Radiation Emergency Preparedness, Resilience and Response (EPRR)

Question 1

Who published the Security Requirements for Radioactive Sources document?

Answer 1

National Counter Terrorism Security Office (NaCTSO).

Question 2

What are the source holding categories 1-5? How is the security category determined for multiple source holdings?

Answer 2

• Category 1: Most dangerous (e.g. HASS sources for medical teletherapy and gamma knife).
• Category 2: e.g. industrial radiography sources and high/medium dose rate brachytherapy sources.
• Category 3/4: e.g. density moisture gauges and low dose rate brachytherapy sources.
• Category 5: Any practice using a radioactive material with an A/D value < 0.01 (excluding categories 1-4) where A is source activity and D is the activity at which the source becomes dangerous.
• For multiple source holdings, the overall holdings category is determined by adding the A/D values for each source.

Question 3

What are the radioactive source security levels and what do they depend on? What additional security measures are required at the more secure levels?

Answer 3

• The radioactive source security levels depend on the source category.
• Level D: The minimum security level which tends to apply to category 5 sources. No specific requirements apart from those imposed by IRR17 and EPR2016 (e.g. duty to exercise contingency plans).
• Levels A-C: Apply to HASS sources or other sources that are deemed to be equally hazardous.
• Additional security measures include:
  
  • Security culture, awareness of the threat and the need to deter, detect and delay.
  • Site security plan.
  • Extendability of security measures dependent on the terrorist threat level.
  • Information security plan.
  • Personnel background checks.
  • Specified number of physical security measures to deter and delay.
  • Monitored intruder alarm for timely detection of unauthorised access.
  • Timely police response to alarm.
  • Close personnel supervision and communication links for mobile sources.

Question 4

List some of the IRR17 regulations relevant to security and emergency preparedness.

Answer 4

• Radiation risk assessment (emergency response).
• Restriction of exposure.
• PPE.
• Maintenance and examination of engineering controls and PPE.
• Dose limitation.
• Contingency plans with rehearsal at suitable intervals.
• Information, instruction and training.
• Additional requirements for designated areas (measures for the prevention of contamination).
• Sealed sources and articles containing radioactive substances (leak tests etc.).
• Accounting for radioactive substances.
• Keeping and moving of radioactive sources.
• Notification of certain occurrences (sources releases, significant contamination, lost or stolen sources, investigations).
• Misuse or interference with sources of ionising radiation.
• Duties of employees.
• Defence of contravention.

Question 5

What do the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR2019) cover?

Answer 5

They establish a framework of emergency preparedness measures to ensure that employees and members of the public are:
- Informed and prepared about what to do in the event of a radiation emergency (i.e. a non-routine event likely to result in a member of the public receiving a dose of greater than or equal to 1 mSv during the year immediately following the emergency) occurring as a consequence of work with radioactive materials.
- Provided with information in a radiation emergency.

Question 6

When should a major incident be declared in healthcare?

Answer 6

A major incident should be declared if special arrangements are required. So, all radiation incidents in which specialist radiation assistance is sought is considered a major incident (even if not a radiation emergency in the context of REPPIR2019).

Question 7

Which IRR17 regulations dovetail with REPPIR2019? How do REPPIR2019 ‘radiation emergencies’ relate to IRR17 ‘radiation accidents’?

Answer 7

• Radiation risk assessment and emergency response.
• Dose assessment and dose recording.
• Dosimetery for accidents (or emergencies) and medical surveillance.
• IRR17 radiation accidents are any accident where immediate action is required to prevent/reduce exposure. REPPIR2019 radiation emergencies are a subset of this relating to accidents with serious consequences.

Question 8

What is the overarching act/framework covering general civil emergency preparedness and response? What other major hazard regulations does REPPIR2019 dovetail with?

Answer 8

• The Civil Contingencies Act (CCA).
• The Control of Major Hazards Regulations (COMAH).
• The Pipelines Safety Regulations 1996.

Question 9

Who has legal duties under REPPIR2019 regulations?

Answer 9

• Operators of premises where work with ionising radiation is carried out where there is potential for a radiation emergency that could impart and effective dose of 1 mSv or greater to a member of the public in the year following.
• Transporters transporting radioactive materials through a public place via pipelines etc. rather than by road etc.
• All local authorities are responsible for off-site emergency response or other radiation emergencies within their boundaries.
• Employers of people who intervene in a radiation emergency (e.g. blue light services).
• All of the above must cooperate with each other under REPPIR2019.

Question 10

How does an operator who works with radioactive material decide if REPPIR2019 regulations apply?

Answer 10

• The quantities of radionuclides (Schedule 1) or fissile materials (Schedule 2) and whether they reside within threshold quantities must be determined. For a mixture of radionuclides, the summed quantity ratio must be considered. If they reside above threshold quantities, there may be potential for a radiation emergency and so the regulations may apply (regardless of the likelihood of any emergency).
• If the employer can demonstrate that the effective dose to a member of the public in the year following a potential radiation emergency is less than 1 mSv, then the regulations do no apply.

Question 11

For which radioactive sources and packages does REPPIR2019 not apply?

Answer 11

• Radioactive source activity concentration < 100 Bq/g.
• Non-dispersible sources (i.e. a sealed source for which is is determined cannot cause a radiation emergency due to its physical and chemical form).
• Special forms of radioactive materials (i.e. meets specific test criteria for non-dispersibility).
• Radioactive sources in type B and C packaging.

Question 12

What does the risk assessment used to determine whether REPPIR19 applies to premises involve? If REPPIR19 does apply, who must this be suppled to? What events must be considered in the risk assessment?

Answer 12

• A Hazard Evaluation and Consequence Assessment Report. This involves using the REPPIR19 ‘Impact Table’ which is used to determine consequences of a radiation emergency when considering effective dose and impact descriptors (e.g. impact on human life, the environment etc.). This is used alongside the ‘Likelihood Table’ which determines the likelihood of a potential radiation emergency.
• The ‘Impact’ and ‘Likelihood’ are used to determine the level of contingency planning required (e.g. none, outline planning, detailed emergency planning, prohibition of activity).
• This must be supplied to the local authority with a propose geographical extent for detailed emergency planning (a detailed emergency planning zone).
• It must also be supplied to the regulator (i.e. HSE for non-nuclear sites and ONR for nuclear sites or similar).
• Plant/equipment failures, breakdown of administrative arrangements, human error, extreme weather/seismic activity etc. must be considered.

Question 13

Aside from the risk assessment to determine whether REPPIR19 applies, what else is the operator responsible for under REPPIR19?

Answer 13

• A site emergency plan that is tested at least every 3 years (reports should be sent to the local authority and regulator).
• Cooperating with the local authority regarding public information and an off-site plan.
• Declare a ‘radiation emergency’ and inform the local authority when to implement the off-site plan.

Question 14

What is required in a detailed emergency planning zone (DEPZ)? How is this different from an outline planning zone (OPZ)?

Answer 14

DEPZ:
- Covered in the local authorities off-site plan.
- Must be detailed.
- The extent of the DEPZ, as determined from the consequence assessment.
- Takes into account the operator’s proposal and factors specific to the local authority (e.g. bisection of a local community).
OPZ:
- If only outline planning is required, the likelihood and/or impact is significantly lower.
- An OPZ will again be covered in the local authorities off-site plan.
- Plans must only be outline.

Question 15

What responsibilities does the local authority have under REPPIR19?

Answer 15

• Must make the operator’s consequence report publicly available.
• Must determine the detailed planning zone (DPZ) taking into account the operator’s proposal and the factors specific to the local authority area.
• Must make arrangements to provide public information regarding a radiation emergency.
• Must notify emergency dose reference levels (dose limits disapply in an emergency) to the regulator.
• Must prepare an off-site emergency plan which:
  
  • Keeps doses ALARP.
  • Adopts a proportionate, graded approach (utilising the risk framework) to ensure effective response for a wide range of radiation emergencies.
  • Dovetails with the operator’s site emergency plans.
  • Covers the critical phase (first few hours) and the longer term recovery phase.
  • Includes reference levels for emergency exposures.
  • Is tested every three years or less with reports sent to the operator and regulator.

Question 16

When must the local authority provide public information in relation to a radiation emergency?

Answer 16

• Information should be provided prior to an emergency in a detailed emergency planning zone (DEPZ), where appropriate.
• Information should be be accessible prior to an emergency in an outline planning zone (OPZ).
• Additional information should be made available in an emergency.

Question 17

What is an emergency exposure under REPPIR19? Who are these permitted for?

Answer 17

A radiation dose (which may exceed IRR17 20 mSv dose limits) incurred as a consequence of an emergency worker responding in the event of a radiation emergency (e.g. to help endangered people, bring help to endangered people, prevent harm to the environment etc.).
- Only permitted for pre-identified employees who have received appropriate information and training and are properly equipped.

Question 18

What are emergency dose reference levels?

Answer 18

• Dose limits are disapplied in a radiation emergency. Reference dose levels are the doses that a member of the public or a responder might be expected to receive in the event of a radiation emergency.
• They are an emergency planning tool aimed to keep exposure ALARP.
• An emergency reference level effective dose to all persons will typically be 100 mSv. In exceptional circumstances (e.g. life saving), the reference level may be 500 mSv. As these are not dose limits, they can be exceeded if there is justification.

Question 19

What are the levels of the REPPIR19 International Nuclear Event Scale (INES)?

Answer 19

• 1: Anomaly.
• 2: Incident.
• 3: Serious incident.
• 4: Accident without significant off-site risk.
• 5: Accident with off-site risk.
• 6: Serious accident.
• 7: Major accident.

Question 20

What is the National Arrangements for Incidents Involving Radioactivity (NAIR) scheme? Who is the coordinating organisation for this scheme?

Answer 20

• Provides quick and widely available assistance to emergency services where no radiation expert is otherwise available (i.e. where no formal contingencies plans exist). Assistance is drawn from volunteers from hospitals, the nuclear industry and government departments.
• The National Institute for Health Protection (NIHP) coordinate this scheme.

Question 21

What is the the National Arrangements for Incidents Involving Radioactivity (NAIR) scheme Stage 1 response? What is a Stage 1 responder not expected to do?

Answer 21

• Acquire local radiation expert assistance. The volunteer will receive a call with relevant information from the Civil Nuclear Constabulary.
• They will be provided with the contact details of the individual dealing with the incident at the scene.
• The radiation expert is typically expected to attend the scene with monitoring equipment to ascertain if a hazard actually exists.
• They will provide technical and radiation safety advice to manage the immediate incident and prevent the situation from deteriorating.
• Advise on Stage 2 response, if required.
• Provide radiological information regarding the incident to (NIHP).
• Stage 1 responders are not expected to carry out large scale decontamination, organise substantial recovery operations or respond to known or suspected terrorism incidents.

Question 22

What is the the National Arrangements for Incidents Involving Radioactivity (NAIR) scheme Stage 2 response?

Answer 22

• Stage 2 assistance normally comes from the nuclear establishment.
• They will provide more sophisticated resources (e.g. transport, monitoring and decontamination equipment and special clothing) for handling the incident.

Question 23

What are some likely National Arrangements for Incidents Involving Radioactivity (NAIR) scheme Stage 1 incidents?

Answer 23

• Transport incidents in which normal response arrangements have failed or been delayed and there is a perceived immediate danger to the public.
• Lost or damaged source.
• Empty radioactive package.
• Potential terrorist incident (but not a confirmed terrorist incident).

Question 24

What should National Arrangements for Incidents Involving Radioactivity (NAIR) scheme Stage 1 responders be aware of to help with their response?

Answer 24

• Common radioactive source appearances.
• Understanding of radioactive packaging for transport by road and how to use information in the documentation (e.g. surface dose rates) to determine if measured dose rates are as expected.

Question 25

What policy change came about in relation to emergency response due to the increase in terrorist threat?

Answer 25

Emergency responder radiation monitoring (i.e. electronic personal dosimeters, or EPDs) were made more widely available.

Question 26

Which act defines Emergency Preparedness, Resilience and Response (EPRR) as a series of statutory responsibilities? What does this require of NHS funded organisations? Who is responsible for the overall leadership of planning and response?

Answer 26

• The Civil contingencies act.
• Requires NHS funded organisations to maintain robust capability (not capacity as this would be costly) to plan for and respond to incidents or emergencies that could impact on health or services to patients.
• NHS Commissioning Board Area Teams are responsible for the overall leadership of planing and response.

Question 27

What are Hazardous Area Response Teams (HART)?

Answer 27

They are a special branch of the ambulance services providing health response in support of the national capabilities program led by the Home Office. They consists of specially recruited and trained personnel. They would work within the ‘hot zone’ of a major radiological incident.

Question 28

What must the plans hospitals with A&E departments have to deal with potentially contaminated/irradiated casualties include?

Answer 28

• Use of RamGENE monitors provided to all A&E departments by the Department of Health.
• Treatment of life-threatening injuries should take priority over decontamination or monitoring.
• Radiation hazards and risks.
• Control measures (prevention of spread of contamination).
• Radiation monitoring.
• Decontamination.
• Access to specialist support (e.g. medical physics).
• Establishing of Radiation Monitoring Units (RMU).

Question 29

What is a Radiation Monitoring Unit (RMU)? What do they do? Who must contribute?

Answer 29

• They are planned emergency units to be established after appropriate radiation incidents to undertake internal/external radiation monitoring of the public, provide decontamination and provide advice or reassurance where appropriate.
• They are located (fixed or temporary) to prevent NHS emergency departments from being overwhelmed.
• They supply information for radiation dose assessments.
• All trusts must contribute to the establishment of RMUs.

Question 30

What will the early response (within first 6 hours of incident) of a Radiation Monitoring Unit (RMU) typically involve (ordered chronologically from arrival)?

Answer 30

• Public holding area and triage stage 1 monitoring. This is undertaken with handheld monitors at ~ 30 cm. Portal walkthrough monitors may be used after 6 hours. This will help find any grossly contaminated monitee for isolation from the crowd and fast-tracking to a decontamination unit (i.e. from a special operation response team SORT).
• If gross contamination found, decontamination takes place and monitee sent to stage 2 monitoring after.
• Other monitees will join a queue for stage 2/3 monitoring after stage 1 monitoring confirms no significant contamination.
• Stage 2 monitoring involves a detailed external monitoring check using a handheld monitor at ~ 5 cm.
• If additional contamination is found at stage 2 the monitee will be sent back to the decontamination unit. They will only be sent back up to two times as, if additional contamination is found, it is likely it is internal contamination.
• Stage 3 monitoring is an attempt to look for internal contamination (e.g. thyroid monitoring). This is not always possible and depends on the nature of the incident.
• Contamination free and decontaminated monitees are then sent to the survivor reception centre.

Question 31

How will the later response (by 24 hours of the incident) of a Radiation Monitoring Unit (RMU) be different from the early response (with first 6 hours)?

Answer 31

• By 24 hours, it is unlikely that any superficial contamination will be present. Attendees will likely have washed and changed and, therefore, any contamination would be internal.
• The RMU is likely to be bigger and more well developed.

Question 32

List some of the roles that would be apparent in a Radiation Monitoring Unit (RMU).

Answer 32

• RMU manager.
• Facilities manager.
• Radiation Protection Manager (advises on radiation protection measures).
• Radiation Protection Officer.
• Personal Monitoring Team Leaders.
• Personal Monitoring Team Members.
• Public Liaison Team.
• Record Keeping and Admin Team.
• Decontamination Team.
• Security Team.
• Media Manager/Press Officer.
• Dispersal Team at the survivor reception centre to deal with members of the public needing help and support.

Question 33

How often must emergency preparedness exercises be rehearsed?

Answer 33

At least every 3 years.