OG Status:

Fully open

Approved by:

R C Gray

Issue #:

1

• 1  Purpose and Scope
• 2  Licence Condition
• 3  Purpose and Guidance on Arrangements for the sub-conditions
• 4  Guidance on Inspection of Implementation
• Glossary
• Appendix 1: Introduction to Exercises
• Appendix 2:  Aide memoire for inspectors for Level 1 emergency exercise evaluation

• Annex 1:  Detailed Supporting Guidance

1  Purpose and Scope

1.1  The purpose of this guidance is to facilitate compliance inspection (site licence arrangements and demonstration emergency exercises) for LC 11. It is intended to promote a consistent approach to the inspection / assessment of emergency arrangements and exercises appropriate to the IRR99 and on-site REPPIR expectations.  Within this document it is not possible (or desirable) to address every possible situation that will arise during compliance inspection.  This guidance is not therefore mandatory but provides a framework for Inspectors who will also need to use judgment and discretion during such inspections.

1.2  This guidance does not indicate the frequency or depth of the compliance inspections.  The intervention strategy / programme will cover these matters.

1.3  This guidance considers each sub condition that is specific to emergency arrangements, identifies its purpose and then indicates the key considerations, which would be expected to be in the licensee’s arrangement.  Guidance on the inspection of the implementation arrangements follows.  A glossary is provided for the terms and abbreviations highlighted in bold text that are used in this guidance.

1.4  Appendix 1 provides guidance to new inspectors on the purpose of demonstration exercises, gives advice on agreeing the scenario and on carrying out inspections.

1.5  Experienced inspectors are referred to Appendix 2 that presents an aide memoire / check list of some of the key attributes for each emergency response activity.  This appendix may benefit new inspectors when it is read in conjunction with the supplementary supporting guidance, ‘Emergency Arrangements – Control Centres and Activities’, Annex 1.

2  Licence Condition

Licence condition 11: emergency arrangements

LC 11(1): Without prejudice to any other requirements of the conditions attached to this licence the licensee shall make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.

LC11(2): The licensee shall submit to the Executive for approval such part or parts of the aforesaid arrangements as the Executive may specify.

LC11(3): The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless the Executive has approved such alteration or amendment.

LC 11( 4): Where any such arrangements require the assistance or co-operation of, or render it necessary or expedient to make use of the services of any person, local authority or other body the licensee shall ensure that each person, local authority or other body is consulted in the making of such arrangements.

LC 11(5): The licensee shall ensure that such arrangements are rehearsed at such intervals and at such times and to such extent as the Executive may specify or, where the Executive has not so specified, as the licensee considers necessary.

LC 11(6): The licensee shall ensure that such arrangements include procedures to ensure that all persons in his employ who have duties in connection with such arrangements are properly instructed in the performance of the same, in the use of the equipment required and the precautions to be observed in connection therewith.

3  Purpose and Guidance on Arrangements for the sub-conditions

3.1  LC 11(1): ‘Without prejudice to any other requirements of the conditions attached to this licence the licensee shall make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.’

Purpose

3.1.1  This is the key sub-condition which is aimed at ensuring a licensee has adequate arrangements in place to respond effectively to any incident ranging from a minor on-site event to a major release off-site of radioactive material.  From a legal stand point adequate arrangements will need to be sufficiently detailed to cope with the occurrences referred to in section 7 of the NI Act and Regulation 7 of REPPIR. 

3.1.2  Paraphrasing NI Act Section 7, the licensee has to ensure that occurrences involving nuclear matter do not cause injury to any person or damage to any property, the injury or damage arising from radioactive properties or a combination of radioactive properties and any toxic, explosive or other hazardous  properties; and that ionising radiations do not cause injury to any person or damage to property of any person other than the licensee.

3.1.3  The REPPIR Reg 7 requirement is that the operator is required to prepare an emergency plan ‘designed to secure, so far as is reasonably practicable, the restriction of exposure to ionising radiation and the health and safety of persons who may be affected by such reasonably foreseeable emergencies as are identified in the said assessment.’

Guidance on arrangements

3.1.4  The ‘arrangements’ which address this sub-condition usually require a high level Emergency Plan (and supporting suite of documents detailing how it is carried into effect) to be prepared and kept under regular review.  The review intervals should be based either on a given time interval, or in the event of a significant change in the site status, risk levels, hazards, etc.  The plan – which is the key element of the arrangements - will require (usually dedicated) facilities on site for its implementation and trained staff to deliver its requirements.  REPPIR schedule 7 provides some detail of what is expected by the Regulations in the plan.  The following paragraphs look more generally at what should be included.

3.1.5  The plan should identify the types of possible incidents on the site and describe a strategy, system and response structure for dealing with them.  It would be expected to be based on a range of potential accidents - from those which are considered reasonably foreseeable to those which the safety case suggests are severe accidents for the site in question.  It should also consider the requirements of ‘extendability’, indicating how this would be addressed if a much larger (unforeseen) event was to occur.

3.1.6  The emergency plan should define the licensee’s strategy for dealing with these incidents, describe the site’s emergency response organisation and its deployment, identify facilities and equipment available for handling the emergency, and describe the arrangements for instruction, training and rehearsals. It would be expected that the plan will provide a classification system for the different levels of severity of emergency, providing criteria for the declaration of severity level.  Depending on the severity it should identify the key roles within the emergency organisation and their associated levels of responsibility and authority. The plan should also describe the roles of, and interfaces with, the organisations with whom the licensee has collaborated in drawing up the plan (e.g. emergency services, local authorities and enforcement agencies). The detailed information underpinning the emergency plan should be given in supporting documentation

3.1.7  When it is possible to foresee an accident that might affect the public off-site, the plan should describe the provisions for an off-site response and interventions to protect members of the public.  It should identify a detailed emergency planning zone (DEPZ) within which appropriate countermeasures are to be implemented, and describe the arrangements that are in place for environmental monitoring of the area surrounding the site.  It should also describe the notification process by which relevant off-site organisations, e.g. Local Authorities, police, fire, ambulance, regulators, etc, are made aware of the potential for an off-site impact.

3.1.8  The arrangements should ensure that, for persons living or working within or near the DEPZ, information about the plan and about any accident that affects them is made available in accordance with the requirements of Regulation 16 of REPPIR.

3.1.9  The licensee’s arrangements should not be limited solely to nuclear aspects.  They should integrate responses to emergencies arising from conventional hazards on nuclear sites (especially on sites which are also COMAH sites), and the handling of environmental events on the licensed site.

3.2  LC11(2): The licensee shall submit to the Executive for approval such part or parts of the aforesaid arrangements as the Executive may specify; and

LC11(3): The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless the Executive has approved such alteration of amendment.

Purpose

3.2.1 These are standard subconditions allowing HSE, having identified key document(s), to call in and freeze (by approval) the contents of the document(s).  Approval is normally applied once the document has undergone technical assessment and HSE is satisfied with the contents.  Once Approved the licensee can no longer modify the document without HSE’s permission.

Guidance on arrangements

3.2.2  In the Emergency Arrangements area, the licensee’s high level plan is usually Approved and the arrangements for controlling this document should recognise this special status.  The Licensee should have in place procedures for recognising when change is required - and HSE’s role in Approving such changes.  Lower level documentation can be changed without HSE’s involvement and the arrangements should ensure that the totality of the lower level changes do not affect the validity of the Approved plan.  Modifications to emergency arrangement documentation should follow similar processes to modifications required under LC 22.

3.3 LC 11(4): Where any such arrangements require the assistance or co-operation of, or render it necessary or expedient to make use of the services of any person, local authority or other body the licensee shall ensure that each person, local authority or other body is consulted in the making of such arrangements.

Purpose

3.3.1 This sub-condition is aimed at ensuring that when the on-site emergency plan is drawn up, the licensee consults those agencies which will be required to provide support for the licensee’s emergency response.  This will ensure that they will be aware of (and agree to) the duties which the licensee expects them to undertake on its behalf. 

Guidance on arrangements

3.3.2  The arrangements should identify (list) all likely on- or off-site organisations from whom the licensee will – or could - require support in order to be able to handle an on-site emergency.  The emergency services – fire, ambulance, police – will clearly be required and, for an event with off-site impact, the Local Authority (LA) will require to mobilise its resources to handle evacuees, support an off-site strategic centre, etc, etc.  The arrangements should recognise duties placed by REPPIR on the LA to generate an off-site plan, and should describe how the licensee’s role and organisation integrates into the off-site plan requirements.  The arrangements should also recognise the interactions with the range of regulators, government departments, hospital trusts, etc who could be involved in a major off-site incident.  The interactions, functions and roles of all these supporting organisations should be described in the supporting documentation. 

3.3.3  The arrangements should address the situation where there is more than one commercial enterprise (and possibility more than one licensee) embedded on the site.  The interactions between the on-site enclaves, the duties that each lays on the other, and the agreed command and control structure integrating the whole site emergency response should also be described in the arrangements.  Likewise, where there are large industrial sites close to the licensed site, COMAH requires that there should be a handshake between the two sets of emergency arrangements.  The arrangements should identify and respond to this requirement.

3.3.4  The arrangements should require routine consultation across a wide range of organisations and the general public.  It would be expected that the arrangements detail formal forums for the appropriate initial and continuing consultation with the local community, emergency services and other persons with roles under the approved plan.  Examples of such forums are the Local Liaison Committee (LLC), the Emergency Planning Consultative Committees (EPCC), or the local resilience committee established under the Civil Contingencies Act.  While the resilience committee will provide an overarching forum at which the full range of potential problems are discussed, the LLC and (especially) the EPCC provide forums that can address specifically nuclear issues. It should be noted that HSE participates in the local resilience committee and has observer status on the other committees.

3.4 LC 11(5): The licensee shall ensure that such arrangements are rehearsed at such intervals and at such times and to such extent as the Executive may specify or, where the Executive has not so specified, as the licensee considers necessary.

Purpose

3.4.1  The aim of this sub-condition is to ensure that the roles and actions required to handle an emergency are practiced on a regular basis.  In part, this is to ensure that those responding are so well trained that the experience and training takes over and allows the required response to be achieved in what could be very adverse conditions. 

Guidance on arrangements

3.4.2  Usually as part of the site training programme, the emergency arrangements should ensure that a programme of rehearsals is generated that covers all aspects of the emergency handling task.  The programme should normally be based on one year for an operational site, providing a refresher on all important aspects over the year.  Clearly response to actual on-site events can be counted as part of this training.

3.4.3  The emergency response can be broken down into simpler subtasks (often based on the Nuclear Emergency Planning Liaison Group (NEPLG) matrix of emergency exercise activities) which can be rehearsed in isolation, but these should be brought together in a series of steadily more complex interactions.  Ultimately these should culminate in a series of full site wide (often shift based) training exercises.  The arrangements should identify the objectives for the various rehearsals e.g. to establish that each emergency handling team on the site is competent to handle any emergency that will arise on the site, even if it has significant implications off-site as well.  Note that one of these ‘overall’ rehearsals will be chosen as a demonstration to be witnessed by NII.  Guidance on the inspection/ evaluation of a Level 1 demonstration exercise (as part of the inspection of the implementation of the arrangements) is given below.

3.4.4  Although this aspect may be covered under the arrangements for other licence conditions, the licensee’s arrangements should recognise and have procedures for the possibility that NII does specify rehearsal requirements.  This would not normally be expected but is an option under the License, e.g. a specific exercise as part of a readiness demonstration.  The arrangements need to ensure the mandatory nature of the specification is recognised by the appropriate level of licensee management.  Basically the arrangements should ensure the site management is well aware of the commitment and its legal basis.

3.4.5  The arrangements should address the feedback from the rehearsals and demonstration exercises.  Lessons learned should influence the rehearsal programme and content - as well as the adequacy of the facilities.  Where it is clear that improvements in facilities are required to produce improvements in performance (or to keep up with modern practice) the arrangements should signpost (or provide) a process to ensure these changes are made to the facilities in a timely fashion.  By similar method, the arrangements should also address the routine maintenance of the facilities and equipment.  Facilities and equipment must always be in a satisfactory condition to be used at a moments notice – either for rehearsal or response to a real event.

3.5  LC 11(6): The licensee shall ensure that such arrangements include procedures to ensure that all persons in his employ who have duties in connection with such arrangements are properly instructed in the performance of the same, in the use of the equipment required and the precautions to be observed in connection therewith.

Purpose

3.5.1  The aim of this sub-condition is to ensure the licensee has available at all times staff that are properly selected and trained (i.e. they are SQEP) to discharge their emergency roles, and that those staff are familiar with the equipment and procedures they may have to use/ implement. 

Guidance on arrangements

3.5.2  The arrangements under this sub-condition interface closely with those produced for other LCs, e.g. LC 10, 12 & 26.  The arrangements should ensure that an annual refresher/ induction training programme covers the full range of necessary skills and competences, takes into consideration learning points generated from rehearsals, and is designed to keep emergency staff current at all times.  It is possible that the NEPLG matrix of exercise activities – or some other formal recognition of the multiple interacting skills/ tasks needed - could be used to ensure all aspects are captured.

3.5.3  The arrangements would be expected to include criteria against which the competence of staff can be judged, acceptable timescales between refresher training, and identify (or signpost) processes to keep track of the emergency training position for each individual.  This will enable the licensee to demonstrate that relevant staff are currently SQEP for the roles they are identified to discharge.  The arrangements should generate – or require to be generated - training packages to equip staff with the necessary initial competences as well as refresher/ familiarisation training to maintain currency.  The arrangements should allow for new developments to be integrated into the overall training package to ensure staff can always respond to an emergency.

3.5.4  The arrangements should also ensure that the requirement to staff the demonstration exercise rotates such that, over a period of time, NII has the opportunity to see every emergency team in operation.

4  Guidance on Inspection of Implementation

4.1  Arrangements

4.1.1  Inspection of the implementation of arrangements looks, inter alia,  for the topics identified under the guidance on arrangements given above. It will involve an inspection of the licensee’s emergency arrangements structures and documentation.  An appreciation of good practice in such areas is essential for effective inspection such that the inspector needs to be aware of practice on more than one site and, preferably, more than one licensee.  Assistance from the Emergency Arrangements team can augment the knowledge of best practice in this area. 

4.1.2  It is usual to undertake a broad overview and then sample in more detail selected areas of the arrangements.  For an individual site inspector  it will be necessary to develop an overall plan of inspection in this area so that specific areas or groups of areas can be checked over time without overlooking any key areas.  If weaknesses are found in any one area, care is required not to concentrate on the rectification of these weaknesses at the expense of continuing to examine the wider picture.

4.1.3  As well as the overall documentation structure and content, examples of broad topics could be the integration of nuclear, conventional and environmental response; the evidence of commitment of the senior management to the emergency organisation, its budget, its delivery of the licensee’s continuous improvement programme etc; the interface and interaction between on and off-site responses/ responding organisations; the ability to learn from/ respond to issues arising in the emergency training programme both on- and off-site, etc.

4.1.4  In addition it will be necessary to focus on the detail of particular aspects.  Examples of these narrower considerations might be a thorough review of the emergency plan and the overall strategy that has been adopted (assistance from the Emergency Arrangements team would allow a wider perspective to be included); looking at the joining up of people/ procedures/ facilities in the emergency response organisation; checking the equipment and facilities provided (standard with respect to good practice/ maintenance records); reviewing the training of individuals and teams/ the quality of courses/ the state of the training programme; interactive training with off-site emergency services; etc.

4.1.5  The above are just some of the examples of topics that might be inspected.  The site inspector will need to check previous visit reports to establish what has been done before, what was found, and what corrective actions were required.  This will give an indication of ground previously covered; the inspection should be aimed at establishing previous corrective actions have been effectively implemented and also looking at new areas.  The whole of the emergency arrangements need to be reviewed over time; the time allocated to complete this will be a function of the site record in this area.  This will be informed by the site performance in the demonstration exercises as well as the results of the implementation of arrangements inspections.

4.2  Emergency Exercises

4.2.1  The evaluation of the demonstration emergency exercise is normally undertaken by a team of NII inspectors.  For an operating site an annual demonstration exercise is usual.  This exercise has its roots in the programme of rehearsals – see under guidance on LC 11(5) – undertaken as part of the internal training programme.  These exercises will range from simple Table Tops through to the full site exercise.  One of the full site exercises is chosen by NII as the demonstration exercise.  It is aimed at convincing NII that the licensee’s emergency arrangements process produces teams of people who can handle any emergency with on or off-site implications.

4.2.2  The scenario – which is usually agreed between NII and the licensee – is the key to setting the aims and objectives for the exercise.  The site inspector needs to be aware of the previous exercise history both in terms of the types of technical scenario chosen and the learning points arising from the exercises. 

4.2.3  Over time, all technical aspects of the emergency response need to be demonstrated.  The NEPLG exercise activity matrix is a useful guide when checking the aspects that have been/ need to be demonstrated.  It would be expected that the licensee would use it - or something similar of its own – to show a proposal for any particular exercise was part of, and fitted into, an overarching emergency response training plan.

4.2.4  The technical scenario needs to be a challenge to the demonstration team and so (normally) should be based on the lower probability events possible on site.  It should include an element of loss of radiological control or nuclear safety.

4.2.5  The key requirement is that the scenario ensures that sufficient elements of the emergency response plan are exercised together, so that the ability to demonstrate integrated control and management of multiple multi-element tasks is tested.  It should require the demonstration team to think – not just run through a routine set of actions.  The defence in depth available on nuclear sites is such that any real emergency is likely to be something unusual – not something that can be dealt with by turning the handle.  A matrix allows exercise elements not tested to be carried forward to successive periods.

4.2.6  The scenario should also take into consideration the learning points from previous exercises – particularly those points which come up more than once.  It should be chosen to show that the corrective actions taken have solved the problem(s) and have been implemented effectively.  Appendix 1 provides further information on selection of appropriate exercise scenarios.

4.2.7  The licensee team chosen to make the demonstration should be rotated through those available.  NII needs to able to evaluate, over time, all those available who could be called upon in a real emergency.  Continual demonstration by the ‘A’ team is not acceptable.

4.2.8  The demonstration exercise is inspected by a team of nuclear inspectors.  It is always useful to have someone with Health Physics expertise in the team and, if possible, inspectors who have hands on experience of operation of similar facilities.  Ideally it should include inspectors who are familiar with the safety case and expected actions as well as those who have experience of emergency exercise performance across a number of  sites and licensees.

4.2.9  Appendix 1 is provided for an inspector who is new to nuclear demonstration emergency exercises and as a refresher for others.  It provides a brief rationale for such inspections, some guidance on what the inspector has to do, advice on agreeing the scenario and discusses the judgements that have to be made and the possible courses of action if the overall judgement is adverse.

4.2.10  Appendix 2 is an aide memoire for the experienced inspector.  Certain general topics are dealt with separately e.g. command and control, contamination control, BA control, etc so that the respective control centre information does not contain repeated information.

4.2.11 The aide memoire may be read in conjunction with the Appendix 2 Detailed Supporting Guidance, Emergency Arrangements – Control Centres and Activities.  This provides detailed guidance on the issues that will require the attention of an inspector.  Aimed at those with only limited experience this guidance is intended to be read before the exercise.  It cannot be all inclusive but is intended to provide a new inspector with sufficient information in those areas where he/she may be unfamiliar.

Glossary

Term	Definition
LC 11 Arrangements	Refers to the totality of the LC11 arrangements and includes the responses of other organisations where these are required to secure the adequacy of the LC11 arrangements.
BA	Self Contained Breathing Apparatus.
COMAH	Control of Major Hazards Regulations 1996.
Demonstration exercise	An exercise selected from an operator’s emergency arrangements training programme that aims to convince ND that the operator’s arrangements produce teams that can manage emergencies on the site.
DEPZ	Detailed Emergency Planning Zone. HSE agrees the size of the DEPZ when it receives and assesses the underpinning safety case for the emergency plan.  This is provided under REPPIR in the form of a (HIRE) report.  REPPIR requires these reports to be resubmitted every 3 years – or a statement made that, in effect, nothing has changed.
ECC	Emergency Control Centre where the operators’ emergency controller manages the on-site response to an emergency, refer to Appendix 2 A2.1.2.
EPD	Electronic Personal Dosimeter.
HIRE	Hazard Identification and Risk Evaluation (report).
IRR99	The Ionising Radiations Regulations 1999.
LA	Local Authority.
Level 1 exercise	A demonstration exercise focusing mainly on an operators’ on-site emergency facilities and arrangements.  It may include some off-site monitoring and interface.
Level 2 / 3 exercises	Demonstration exercises that test the LA off-site and national arrangements respectively.
NEPLG	Nuclear Emergency Planning Liaison Group.  See also Civil Nuclear Emergency Planning. Consolidated guidance prepared by the Nuclear Emergency Planning Liaison Group (NEPLG consolidated guidance).
REPPIR	The Radiation (Emergency Preparedness and Public Information) Regulations 2001.
Table Top	An exercise where participants review and discuss the actions they would take per the emergency plan, but do not perform the actions.
Umpires	Exercise directing staff provided by the operator to provide scenario information and injects as required by the exercise plan.

Appendix 1: Introduction to Exercises

A1.1    Why Inspect a Demonstration Exercise?

A1.1.1  A Level 1 demonstration exercise is a single snapshot of the performance of one of the (usually several) emergency response teams that a licensee has on site.  The exercise will deal with a single scenario, possibly in only one of several facilities, on one particular day.  It is important to form a view in the context of continued readiness and the ability of the licensee to respond to a real event at any time.  An intense training period prior to a demonstration exercise is not the preferred approach.

A1.1.2  To answer the question it is necessary to recognise that the site inspector will, as matter of routine, be keeping a watching brief on the licensee’s annual emergency preparedness training programme.  This will generate a programme of internal exercises/ rehearsals/ demonstrations that the licensee undertakes to allow it to assess its overall state of competence and capability.  Taking an NII team – with wide ranging experience – to site enables NII to subject the demonstration to an in depth inspection; this team can, simultaneously, cover a wide variety of facets of the response and the interactions between them.  However, the size of the team does need to be proportionate in respect of the priority attached to the intervention, i.e. informed based upon a prioritised programme.

A1.1.4  The team enables NII to evaluate the management and integration of the response by being in more than one place at the same time.  Thus for any particular exercise an in depth review of some key areas, together with an overview of others, enables the exercise evaluation team to make a judgement on the ability of the licensee’s staff to cope with a real emergency.

A1.2  What do you have to do?

A1.2.1  The site inspector ensures that the scenario tests a significant proportion of the emergency response capability; he/ she will also have reviewed the scenario and will require the licensee to demonstrate that learning points identified from previous exercises have been successfully addressed.  To avoid last minute changes, it is important to agree the scenario with the licensee well in advance of the date of the demonstration exercise.

A1.2.2  To carry out an adequate assessment of the licensee’s arrangements, members of the NII team should be suitably qualified and experienced.  Team members should have completed the Command and Control “Foundation” and “Exercise Evaluation” training courses provided by the Emergency Arrangements team.

A1.2.3  Agreeing the scenario

• The key requirement is that the scenario ensures that sufficient elements of the emergency response plan are exercised together, so that the ability to demonstrate integrated control and management of multiple multi-element tasks is tested.
• The scenario should be rooted in the current safety case for the site/ facility.  It should involve an element of loss of radiological control or nuclear safety.  The technical scenario can range from REPPIR’s reasonably foreseeable event to the more extreme possibilities in the safety case and should involve casualty recovery and contamination and radiation dose control appropriate to the site in question.
• It need not require an off-site radiological release in situations where this is not credible. However to ensure that public protection is actively considered as well as on-site actions, it is possible to have an on site incident that is coupled to an ‘unrelated’ off-site release.  Umpiring can make the ECC Director aware he/ she has two ‘unrelated’ problems to face.
• The scenario should contain the unexpected - making the emergency team think rather than just running through a standard set of responses. 
• Before agreeing to the scenario it will be necessary to be aware of the recent history of scenarios set, the lessons to be learned from the last exercise (and any recurrent actions from previous exercises), any areas/ aspects that have not been demonstrated to the regulator for some years, any recent changes to the emergency arrangements, and any ongoing policy issues being followed up by the Emergency Preparedness section.
• When the off-site emergency services are involved, the scenario should provide a sufficient challenge (e.g. casualties for recovery/ a large fire in the controlled area/ an on-site Road Traffic Accident [with trapped personnel] in the plume, contaminated casualties to be taken to hospital, etc) to ensure they have work to do.  This will require the demonstration of an integrated approach from licensee and emergency services.
• Levels of radiation and contamination should be such that active control is necessary, with sufficient back up information e.g. contamination data to be used if the demonstration of control is inadequate.
• It will add to the realism if the simulated ‘repair’ can actually be carried out by the damage repair team (DRT).  Likewise the use of actors to simulate casualties adds an element of realism.  Note that casualties should have ‘real’ names – not something that is obviously made up (e.g. Andrew N. Other) and not the same names used year after year.
• The scenario should be aimed at being completed in about 3 hours with the licensee making provision for domestic arrangements as appropriate.  There should be a clearly expected decision sequence which can be used to judge the actual actions as against those expected.
• It is not possible to prevent those involved in the exercise having some prior knowledge of the event.  Since exercises develop a life of their own (i.e. the same scenario never plays the same way twice) prior knowledge is more likely to be a hindrance than a help.
• The scenario should be passed out to the inspection team at least 2 weeks in advance to allow it to be studied and any questions raised.  However, if the site inspector is to play his/ her expected role in the exercise another inspector (perhaps from a twin site) should organise the scenario and handle the administration.

A1.2.4  At the same time that the scenario is agreed, it is good practice to define the exercise objectives.  Inspectors may wish to use the bullet point headings from the Appendix 2 aide memoire to agree detailed measurement criteria.

A1.2.5  Before going to site the inspection team should be familiar with the scenario.  They will need to know what is expected to happen, when it is expected to happen, who the casualties will be and where they will be, who is expected to take which decisions, and what the licensee success criteria are.  Quite often it will only be possible to hear one side of any communication e.g. a telephone call so that it will be necessary to deduce what is happening from what can be heard and the actions that result from the call.  Knowing the scenario in detail facilitates such deduction. 

A1.2.6  Before any exercise it is usual to have a meeting on-site to handle the admin for the day, to clarify any last minute issues, to sort out access to active areas, to distribute identifying tabards, to identify minders, etc.  After this meeting it is usual for the NII team to be taken round the areas of action during the exercise to familiarise themselves with the layout and facilities that are to be used.  Having read the scenario, a new inspector should raise any queries with the site inspector prior to departure.  However, if there are any remaining uncertainties these can be raised at this meeting with the licensee.

A1.2.7  It is best if a new inspector knows before going to site what parts of the exercise he/ she is expected to cover.  If this involves entry to the active area and the inspector is a radiation worker, it is essential that the inspector’s TLD/ radiation pass book is passed to the licensee at the meeting to ensure both inspector and licensee comply with the law. 

A1.2.8  At the pre-meeting inspectors should establish if, when, and where they are required to muster, and pick up an observer tabard.  If the inspector is unfamiliar with the site and the licensee offers a ‘minder’ it is recommended that the offer be accepted.  These individuals look after the details of routine protection, getting inspectors around on the site, into the areas they want to visit, etc.  They can be very useful since they see what the inspector sees and should be made aware of what the inspector thinks, limiting surprises when the site and NII get together in the ‘hot’ exercise debrief.  Usually familiar with the site emergency procedures, they can be useful in allowing an inspector to check whether what is being observed is a valid part of the site’s arrangements or a ‘construct’ of the particular exercise.

A1.3  Observing the Exercise

A1.3.1  To gain an overall picture of what has happened it is necessary for all inspectors to keep a timed log of all key events and decisions at their location(s).  It is usually best to note the time that the site alarm sounds at the start of the exercise and time everything relative to this.  Putting individual information together enables an overall picture of what the various licensee teams knew (when), what decisions they took (when), what they did (when), what information they exchanged (when), etc. 

A1.3.2  If inspectors are not satisfied with the exercise play, any required intervention should be through the umpires/ exercise controllers via the NII team leader; usually the Superintending Inspector.  Inspectors should only intervene directly if they see something that is sufficiently unsafe to require an instant response.  In general non-urgent issues identified on site are usually fed back to the site inspector to carry forward.

A1.3.3  Umpires

• Umpires should wear tabards that identify them clearly.  They should be competent to provide the information they have to transfer so that they can improvise realistically if questions are raised that the scenario has not considered in detail.
• Umpires should not normally volunteer information e.g. radiation/ contamination readings unless asked for them.  NB when asking the instrument should be switched on.
• Umpires can point out things that would be obvious in real life but may not be so in the simulation e.g. seeing a large pool of water, the sound of escaping gas/ high pressure steam, the sound and sight of a large fire, hearing of loud noises, etc, etc.
• Umpires should not steer, comment to, or prompt teams undertaking exercise tasks – even if the team are obviously getting it wrong.

A1.3.4  Safety

• On the familiarisation visit to the site before the exercise, inspectors should be looking at what is proposed for the exercise.  Nothing introduced should undermine the usual safe practices on site.
• Inspectors looking at team deployment should be familiar with the symptoms of fatigue and heat exhaustion.  They should continually review the performance of the teams to identify anyone suffering from it.  Individuals believed to be so suffering should be pulled out of the exercise before an accident happens.
• BA teams tend to be young and fit.  Inspectors should consider their own capabilities when following them to ensure they do not overstrain themselves.
• Safety should always supercede any form exercise play.  Exercises should be stopped if unsafe acts happen (or are about to happen) or if a real incident/ injury occurs.

A1.3.5  Exercise Termination

• Exercises should normally be run until the licensee’s exercise objectives (usually stated in the scenario) have been met, and the NII team is satisfied they have seen enough.
• Exercises should normally be allowed to run until the DRTs have demonstrated their capability and have returned safely to the exit barrier.
• If an exercise has gone awry e.g. the casualties have not been rescued after several hours the exercise should be terminated after a given period of time.  Bearing in mind the fatigue load on those taking part (and the fact that if a real event occurs as the exercise is finishing and they will have to respond), 4 hours is about the maximum that they should be asked to perform.
• The NII team should agree beforehand who will decide/ tell the licensee that the exercise is considered finished, this is usually the NII Team Leader.  If a consensus is required, inspectors who are deployed round the site should pick up an ECC phone number and phone in to the ECC observer to give their view on whether it should finish or not.  Alternatively, the exercise control team will have radios that can be borrowed to get the message in.

A1.4  Making the Judgement

A1.4.1  When observing the exercise play it should be born in mind that at the end of the exercise the inspector will be asked to provide a judgement on the standard of those sections which he/ she has observed.  Comparison of the detailed measurement criteria from A1.2.4 with what was actually done is one criterion for making a judgment on the success of the demonstration.  During the NII hot debrief the team discusses what has been seen and, sometimes most important, when the different centres became aware of various issues. 

A1.4.2  Comparing his/ her event time line with that of other inspectors it is possible to derive a picture of what actually happened overall.  Once the picture is clear the inspector will need to make an individual judgement on what they have seen so that an overall team judgment of the whole exercise can be derived.  There are various ways in which this overall judgement is derived within the NII team during its hot debrief.  As an example each team member is asked (based on what they have observed) to rank the licensee performance on a scale of 0 – 10 where 5 is not permitted.  0 – 4 represents degrees of unacceptability, 6 – 10 degrees of acceptability.

A1.4.3  To make such a judgement it is necessary to allow for the unreality of the scenario - and the level of role playing that is incorporated to get the scenario to work.  A licensee team may have to be told the temperature is increasing, or that they can see a fire or flood – the reality is that their senses would tell them that.  It should be remembered that the key consideration is whether you think the licensee’s team would cope in a real emergency. 

A1.4.4  Once an overall team view is established it is then usual to generate a list of good points that you observed and a list of learning points i.e. those points where you consider that some change is required.  It is a good idea to know what you think should be done as this will assist the site inspector when he comes to check how they have responded to your learning point.  It will be necessary to provide evidence to support any criticisms.  They will be discussed with the licensee team at the joint debrief which follows the NII hot debrief.  This is when detailed notes come in useful – unless the fault has already been noted by the licensee or is so self evident that it could not be overlooked e.g. it took 2 hours to rescue the first casualty.

A1.4.5  Following the NII hot debrief, a joint NII/ licensee meeting takes place; other participating stakeholder organizations also attend.  The debrief follows a structured protocol with a single spokesperson delivering the feedback.  The licensee first reports back from its own hot debrief and then the NII comments are fed back to the licensee, including the team’s judgement on the adequacy of the demonstration.

A1.4.6  Most licensees are self-critical.  They will also have a more complete picture of what occurred since they know what they were thinking (and why) at particular times.  It is no disgrace in the joint debrief to listen to the licensee’s explanation of a problem, which you have identified, and to decide that you will give them the benefit of the doubt and withdraw your criticism.  Indeed, it is to your advantage if you accept their explanation since in areas where you do not they will be more inclined to listen to your point of view.

A1.4.7  When making the judgement not only what has been achieved but how it has been achieved will be considered.  However, if a good overall performance has been achieved by methods which do not correspond to the generality of good performance – say a very personal command and control style is used – this should not require an aspect to be repeated.  It is the ability to cope, (safely in a well-controlled managed way), that in reality matters – not the method by which individuals choose to cope.

A1.5  If the judgement is adverse

A1.5.1  In making the judgement on specific exercises the key question is whether the regulatory team considers the licensee team would cope with a real emergency.  The result of the exercise will be either a satisfactory demonstration of the arrangements or that a further rehearsal is required.  If the demonstration was unsatisfactory, a decision is required on whether the extent of problems revealed will necessitate a partial or a full repeat exercise (once the problems have been addressed by the licensee). 

A1.5.2  This decision should be based on the performance as demonstrated on the day.  For example if the problem is assessed as being associated with general communication on site, improved communication is only likely to be demonstrated by running all the on-site facilities.  On the other hand, if the problem is communication between the off-site survey vehicles and the site, then this could be demonstrated by a repeat of that part of the exercise.

A1.5.3  If a repeat is judged necessary, the question of continued operation of the site arises while the shortfalls are addressed.  The decision will be dependent on the number and significance of the shortfalls on the particular day, and a judgement on whether they represent fundamental weaknesses in the licensee’s arrangements, or are associated with the particular licensee’s team getting it wrong.  This judgement will draw on the work that the site inspector has undertaken as part of his/ her routine inspection of emergency arrangements and their implementation on the site. 

A1.5.4  It should be borne in mind that, if the licensee does not provide a satisfactory demonstration of the arrangements this does not usually require a site or facility to be shut down (or be brought to a safe state) while the emergency response capability is recovered.

Appendix 2:  Aide Memoire for Inspectors for Level 1 Emergency Exercise Evaluation

A2.1  Emergency Arrangements - Control Centres

A2.1.1  The following figure and paragraphs describe the typical command and control centre arrangements for a site.  The exact arrangements including names and locations of the various centres may vary between licensees.

A2.1.2 The site Emergency Control Centre (ECC) is usually located on the affected site and is where the site emergency controller manages the overall Licensee’s activities to minimise off-site releases and restore the site to a safe condition. For the reactor sites a further centre, (Central Emergency Support Centre (CESC)), is set up to provide technical support to the ECC and manage the off-site interface and monitoring aspects.

A2.1.3 The Strategic Co-ordination Centre (SCC) is sited sufficiently far from the affected site not to be directly affected by the site emergency. Its purpose is to decide upon the actions to be taken off-site to protect the public, to ensure that those actions are implemented effectively and to ensure that authoritative advice is passed to the public.

A2.1.4 The Facility Control Centre (FCC) is located in the facility affected by the emergency. Its purpose is to provide management control over activities to recover casualties, make an initial assessment of the impact of the incident and plan and initiate tactical measures to return the plant to a safe state.

A2.1.5 On sites where potential incidents may require a facility to be evacuated, the activities of the FCC may be carried out at a remote Evacuation / Incident Centre. This centre also serves as a muster point to identify missing persons, perform an initial assessment of the radiological exposure of facility workers and to manage the interim health and welfare requirement of evacuees.

A2.1.6 The Incident Control Point (ICP), also called Access or Forward, provides the front line control at the incident scene. The key objectives managed from the ICP are to search for and recover casualties, assess plant damage and to terminate the incident and effect damage repair.

A2.2 Emergency Arrangements Control Structure

This section is intended as aide memoire guidance for inspectors identifying the significant attributes for each emergency response activity with some general key words as indicators of what to look for. New inspectors may also wish to refer to the supporting guidance that provides further clarification and detailed information on each control centre or process activity.

List of Sections

Control Centres / Points
A2.2.1. Emergency Control Centre (ECC)
A2.2.2. Facility Control Centre / Room (FCC)
A2.2.3. Evacuation / Muster Centre
A2.2.4. Incident Control Point (ICP)

Process Activities

A2.2.5. Command and Control
A2.2.6. Teams
A2.2.7. BA Control
A2.2.8. Dose Control
A2.2.9. Contamination Control
A2.2.10. On- and Off-Site Survey Control

Non Reactor sites

A2.2.11. Plant with Chemical / Dispersible Radioactive Source Terms

A2.2.1 Emergency Control Centre

Attributes	Indicators
Management	Centre managed using Command and Control principles A2.2.5
Strategic Thinking	Big picture, realistic/ worse case scenarios Actions based on realistic/ resources in place for worst case Forward thinking, timeous decisions based on best available information Strategic action tracking/ response to actions not being met Public/ personnel/ plant/ environment
Public/ Personnel Protection	Early/ continuing conservative off-site countermeasure advice Muster points/ plume position Keeping staff informed Moving non-essential personnel out of danger/ off-site Decision making on individual dose commitment Tenability (refer to supporting guidance document)
Muster co-ordination	Site closed up Casualty/ missing person identification (golden hour) Early incident area/ site wide reconciliation Release of individuals to support emergency response
Communication	Sharing focus/ status information, (refer to supporting guidance document - Information management, action management & record keeping and FCC Interface with ICP/ECC) Emergency services (refer to supporting guidance document - Emergency Services Liaison) Information to SCC/ clarity of control handover Requests to/ from other external centres, e.g. CESC Refer to (refer to supporting guidance document - On and off-site communication)

A2.2.2 Facility Control Centre / Room

Attributes	Indicators
Management	Centre managed using Command and Control principles A2.2.5
Strategic/ tactical thinking	Early stages until ECC operational strategic thinking/ issues as ECC Once ECC taken over forward thinking about tactical overview/ guidance/ assistance to ICP on incident assessment, casualty recovery, incident control and termination Generation/ evaluation of practical aspects of repair proposals
Declaration	Evaluation of all available information e.g. plant status/ symptoms, CCTV, maintenance jobs, fence post monitors Realistic/ possible worst case assessment Early conservative decision based on best available information, (refer to supporting guidance document – Declaration)
Public/ Personnel Protection	Early ECC stand in role Alarm/ tannoy/ site close up & muster, (refer to supporting guidance document - Roll call) Tannoy incident outline/ safe muster routes Early conservative countermeasure advice to Police, (refer to supporting guidance document - Off and On-site countermeasure advice) Tenability (refer to supporting guidance document)
Plant Control	Evaluation of incident/ prognosis based on realistic/ worse case assumptions Steps to alleviate incident impact/ terminate incident Short and long term stable end point position ‘Beyond Design Basis’ instructions/ operations Refer to supporting guidance - Plant Control
Interfaces/ communications	Handover to ECC Sharing focus/ status with ECC/ ACP, (refer to supporting guidance document - On and off-site communication and FCC Interface with ICP/ ECC) Use on on-site resources e.g. damage repair

A2.2.3 Evacuation Centre / Muster Point (refer to supporting guidance document)

Attributes	Indicators
Management	Centre / Point managed using Command and Control principles A2.2.5
Roll Call	Co-ordinated central system identifying those involved Seriously injured need to be identified and recovered within the ‘golden hour’ Any system – be it paper or electronic – is acceptable if it can deliver in the timescale Seriously injured casualties only ‘accounted for’ when they receive medical treatment
Muster points	Venue large enough to handle those mustering/ having sufficient respirators to allow evacuation through plume Single individual in control Application of automatic countermeasures - KIO3 simulated realistically – water available - Doors/ windows shut; ventilation off (unless plenum appropriately filtered) Contamination Control A.2.2.9 Radiation/ contam monitoring instrumentation being used Audible tannoy / Effective communication Release of individuals to support emergency response
Plant muster point	Rapid screening system for and segregation of contaminated individuals Decontamination facilities e.g. shower TLD/ dose checking Routine monitoring/ air samples for contam spread with fixing or removal Debriefing of those involved & feed forward of information Release of individuals to support emergency response
Criticality Issues	Checking for symptoms of high radiation dose Immediate dose assessment Those suspected of having high dose to medical facilities Debrief of those ‘close’ to the event & feed forward of information Release of individuals to support emergency response

A2.2.4 Incident Control Point, (also termed Access or Forward Control Point)

Attributes	Indicators
Management	Control point managed using Command and Control principles A2.2.5
Tactical thinking	Incident assessment/ Casualty recovery/ incident alleviation & termination What has to be done, in what order, how, requiring what resources/ equipment/ material Continuous assessment of risks, consideration of existing and forward resource requirements Contamination Control A.2.2.9 Changes of direction based on what has been achieved, what needs to be achieved, and what can be achieved
Team Control	Clear objectives set – for re-entry team and for teams deployed, (refer to supporting guidance document - Entry Team co-ordination and control) Series/ parallel working as situation allows Coordination/ co-operation with emergency services Plans/ objectives changed/ updated as teams gather information/ achieve objectives Tenability (refer to supporting guidance document) Entry Team Communications (refer to supporting guidance document)
Emergency services liaison/ co-operation/ coordination	Sharing of information Agreed command structure in ICP and for individual teams Recognition of possible areas of contribution and specialist skills Effective use of specialist skilled resources
Information Handling	Single radio contact point in quiet area Flow of info from deployed/ debriefing teams to boards and controller Use of all information sources e.g. fixed cameras, installed monitoring equipment etc Interaction with other centres e.g. sharing of focus points/ action outcomes Record keeping

A2.2.5 Command and Control (refer to supporting guidance document)

Attributes	Indicators
Leadership	direction (short and long term)/ focus priorities (short and long term/ regular review) for public, personnel, plant and environment calm operating environment team roles defined
Decision making/ action tracking	forward thinking/ resourcing for worst case/ acting on most likely anticipating events using available information / not waiting too long to decide monitoring action completion/ responding to answers
Information Handling	briefing team/ emergency services use of boards co-ordination with other centres Record keeping

A2.2.6 Teams (refer to supporting guidance document - Teams)

Attributes	Indicators
Composition	Initial teams site personnel switching to mixed/ emergency services when position on access and egress known Initial teams to include HP carrying/ using instruments Initial team to include first aiders for casualty handling
PPE/ RPE	Full change/ impervious suit with gloves/ boots/ suit hoods taped Initially BA until hazard understood EPDs carried with rate and accumulated dose. Dose reference levels / EPD alarms set based on entry task
Briefing	Before entry on task, known and potential hazards, safe routes/ fall back areas, comms requirements, dose constraints/ action levels, expected actions if casualties encountered/ team has problems/ unexpected conditions encountered plus any specialist requirements e.g. position of fire risers/ stretchers, etc
Back up Rescue Team	During any entry a BA back up rescue team should always be available for instant deployment
Task Definition	Tasks thought through to minimise team dose Complex tasks rehearsed before entry Equipment tried and tested before entry

A2.2.7 BA Control (refer to supporting guidance document - BA Control)

Attributes	Indicators
Tally board	Single tally board – or two teams (fire/ licensee) situated close together - with a single individual staffing the board(s) at all times Tallies and BA pressures entered and removed as team members enter and exit Controller should know who is in/ out at all times

A2.2.8 Dose Control (refer to supporting guidance document - Dose Control)

Attributes	Indicators
ALARP	While IRR dose limits disapplied (provided a Radiation Emergency declared) during emergency ALARP still has to be applied Tasks involving dose commitment should be planned to minimise dose Continuous risk assessment should be undertaken (could be done in the head of the ICP controller / other ICP specialists)
Systems	For monitoring and recording individuals’ doses received during entries for comparison with previously agreed emergency dose limits and controlling dose commitment to individual team members To go to higher authority e.g. Emergency Controller in the ECC for authorisation of doses in excess of delegated limits

A2.2.9 Contamination Control (refer to supporting guidance document - Contamination Control)

Attributes	Indicators
Fixed and Mobile Facilities	Segregation of incident access and egress Air Flow: Clean to Dirty, (physical segregation is preferable) Double barriers on exit with decontaminable surfaces/ floor Routine area monitoring & decontamination/ air samplers running and checked
Dressing	Appropriate PPE, Full change/ impervious outer suit with gloves/ boots taped BA set/ respirator with suit hood taped over mask Team members self checking/ checking each other for PPE seal/ BA pressure
Undressing	By PPE protected assistants Prioritised based on remaining air Contam fixed/ removed (vac)/ damped down before monitoring/ undressing. (Watch for monitor probes touching clothing/ becoming contaminated, (appropriate unless alpha)) Undressing into contam clothing containment bag Top down/ glove changing before fitting clean respirator Over first barrier in full change/ respirator/ overshoes for full monitor Respiratory protection maintained until monitored clear
Housekeeping	Contam clothing contained in sealed bags routinely monitored/ removed from operating area Routine monitoring of floors/ barriers/ contam found fixed or removed Alarm air samplers running Undressers on dirty side wearing PPE
Casualty Handling	Casualty brought to first exit barrier monitored Seriously hurt casualties fast tracked by wrapping in clean plastic (bagged) before passing over barrier without further decontam (watch glove changing/ contam of outside of ‘bag’) Walking wounded decontam’ed before being passed to Medical Refer to supporting guidance document - Casualty Handling/ Medical Aspects

A2.2.10 On & Off site Survey Control (Refer to supporting guidance document -On and Off Site Surveys)

Attributes	Indicators
Strategy/ Control	Early confirmation of on- and off-site position Locate plume edges/ monitor changes of plume position Minimise team’s in plume time
Deployment	Vehicle integrity/ personnel PPE/ RPE Vehicle roadworthiness checks Instrument checks (function & calibration) Comms checks & initial briefing Deployment time/ time to first result
HP Advice	Predictive modelling – interpolation & decisions on next measured position Predictive/ measured data melded into clear on- & off-site advice Clarity of presentation/ interface with FCC/ ECC/ SCC as structure develops

A2.2.11 Plant with Chemical / Dispersible Radioactive Source Terms (refer to supporting guidance document)

Attributes	Indicators
Spills	Source term Spread - Wind direction/ ventilation flows Approach to incident Barriers; isolation from drains/ inactive areas Recovery – potential criticality/ containers Priorities when combined with other aspects of the incident
Criticality	Local/ building inventory/ amount involved Liquid systems chugging/ re-criticality on recovery Ventilation contamination spread/ filter high radiation Human moderator in fissile stores Fire fighting limitations in, say, fissile stores
Access	Air sampler alarms Contamination monitoring of access/ egress routes Restricted Area entry prohibition Damaged windows/ high radiation fields
Monitoring	Detection of unaged Pu Instrument contamination Detection of alpha in wet conditions
Multiplant Sites	Remote location mobile facilities Site wide emergency response checking/ release of those not involved Interlinkage of building ventilation
Security	Prioritisation of security aspects Interface of security and safety emergency arrangements Protection of security staff from activity On-site personnel movement for security reasons Specialised search teams

• Annex 1: Detailed Supporting Guidance - Emergency Arrangements - Control Centres and Activities