an off-site emergency plan if there is the possibility of an off-site release of radioactivity, and is now due for  review by the government.    Such a review is long overdue, but it is difficult to see where the government can go if it wishes to retain its 'keep the emergency planning area small' approach.

In addition, many current nuclear emergency plans appear to be in breach of section 14 of REPPIR, which requires the blue light services to identify specially trained and equipped personnel who would be made available in the event of an emergency and who are registered to be exposed to higher than authorised levels of radiation as are likely to be found in an accident.  There is little evidence from investigations in the Sizewell case that the emergency services have adequate numbers of section 14 registered personnel to deal with a serious incident, and local campaigners are actively considering a legal challenge to the ONR and local authorities on these grounds and other issues of non-compliance.  

The matter may be taken out of the hands of the UK authorities.  A joint report by the Heads of European Radiological Competent Authorities (HERCA) and the West European Nuclear Regulators Association (WENRA) called  'A New European Approach for cross-border Emergency Preparedness' makes for uncomfortable reading for the UK nuclear industry, the government, local authorities and for the regulators.  It states:

 

According to the current studies and international standards and methods used for EP&R, an accident comparable to Fukushima would require protective actions such as evacuation up to 20 km and sheltering up to 100 km. These actions would be combined with the intake of stable iodine. In this framework the national nuclear and radiation safety regulators propose a methodology for a common European approach allowing to recommend urgent protective actions as well as a minimum common level of preparation for these actions:
 
evacuation should be prepared up to 5 km around nuclear power plants, and sheltering and iodine thyroid blocking (ITB) up to 20 km;
 
a general strategy should be defined in order to be able to extend evacuation up to 20 km,
and sheltering and ITB up to 100 km;
 
nuclear and radiation safety authorities in Europe should continue attempts to promote compatible response arrangements and protection strategies amongst the European countries. The need for rapid decisions using the simplified schemes for protective actions will only apply during an initial phase. As soon as the accident country is in a position to present a more elaborate assessment of the plant status and the expected off-site impact, it will take the necessary steps to align its decisions and cross-border coordination mechanisms accordingly.

 

Post-Fukushima improvements and precautionary upgrades to nuclear facilities are still being implemented today and are far from complete.   If there is one lesson emerging from that awful tragedy it is that every nation which misguidedly follows a nuclear path has to be prepared for the consequences of an unforeseeable accident or incident which can affect a large number of its own people, let alone those in other countries through trans-boundary contamination.  Playing with the health, wellbeing, and possibly lives of thousands of people who live within the shadow of nuclear facilities in order to hide the potential impacts of the nuclear industry is not an option.   Failing to put in place workable, demonstrably effective and operationally feasible emergency evacuation plans  represents a serious derogation of duty on behalf of the authorities in whom we have to place our trust to protect us in emergency situations.   Those  tens of thousands of Japanese people who have been required to leave their homes for years on end  – some never able to return – send us a warning we must not ignore lest their nightmare be repeated.

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