Proposal for guidelines for the transposition and implementation of the provisions of Directive 2013/59/Euratom on EP&R : final report.
Date: 2018-11-29
Institutions: Directorate-General for Energy
Subjects: application of EU law, environmental risk prevention, ionising radiation, nuclear accident, nuclear safety, occupational safety, radiation protection, radioactive materials, radioactivity

VINÇOTTE NUCLEAR SAFETY 

 Report VNS-TR-16-035 v1 

Proposal for guidelines for the transposition and 
implementation of the provisions of Directive 
2013/59/Euratom on EP&R 

Committed to safety

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Proposal for guidelines for the transposition and 
implementation of the provisions of Directive 
2013/59/Euratom on EP&R 

Final report prepared by VNS for the European Commission under contract 
ENER/2015/NUCL/SI2.721507 

Catalogue number MJ-02-17-387-EN-N 

ISBN 978-92-79-67896-7  

DOI 10.2833/270520 

© European Atomic Energy Community, 2017 

Disclaimer: 
This  report  has  been  produced  for  the  European  Commission  under  contract  by  VNS.  The  views 
represented  in  the  report  are  those  of  its  authors  and  do  not  necessarily  represent  the  views  or 
official  position  of  the  European  Commission.  The  European  Commission  does  not  guarantee  the 
accuracy  of  the  data  included  in  this  report,  nor  does  it  accept  responsibility  for  any  use  made 
thereof. Information provided by individuals in the authorities of the mentioned Member States in 
response  to  questionnaires,  is  included  in  this  publication.  Any  views  expressed  therein  may  not 
reflect the official position of the authorities, nor of the European Commission. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Versions history 

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v1 

23/05/2017 

v0 
Version 

06/04/2017 
Date 

Clarifications  regarding  some 
differences  in  the  terminology, 
concepts 
guidance 
and 
levels/reference levels between 
the IAEA GSR Part 7 and the BSS 
EU  
and 
Directive 
Regulation 2016/52. 
Final report  
Description 

the 

A. de Lhoneux  S. Shihab 

S. Shihab 

A. de Lhoneux  S. Shihab 
Written 

Verified 

S. Shihab 
Approved 

LEGAL NOTICE 

LIABILITY 

This  document  was  prepared  by  VNS  which  always  endeavours  to  deliver  high  quality  services. 
Notwithstanding this, 

a) 

b) 

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no guarantee can be given on the correctness or completeness of the information provided in 
this  document,  or  that  the  use  of  any  information  disclosed  in  this  document  may  not 
infringe third party rights, and 
neither  VNS  nor  any  person  working  on  behalf  of  VNS,  is  responsible  or  may  be  held 
accountable for any loss suffered because of reliance upon the information provided or for 
any third-party rights infringement resulting from the use of this information. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Table of content 

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1 

Introduction ..................................................................................................................................... 9 

2  Methodology ................................................................................................................................. 11 

3 

Provisions of the BSS Directive on EP&R ....................................................................................... 13 

3.1 

3.2 

4 

5 

5.1 

5.2 

The new BSS Directive .................................................................................................... 13 

General description of new and extended provisions in the BSS Directive ................... 14 

3.2.1 

Emergency management system ................................................................................... 14 

3.2.2 

International cooperation............................................................................................... 16 

3.2.3 

Emergency response ....................................................................................................... 16 

3.2.4 

Reference levels for public exposures in an emergency exposure situation ................. 16 

3.2.5 

Protection of emergency workers .................................................................................. 16 

Challenges in the implementation of EP&R provisions under the BSS Directive .......................... 17 

ICRP and IAEA standards and recommendations pertaining to EP&R .......................................... 19 

ICRP Publications ............................................................................................................ 19 

IAEA Safety Standards and technical guidance .............................................................. 19 

5.2.1 

Safety Standards ............................................................................................................. 19 

5.2.2 

Technical Guidance ......................................................................................................... 20 

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6 

Transposition status of the EP&R provisions of the BSS Directive by the 10 selected MS ........... 23 

7  Need for guidelines or recommendations .................................................................................... 24 

8 

9 

The HERCA working groups on EP&R ............................................................................................ 27 

Discussion on the topics related to EP&R of the BSS Directive ..................................................... 30 

9.1 
Transition  from  an  emergency  exposure  situation  to  an  existing  exposure  situation 
including recovery and remediation ..................................................................................................... 30 

9.1.1 

Issues to be further addressed ....................................................................................... 30 

9.1.2 

Available international guidance .................................................................................... 31 

9.1.3 

Preliminary guidance or recommendations ................................................................... 32 

9.2 
Generic criteria for particular protective measures, default triggers, operational criteria 
for particular actions ............................................................................................................................. 33 

9.2.1 

Issues to be further addressed ....................................................................................... 33 

9.2.2 

Available international guidance .................................................................................... 33 

9.2.3 

Preliminary guidance or recommendations ................................................................... 39 

9.3 

Protection strategies for the public and optimisation approaches ................................ 39 

9.3.1 

Issues to be further addressed ....................................................................................... 39 

9.3.2 

Available international guidance .................................................................................... 40 

9.3.3 

Preliminary guidance or recommendations ................................................................... 42 

9.4 

Reference levels .............................................................................................................. 45 

  
 
 
 
 
 
 
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9.4.1 

Issues to be further addressed ....................................................................................... 46 

9.4.2 

Available international guidance .................................................................................... 46 

9.4.3 

Preliminary guidance or recommendations ................................................................... 47 

9.5 

Involvement of stakeholders .......................................................................................... 49 

9.5.1 

Issues to be further addressed ....................................................................................... 49 

9.5.2 

Available international guidance .................................................................................... 49 

9.5.3 

Preliminary guidance or recommendations ................................................................... 49 

9.6 

Reference levels for emergency occupational exposure ................................................ 50 

9.6.1 

Issues to be further addressed ....................................................................................... 50 

9.6.2 

Available international guidance .................................................................................... 50 

Assessment  of  potential  emergency  exposure  situations  and  associated  public  and 
9.7 
emergency occupational exposures ...................................................................................................... 51 

9.8 
Information to the public (likely to be affected or actually affected in the event of an 
emergency)  ……………………………………………………………………………………………………………………………………51 

9.8.1 

Issues to be further addressed ....................................................................................... 51 

9.8.2 

Available international guidance .................................................................................... 51 

9.8.3 

Preliminary guidance or recommendations ................................................................... 52 

9.9 
Prior information and training for emergency workers and all other persons with duties 
and responsibilities in emergency response ......................................................................................... 53 
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Issues to be further addressed ....................................................................................... 53 

9.9.1 

9.9.2 

Available international guidance .................................................................................... 53 

9.9.3 

Preliminary guidance or recommendations ................................................................... 53 

9.10 

International cooperation............................................................................................... 53 

9.10.1 

Issues to be further addressed ....................................................................................... 54 

9.10.2  Available international guidance .................................................................................... 54 

9.11 

Health protection of emergency workers ...................................................................... 54 

9.11.1 

Issues to be further addressed ....................................................................................... 54 

9.11.2  Available international guidance .................................................................................... 55 

10 

Proposal for guidelines ........................................................................................................ 56 

10.1 
Transition  from  an  emergency  exposure  situation  to  an  existing  exposure  situation 
including recovery and remediation ..................................................................................................... 56 

10.2 
Generic criteria for particular protective measures, default triggers, operational criteria 
for particular actions ............................................................................................................................. 56 

10.3 

10.4 

10.5 

10.6 

Protection strategies for the public and optimisation approaches ................................ 57 

Reference levels for public exposure .............................................................................. 58 

Involvement of stakeholders .......................................................................................... 58 

Reference levels for emergency occupational exposure ................................................ 58 

  
 
 
 
 
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10.7 
Assessment  of  potential  emergency  exposure  situations  and  associated  public  and 
emergency occupational exposures ...................................................................................................... 58 

Information to the public (likely to be affected or actually affected in the event of an 
10.8 
emergency)  ……………………………………………………………………………………………………………………………………58 

10.9 
Prior information and training for emergency workers and all other persons with duties 
and responsibilities in emergency response ......................................................................................... 59 

10.10 

10.11 

11 

12 

International cooperation............................................................................................... 59 

Health protection of emergency workers ...................................................................... 59 

Conclusions .......................................................................................................................... 61 

References ........................................................................................................................... 63 

Annex 1: 
Questionnaire sent to the 10 selected MS on the transposition and implementation of 
the BSS provisions on EP&R .................................................................................................................. 65 

Annex 2: 

Questionnaire on EP&R sent to HERCA and WENRA ...................................................... 87 

Annex 3: 

Compilation of the answers received by HERCA-WENRA to the questionnaire............. 89 

Annex 4: 

Provisions of the BSS Directive on EP&R ........................................................................ 94 

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List of Acronyms 

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BSS  
CLI 
CODIRPA 

DG ECHO 
DG ENER 
EFTA 
ENSEMBLE 
EP&R 
EPZ 
ETHOS 

EU 
EURANOS 

FARMING 
HERCA 
HWA 
IAEA 
ICRP  
ITB 
JRC  
MS 
NERIS 

NTW 
PREPARE 

VNS 
WENRA 

Basic Safety Standards 
Commission Locale d’Information 
COmité DIRecteur pour la gestion de la phase Post Accidentelle d'un accident 
nucléaire ou d'une situation d'urgence radiologique 
Directorate-General for European Civil Protection and Humanitarian Aid Operations 
Directorate-General for Energy 
European Free Trade Association 
Reconciliation of National Forecasts of Atmospheric Dispersion 
Emergency Preparedness and Response 
Emergency Planning Zone 
Rehabilitation of living conditions in the territories contaminated by the Chernobyl 
accident 
European Union 
European Approach to Nuclear and Radiological Emergency Management and 
Rehabilitation Strategies 
Food and Agriculture Restoration Management Involving Networked Groups 
Heads of the European Radiological Protection Competent Authorities 
HERCA/WENRA Approach 
International Atomic Energy Agency  
International Commission on Radiological Protection 
Iodine Thyroid Blocking 
Joint Research Centre 
EU Member States 
European Platform on preparedness for nuclear and radiological emergency 
response and recovery 
Nuclear Transparency Watch 
Innovative integrative tools and platforms to be prepared for radiological 
emergencies and post-accident response in Europe 
Vinçotte Nuclear Safety 
Western European Nuclear Regulators Association 

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1  Introduction 

The European Atomic Energy Community has established in the Council Directive 2013/59/Euratom 
laying  down  basic  safety  standards  for  protection  against  the  dangers  arising  from  exposure  to 
ionising  radiation  (BSS)  an  advanced  set  of  safety  standards  to  protect  workers,  members  of  the 
public and patients. It entered into force on 6 February 2014 and is to be transposed into Member 
States’ (MS) national legislation by 6 February 2018. 

In  December  2015,  the  Council  of  the  European  Union  adopted  a  set  of  Council  Conclusions 
pertaining  to  off-site  emergency  preparedness  and  response  (EP&R)  serving  to  highlight  the 
importance of EP&R to policymakers, decision-makers and the public in the EU1. 

The  Council  Conclusions  emphasize  measures  to  improve  coordination  and  to  better  align  EP&R 
arrangements among MS, especially in cases where an accident may affect neighbouring countries. 

The European Commission is invited to organise workshops to facilitate the consistent transposition 
and  implementation  of  the  BSS  Directive,  aiming  at  developing  a  coherent  approach  to  EP&R 
provisions of the Directive, including discussion of: 

•  Protection strategies and optimization approaches, including the use of reference levels; 
•  Generic criteria, operational criteria, default triggers; 
•  Arrangements for the transition from emergency to existing exposure situations; 
•  Emergency response arrangements and information to the public. 

The European Commission Directorate-General for Energy (DG ENER) has selected Vinçotte Nuclear 
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Safety (VNS) of Belgium to help implement the above-mentioned actions and activities2. 

One concrete output of such workshops could be the development of “implementation guidelines” 
(in  the  form  of  non-binding  guidelines,  recommendations  or  codes  of  good-practice3  )  to  help 
support MS during the transposition and particularly the implementation phase of the BSS Directive. 
It  would  assist  MS  to  achieve  better  coherence  and  consistency  in  their  emergency  planning  and 
response,  in  particular  for  cross-border  issues.  Furthermore,  the  identification  of  issues  regarding 
implementation  practices  at  the  EU  level  could  help  the  development  of  further  standards  and 
guidance currently being developed at the international level, for example by the IAEA. 

This  report  is  a  deliverable  to  the  European  Commission,  DG  ENER,  in  the  frame  of  contract 
ENER/2015/NUCL/SI2.721507. 

This report presents a survey on the strategies and plans of 10 selected EU member states (MS) for 
the  transposition  and  implementation  of  the  EP&R  provisions  of  the  BSS  Directive.  With  a  view  to 
supporting more coherent approaches to the implementation of the BSS Directive, it presents results 

1 3439th Council meeting, General Affairs, Brussels, 15 December 2015, document reference 15313/15 
2 Service Contract No. ENER/2015/NUCL/SI2.721507 on the transposition and implementation of the Emergency 
Preparedness and Response provisions of Directive 2013/59/Euratom. 
3 The ENCO-UJV review of off-site nuclear EP&R arrangements (2014 ) also made a number of recommendations of 
European level actions to make improvements, including promotion of harmonisation of criteria through the 
development of European guidance or Codes of Practice to address issues such as planning zones, criteria for 
protective actions, and cross-border arrangements, see 'Review of Current Off-site Nuclear Emergency Preparedness 
and Response Arrangements in EU Member States and Neighbouring Countries' ENER/D1/2012-474, Final Report, 
Main Text. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                             
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of  a  survey  to  identify  the  main  emergency  preparedness  and  response  topics  of  the  Directive  for 
which further guidelines appear to be mostly welcomed by the MS. 

This  report  analyses  also  the  international  standards  and  guidance  (IAEA,  ICRP)  to  assess  to  what 
extent  they  could  fulfil  the  needs  for  the  transposition  and  the  implementation  of  the  provisions 
related to the EP&R provisions of the BSS Directive. 

After analysis of the survey and the international guidance, issues were identified and proposals for 
draft  guidelines  were  made.  These  proposals  for  draft  guidelines  were  subject  to  a  dedicated 
Workshop  held  on  the  15  and  16  November  2016  where  nuclear  safety  authorities  and  other 
relevant  nuclear  EP&R  organisations  from  MS,  EU  Candidate  Countries,  and  EEFTA  Countries  were 
invited.  Most  of  these  countries  delegated  participants.  Based  on  the  discussions  and  feedback  at 
this  Workshop  [VNS,  2016b],  the  draft  guidelines  were  revised  to  form  the  present  report  which 
contain  the  basis  and  content  of  the  non-binding  guidelines  for  the  transposition  and 
implementation of the provisions of the Directive 2013/59/Euratom on EP&R. 

MS  can  use  existing  international  standards  and  guidance  where  appropriate.  The  European 
Commission  could  prepare  to  develop  and  adopt  guidance  at  the  EU-level  if  it  provides  an  added 
value and if it supports a greater coherence of approaches. EU-level guidance could address gaps or 
inconsistencies in available international standards and guidance, or European specificities. 

Possible tools for promoting an EU approach to EP&R consist in: 

•  Funding research projects and studies on specific topics (e.g. EURANOS, PREPARE projects); 
•  Promoting common EU response to consultations on international standards and guidance; 
•  Continuing the organization of MS meetings, workshops, expert group meetings. 

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Other non-legislative tools available to promote an EU approach to EP&R are: 

•  Commission guidance in Radiation Protection series; 
•  Commission Communication; 
•  Commission Recommendations. 

The proposals and recommendations made in this report are those of VNS and do not necessarily 
reflect the official opinion of the European Commission.  

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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2  Methodology 

VNS  conducted  a  survey within  10 MS  (5  nuclear  and  5  non-nuclear MS)  with  a  view  to  determine 
their strategies and plans for the transposition and implementation of the EP&R provisions of the BSS 
Directive. The outcomes of previous studies on the same topic were considered, in particular [ENCO, 
2013] and [RISKAUDIT, 2016]. 

The  study  was  limited  to  10  countries  rather  than  all  28  MS  to  provide  useful  results  despite  the 
limited timescale of the study, and yet provide representative findings. 

On  basis  of  criteria  such  as  the  geographical  representativeness  within  the  EU,  the  potential  for 
cross-border impact in case of an emergency situation and the advancement in the transposition and 
the implementation of the BSS Directive [VNS, 2016a], the following 10 MS were selected: Austria, 
Belgium, Bulgaria, Czech Republic, Germany, Denmark, France, Croatia, Ireland and Luxembourg. 

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Figure 1: Operating nuclear power plants in the European Union and density of population around 
the facilities. Source: DG ENER, data from 2011.  

  
 
 
 
 
 
 
 
 
 
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Figure  2:  100  km  circles  around  NPPs.  Source:  "How  do  we  harmonize  response  to  our  ultimate 
challenge?",  WS  on  the  Implementation  of  the  HERCA-WENRA  Approach,  13-15  June  2016,  Bled, 
Slovenia, by Andrej Stritar. 

A  comprehensive  questionnaire  to  address  the  transposition  and  implementation  of  the  EP&R 
provisions  of  the  BSS  Directive  by  the  MS  was  initially  prepared  by  VNS.  Several  proposals  for 
modification were made by the DG ENER to avoid the duplication of work performed in the past or in 
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on-going  contracts  on  the  same  topic,  notably  [ENCO  2013,  RISKAUDIT  2016].  This  resulted  in  the 
questionnaire reproduced in Annex 1.  

On  the  basis of  the  answers  (Annex 1),  topics where  further  guidelines  are  mostly welcomed were 
identified. For each of these topics, an analysis was performed to assess to what extent the relevant 
international standards or guidance e.g. from the ICRP or IAEA covers the scope of the BSS provision 
in  a  sufficient  manner.  Where  needed,  additional  recommendations  for  the  transposition  and 
implementation of the provisions of the BSS Directive are made. 

A  two-day  Workshop  was  organised  on  15-16  November  2016  in  Brussels.  Relevant  organisations 
from  all MS,  EU  Candidate  Countries,  and  EEFTA  Countries  were  invited. The  aim of  the  Workshop 
was to present and discuss the national transposition and implementation plans and activities of the 
selected 10 MS and to assess the proposed draft guidelines. 

As the Council Conclusions on EP&R did recognize the work carried by HERCA and WENRA to improve 
cross-border approaches, a questionnaire was sent to HERCA and WENRA to have a comprehensive 
view of the status of their work on EP&R. This questionnaire is reproduced in Annex 2. HERCA and 
WENRA provided answers which are reproduced in Annex 3. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
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3  Provisions of the BSS Directive on EP&R  

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3.1  The new BSS Directive  

Among  other  provisions,  the  BSS  Directive  contains  strengthened  requirements  on  EP&R,  taking 
account of the lessons learned from the Fukushima accident. The chapter on intervention (including 
emergency  planning  and  response)  in  the  previous  version  of  the  BSS  Directive  (Council  Directive 
96/29/EURATOM4)  is  replaced  with  more  detailed  requirements,  notably  the  Articles  7,  69,  97,  98, 
and 99 of the new BSS Directive. The provisions relevant for emergency preparedness and response 
in the BSS Directive are the followings: 

•  Art. 7 Reference levels 
•  Art. 17 Emergency workers 
•  Art. 53 Emergency occupational exposure 
•  Art. 69 Emergency response 
•  Art. 70-71 Information to the public 
•  Art. 97 Emergency management system 
•  Art. 98 Emergency preparedness 
•  Art. 99 International cooperation 

In addition the emergency provisions include the following annexes: 

•  Annex I Reference levels 
•  Annex XI Elements of emergency management system and emergency response plan 
•  Annex ХII Information to the public 

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The provisions relevant for EP&R are reproduced in Annex 4 together with some general remarks.  

The  provisions  consider  the  recommendations  from  the  International  Commission  on  Radiological 
Protection (ICRP). The BSS Directive applies to any planned, existing or emergency exposure situation 
which involves a risk arising from ionising radiation. The BSS Directive sets out general principles of 
radiation  protection,  giving  a  more  prominent  role  to  dose  constraints  for  occupational  and  public 
exposure.  An  annex  lists  the  ranges  of  reference  levels  proposed  by  the  ICRP  for  existing  and 
emergency exposure situations. 

Under the existing basic safety standards contained in Directive 96/29/EURATOM the requirements 
pertaining to EP&R are quite general, requiring appropriate 'intervention plans', drawn up at national 
or  local  level  to  deal  with  various  types  of  radiological  emergency,  which  should  be  tested  to  an 
appropriate extent at regular intervals. MS are required to take account of:  

the fact that radiological emergencies may occur on or outside its territory;  
the need for their reporting;  

• 
• 
•  and  the  need  for  assessment  of  the  dispersion  of  radioactive  substances  and  potential 

exposures. 

 A  general  provision  refers  to  the  need  for  cooperation  in  relation  to  possible emergencies on  MS’ 
territories  which  may  affect  other  countries.  Relevant  to  emergency  response,  Directive 

4 Council Directive 96/29/EURATOM of 13 May 1996 laying down basic safety standards for the health protection of the general 
public and workers against the dangers of ionizing radiation (OJ L-159, 29.06.1996,p. 1). 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                             
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2013/59/Euratom  incorporates  provisions  of  Council  Directive  89/618/Euratom5  on  informing  the 
general public about measures to be taken in the event of a radiological emergency. 

The new BSS Directive follows the situation-based approach to radiation protection recommended by 
the  International  Commission  on  Radiological  Protection  (ICRP)6,  distinguishing  between  existing, 
planned and emergency exposure situations.  

The  essential  elements  to  be  included  in  an  emergency  management  system  (prior  assessment  of 
emergency exposure situations, allocation of responsibilities, efficient coordination, cooperation and 
communication measures etc.) and in an emergency plan (reference levels for exposure, optimised 
protection  strategies,  pre-defined  generic  criteria,  default  triggers  or  operational  criteria  etc.)  are 
specified. 

The need for efficient management of an emergency with cross-border consequences is recognised 
through provisions for enhanced cooperation between MS in emergency planning and response. The 
proposed  revision  requires  MS to  cooperate  with other MS  and with  third  countries which may  be 
involved or are likely to be affected by an emergency, with a view to sharing the assessment of the 
exposure situation and coordinating protective measures and public information by using bilateral or 
international information exchange and coordination systems. 

The emphasis on optimisation, using reference levels, in emergency and existing exposure situations 
expands the earlier use of optimisation from planned activities to all exposure situations. To achieve 
optimised  protection  strategies,  accounting  for  the  effects  of  ionising  radiation  as  well  as  other 
societal criteria, is of particular importance in an accident and post-accident phase. 

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3.2  General  description  of  new  and  extended  provisions  in  the  BSS 

Directive 

3.2.1  Emergency management system  

MS are required to take account of the fact that emergencies may occur on their territory and that 
they may be affected by emergencies occurring outside their territory. The BSS Directive requires the 
establishment of a national emergency management system and adequate administrative provisions 
to maintain such a system. The management system shall be designed to be commensurate with the 
results  of  an  assessment  of  potential  emergency  exposure  situations  and  be  able  to  respond 
effectively to these emergency exposure situations. For the various types of emergency identified by 
the above-mentioned assessment, facility-specific or activity-specific emergency response plans need 
to be established in advance. These plans need to be tested, reviewed and, as appropriate, revised at 
regular intervals, taking into account lessons learned from past emergency exposure situations and 
the  results  of  the  participation  in  emergency  exercises  at  national  and  international  level.  The 
emergency  response  plans  shall  also  include  provisions  for  the  transition  from  an  emergency 
exposure  situation  to  an  existing  exposure  situation.  Annex  XI  of  the  new  BSS  Directive  provides 
detailed  elements  which  need  to  be  covered  by  the  national  emergency  management  system  and 
emergency response plan: 

•  Elements to be included in an emergency management system 

5 Council Directive 89/618/EURATOM of 27 November 1989 on informing the general public about health protection measures 
to be applied and steps to be taken in the event of a radiological emergency (OJ L-357, 07.12.1989, p. 31). 
6 ICRP Publication 103 (2007) The 2007 Recommendations of the International Commission on Radiological Protection, Ann. 
ICRP 37 

  
 
 
 
 
 
 
 
 
 
 
 
                                                             
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o  Assessment  of  potential  emergency  exposure  situations  and  associated  public  and 

emergency occupational exposures; 

o  Clear  allocation  of  the  responsibilities  of  persons  and  organisations  having  a  role  in 

preparedness and response arrangements; 

o  Establishment  of  emergency  response  plans  at  appropriate  levels  and  related  to  a 

specific facility or human activity; 

o  Reliable  communications  and  efficient  and  effective  arrangements  for  cooperation  and 
coordination at the installation and at appropriate national and international levels; 

o  Health protection of emergency workers; 
o  Arrangements for the provision of prior information and training for emergency workers 
and  all  other  persons  with  duties  or  responsibilities  in  emergency  response,  including 
regular exercises; 

o  Arrangements for individual monitoring or assessment of individual doses of emergency 

workers and the recording of doses; 

o  Public information arrangements; 
Involvement of stakeholders; 
o 
o  Transition  from  an  emergency  exposure  situation  to  an  existing  exposure  situation 

including recovery and remediation. 

•  Elements to be included in an emergency response plan 

For emergency preparedness: 

o  Reference  levels  for  public  exposure,  taking  into  account  the  criteria  laid  down  in 

Annex I; 

o  Reference levels for emergency occupational exposure taking into account Article 53. 
o  Optimised  protection  strategies  for  members  of  the  public  who  may  be  exposed,  for 

different postulated events and related scenarios; 

DRAFT 

o  Predefined generic criteria for particular protective measures; 
o  Default  triggers  or  operational  criteria  such  as  observables  and  indicators  of  on-scene 

conditions; 

o  Arrangements  for  prompt  coordination  between  organisations  having  a  role 

in 
emergency preparedness and response and with all other Member States and with third 
countries which may be involved or are likely to be affected; 

o  Arrangements  for  the  emergency  response  plan  to  be  reviewed  and  revised  to  take 

account of changes or lessons learned from exercises and events. 

Arrangements  shall  be  established  in  advance  to  revise  these  elements,  as  appropriate 
during an emergency exposure situation, to accommodate the prevailing conditions as these 
evolve throughout the response. 

For emergency response: 

The  response  to  an  emergency  exposure  situation  shall  be  undertaken  through  the  timely 
implementation of preparedness arrangements, including but not limited to: 
o  Promptly implementing protective measures, if possible, before any exposure occurs; 
o  Assessing the effectiveness of strategies and implemented actions and adjusting them as 

appropriate to the prevailing situation; 

o  Comparing  the  doses  against  the  applicable  reference  level,  focusing  on  those  groups 

o 

whose doses exceed the reference level; 
Implementing further protection strategies, as necessary, based on prevailing conditions 
and available information. 

  
 
 
 
 
 
 
 
 
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Amongst  the  preparation  measures,  members  of  the  public  likely  to  be  affected  by  an  emergency 
should be given prior information about health protection measures they should take in the event of 
an emergency.  

3.2.2 

International cooperation  

The  BSS  Directive  contains  strengthened  requirements  on  international  cooperation  in  case  of  an 
emergency  (in  an  EU  MS)  which  may  affect  other  MS  or  third  countries,  in  order  to  facilitate  the 
organisation  of  radiological  protection  in  all  countries  affected.  In  case  of  an  emergency,  this 
cooperation shall allow to promptly establish contacts with countries likely to be affected, share the 
assessment of the exposure situation, coordinate protective measures and inform the public by using 
bilateral and international information exchange and coordination systems. MS shall also cooperate 
in the transition from an emergency exposure situation to an existing exposure situation. 

3.2.3  Emergency response 

The installation or undertaking concerned is required to notify the competent authority immediately 
of  any  emergency  in  relation  to  the  practice  for  which  it  is  responsible  and  to  take  all  appropriate 
action  to  mitigate  the  consequences.  The  undertaking  is  also  responsible  for  making  an  initial 
provisional  assessment  of  the  circumstances  of  the  emergency  and  to  assist  with  protective 
measures. 

In  case  of  such  an  event,  the  authorities  in  the  concerned  MS  are  responsible  for  the  protective 
measures to be taken with regard to the radiation source, to reduce or stop the radiation, including 
DRAFT 
the release of radionuclides, with regard to the environment, to reduce the exposure of individuals 
resulting from radioactive substances through relevant pathways. Further requirements concern the 
provision  of  medical  treatment  of  those  affected,  if  the  situation  requires.  In  case  of  a  real 
emergency,  the  public  actually  affected  must  be  informed  without  delay  about  the  facts  of  the 
emergency and the protection measures to be taken. 

3.2.4  Reference levels for public exposures in an emergency exposure situation  

The new BSS Directive has introduced the concept of “reference levels” for emergency and existing 
exposure  situations.  It  allows  for  a  constrained  and  optimized  protection  of  the  public  as  well  as 
consideration  of  other  societal  and  economic  factors  in  a  similar  way  as  for  planned  exposure 
situations. 

3.2.5  Protection of emergency workers 

Special  emphasis  has  been  put  on  the  protection  of  emergency  workers.  The  Directive  contains 
specific requirements on the information and training to be provided to emergency workers prior to 
an  accident  and  in  case  of  a  real  event.  Emergency  occupational  exposure  shall  remain,  whenever 
possible, below the dose limits for occupational exposure. For situations where this is not possible, 
reference levels for emergency exposures of maximum 100 mSv shall be set, however in exceptional 
circumstances this may be set up to 500 mSv. In these cases, emergency workers shall be subject to 
appropriate radiological monitoring and special medical surveillance. 

  
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
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4  Challenges  in  the  implementation  of  EP&R  provisions  under  the 

BSS Directive 

The  provisions  of  the  BSS  Directive  on  EP&R  are  a  set  of  minimum  requirements  to  set  common 
national  objectives  in  terms  of  EP&R  within  the  EU.  The  BSS  Directive  requires  EU  countries  to 
achieve certain objectives but leaves them free to choose how to do so. 

The  provisions  of  the  BSS  Directive  on  EP&R  are  generic  in  nature  and  no  detailed  guidelines  or 
recommendations are provided by the Council of the European Union or the European Commission 
to the MS on the methods acceptable for complying with the provisions on EP&R. Therefore, a large 
set of opinions may exist on the extent and the level of detail required in the implementation process 
of the BSS Directive. 

At  the  very  heart  of  the  BSS  Directive  provisions  on  EP&R  is  the  principle  of  optimization  of  the 
protection. Its application can result in a broad range of outcomes. 

MS  have  developed  their  arrangements  for  EP&R  on  basis  of  international  and  national  standards. 
Differences in the standards used or in their interpretation result in different arrangements for EP&R 
between the MS.  

The 10 selected MS rely mostly on existing international standards and recommendations provided 
by  the  IAEA  and  the  ICRP  for  the  implementation  of  the  EP&R  provisions  of  the  BSS  Directive,  as 
deduced from the answers to questions 3 and 5 in Annex 1. They can therefore be considered as the 
basis of guidelines for the consistent implementation of the EP&R provisions throughout the EU. 

DRAFT 
The main international standards and recommendations that are used for the development of EP&R 
approaches are the ICRP and IAEA standards. The relevant documents are listed in the section 5. 

Specific guidance was also developed by some MS, for example: 

•  The  Nordic  Guidelines  and  Recommendations  on  Protective  measures 
intermediate phases of a nuclear or radiological emergency [NORDIC, 2014]. 

in  early  and 

•  The French national plan for responding to a major nuclear or radiological accident [SGDSN, 

2014]. 

•  The recommendation by the German Commission on Radiological Protection on the planning 

areas for emergency response near nuclear power plants [SSK, 2014]. 

In the context of planning and response to radiation emergencies which are only likely to affect the 
territory of the MS, the standards and basis of the arrangements is a matter for that MS, provided 
these  are  in  conformance  with  the  relevant  legislation,  including  the  EU  regulatory  framework. 
However, in the case of scenarios which may have cross-border implication, while these differences 
might  be  technically justifiable,  they  may  hinder  an  integrated  and  efficient  management  of  cross-
border emergency issues. 

In  the  context  of  cross-border  nuclear  accidents,  concerned  countries  are  sovereign  in  preparing 
their  emergency  response.  Consequently,  the  types  of  protective  actions,  criteria  for  introducing 
protective actions, triggers values, operational criteria, and methods for assessing source terms may 
differ (Figure 3). 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Multiple  MS  may  be  found  within  the  Emergency  Planning  Zone  (EPZ)  around  nuclear  facilities. 
Several  MS  will  have jurisdictional  authority within  the  EPZ  and  these  separate  entities will  control 
their own emergency response organizations and resources. In multi-country situations, compatible 
response  should  be  ensured.  An  integrated  multi-country  level  emergency  response  plan  may  be 
even preferable. The response organizations and resources of the MS can be integrated - by mutual 
agreement - into the overall multi-country emergency response plan. 

Emergency planning has evolved in all states over many years, mostly without giving great priority to 
cross-border issues. Should a nuclear emergency occur in Europe, these differences can potentially 
have a significant effect, especially if the emergency occurs close to a national border and because 
not all MS considered the transposition and implementation plans and strategies in the neighbouring 
EU countries for the development of their own national plans and strategies.  

A

B

C

D

DRAFT 
Figure 3: Possible Implementation of Protective Actions. Source: Status of the work of HERCA and 
WENRA on EP&R | WS on EP&R in the Euratom-BSS, Brussels, 15-16.11.16 | Georges Piller. 

Dedicated  working  groups  have  proposed  guidance  for  cross-border  nuclear  or  radiological 
emergencies, notably the HERCA [HERCA, 2014]. For that reason, the work of HERCA is presented in 
section 8 and will be considered for non-binding guidelines at the EU level in the present report. 

The  lack of  harmonisation of  EP&R measures  is  seen by  some  stakeholders as  a  major  issue  for  an 
integrated response in case of a nuclear accident affecting neighbouring countries. The BSS Directive 
gives a chance for the implementation of compatible criteria for protective actions and planning. The 
HERCA  association  promotes  comparable  protection  level  of  the  populations  on  each  side  of  the 
border and the alignment of protective actions along borders [HERCA, 2015]. 

However,  while  the  harmonization  of  the  approaches  may  facilitate  the  integrated  and  efficient 
management  of  cross-border  emergency  situations,  it  is  the  compatibility  of  the  approaches  that 
should,  at  least,  be  ensured.  Compatible  arrangements  for  EP&R  should  be  ensured  between 
neighbouring  MS  for  cross-border  events,  in  particular  for  both  the  early  phase  after  a  severe 
accident (within some hours) and for the intermediate period, because relatively shorter times may 
be available to implement immediate protective actions. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

5  ICRP  and  IAEA  standards  and  recommendations  pertaining  to 

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EP&R 

5.1  ICRP Publications 

The main publications of the ICRP pertaining to EP&R are: 

• 

• 

• 

ICRP 103. The 2007 Recommendations of the International Commission on Radiological 
Protection. ICRP Publication 103. Ann. ICRP 37 (2-4). 
ICRP 109. Application of the Commission's Recommendations for the Protection of People in 
Emergency Exposure Situations. ICRP Publication 109. Ann. ICRP 39 (1). 
ICRP 111. Application of the Commission's Recommendations to the Protection of People 
Living in Long-term Contaminated Areas after a Nuclear Accident or a Radiation Emergency. 
ICRP Publication 111. Ann. ICRP 39 (3). 

5.2  IAEA Safety Standards and technical guidance 

The  EP&R  Safety  Standards  and  technical  guidance  that  are  available  or  under  development  at the 
IAEA  are  listed  below.  Those  that  are  published  are  available  on  the  IAEA  website  (hyperlinks  are 
provided  below).  For  those  that  are  under  development,  an  overview  of  their  intended  objectives 
and timelines for completion is given: 

5.2.1  Safety Standards  

DRAFT 

Published standards are available at https://www-ns.iaea.org/tech-areas/emergency/e-
standards.asp?s=1. 

•  Preparedness and Response for a Nuclear or Radiological Emergency, IAEA Safety Standards 

Series No. GSR Part 7, IAEA, Vienna (2015). 

GSR-Part 7 is relatively new and some time should be given to the States to adapt their EP&R 
plans. IAEA follow the implementation of GSR Part 7 (e.g. dedicated workshop 11/2015). 

•  Arrangements for Preparedness for a Nuclear or Radiological Emergency, IAEA Safety 
Standards Series No. GS-G-2.1, IAEA, Vienna (2007) (revision to be initiated in 2017). 

•  Criteria for Use in Preparedness and Response for a Nuclear or Radiological Emergency, IAEA 

Safety Standards Series No. GSG-2, IAEA, Vienna (2011). 

Those under development are: 

•  Arrangements for the Termination of a Nuclear or Radiological Emergency (DS474). 

Recommendations  and  guidance  on  arrangements  for  termination  of  a  nuclear  or 
radiological emergency and subsequent transition to new exposure situation (either planned 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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or  existing)  including  primary  objective  of  termination  and  prerequisites  to  be  met  during 
transition phase. Expected completion: end of 2017, to be published 2018. 

•  Arrangements for Communications with the Public in Preparedness and Response for a 

Nuclear or Radiological Emergency (DS475) 

in  emergency 
Recommendations  and  guidance  on  communicating  with  the  public 
preparedness  and  response  taking  into  account  some  particular  circumstances  (e.g. 
coincident  emergencies,  emergencies  triggered  by  a  nuclear  security  event,  transition 
phase). Expected completion: 2018, to be published 2019. 

•  Preparedness and Response for an Emergency during the Transport of Radioactive Material 

(Revision of TS-G-1.2 issued in 2002) 

Guidance  and  recommendations  on  the  implementation  of  the  requirements  established 
primarily in GSR Part 7 and SSR 6 “Regulations for the Safe Transport of Radioactive Material” 
2012 in order to prepare for and respond to emergencies during the transport of radioactive 
material. Expected completion: end of 2019, to be published 2020. 

5.2.2  Technical Guidance  

These series are intended to support application of EP&R Safety Standards by: 

•  Providing further technical guidance and tools to support the establishment of effective and 
efficient emergency arrangements by Member States consistently with Safety Standards; 
•  Providing material to be used for training purposes at the international and regional levels or 
as a basis for development of training materials at national level in various areas of EP&R. 

DRAFT 

Published  
(Available at: https://www-ns.iaea.org/tech-areas/emergency/technicalproducts.asp?s=1&l=1) 

EPR-Lessons Learned  Lessons Learned from the Response to Radiation Emergencies 

2012 

EPR-Embarking 

EPR-Exercise 

EPR-Method 

EPR-D-values 
TECDOC-1432 

EPR-First 
Responders 
EPR-NPP Public 
Protective Actions 
EPR-Research 
Reactor 

(1945-2010) 
Considerations in Emergency Preparedness and Response for a 
State Embarking on a Nuclear Power Programme 
Preparation, Conduct and Evaluation of Exercises to Test 
Preparedness for a Nuclear or Radiological Emergency 
Method for Developing Arrangements for Response to a Nuclear 
or Radiological Emergency - updating IAEA-TECDOC-953 
Dangerous quantities of radioactive material 
Development of an Extended Framework for Emergency 
Response Criteria: Interim Report for Comments 
Manual for First Responders to a Radiological Emergency 

Actions to Protect the Public in an Emergency due to Severe 
Conditions at a Light Water Reactor 
Generic Procedures for Response to a Nuclear or Radiological 
Emergency at Research Reactors 

2012 

2005 

2003 

2006 
2005 

2006 

2013 

2011 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
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EPR-TRIGA-Research 
Reactor 
TECDOC 955 

TECDOC-1092 

TECDOC 1162 

EPR-Medical 

EPR-Biodosimetry 

EPR-Public 
Communications 
EPR-Communication 
Plan 
EPR-NPP OILs 

Under development: 

Generic Procedures for Response to a Nuclear or Radiological 
Emergency at TRIGA Research Reactors 
Generic assessment procedures for determining protective 
actions during a reactor accident 
Generic procedures for monitoring in a nuclear or radiological 
emergency 
Generic procedures for assessment and response during a 
radiological emergency 
Generic Procedures for Medical Response during a Nuclear or 
Radiological Emergency 
Cytogenetic Dosimetry: Applications in Preparedness for and 
Response to Radiation Emergencies 
Communication with the Public in a Nuclear or Radiological 
Emergency 
Method for Developing a Communication Strategy and Plan for a 
Nuclear or Radiological Emergency 
Operational Intervention Levels for Reactor Emergencies and 
methodology for their derivation 

2011 

1997 

1999 

2000 

2005 

2011 

2012 

2015 

2017 

•  Considerations  in  the  Development  of  a  Protection  Strategy  for  a  Nuclear  or  Radiological 
Emergency (EPR-Protection Strategy) - Expected completion: end of 2017, to be published in 
2018. 

The objectives are: 

DRAFT 

o  To provide Member States with practical guidance and a stepwise approach for 
the development, justification and optimization of a protection strategy and for 
the  implementation  of  reference  levels  and  generic  criteria  as  dosimetric 
concepts; 

o  To  elaborate  in  more  detail  on  the  different  factors  to  be  considered  by  the 
responsible  authorities  in  a  State  at  the  national  level  and  on  the  data  and 
information necessary to support the development of a justified and optimized 
protection strategy; 

o  To  provide  examples  of  protection  strategies  for  a  postulated  nuclear  or 
radiological  emergency  for  the  five  emergency  preparedness  categories 
introduced in IAEA safety standards. 

•  Preparedness  for  and  response  to  a  nuclear  or  radiological  emergency  occurring  in 
combination  with  a  disaster  caused  by  an  extreme  natural  event  (EPR-Combined 
Emergencies) - Expected completion: end of 2017, to be published in 2018. 

The objectives are: 

o  To  provide  practical  considerations  for  application  of  GSR  Part  7  and  its 
supporting  guides  to  nuclear  or  radiological  emergencies  occurring 
in 
combination with a disaster caused by an extreme natural events; 

o  To  assist  States  prone  to  extreme  natural  events  on  developing  arrangements 
needed to establish effective capabilities at all levels (national, regional, local and 

  
 
 
 
 
 
 
 
 
 
 
 
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facility) for responding to a radiation emergency occurring in combination with a 
disaster caused by an extreme natural event. 

•  Considerations  in  Emergency  Preparedness  and  Response  Arrangements  for  an  Operating 
Organization (EPR-NPP Onsite) - Expected completion: 2017, to be published 2017/2018. 

The objectives are: 

o  To  systematically  addresses  how  EP&R  requirements  could  apply  to  operating 

organizations; 

o  To provides practical guidance on how operating organizations could meet those 

requirements. 

•  Operational  Intervention  Levels  for  Radiological  Emergencies  and  methodology  for  their 
derivation (EPR-RAD OILs) - Expected completion: end of 2017, to be published in 2018 

The objectives are to provide Member States with: 

o  Default OIL values that can be used immediately in the response to a radiological 

emergency; 

o  A detailed explanation of the methodology for deriving the default OIL values;  
o  Practical tools and recommendations on how to use the OILs;  
o  Considerations for revising the default OIL values. 

DRAFT 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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6  Transposition status of the EP&R provisions of the BSS Directive by 

the 10 selected MS 

An  assessment  of  the  transposition  status  was  already  performed  by  RiskAudit  [RISKAUDIT,  2016]. 
The main findings were that:  

•  Overall  most  countries  did  not  consider  there  are  major  difficulties  in  transposing  the 

requirements; 

•  The transposition process was still subject to internal decision processes in some countries; 
• 

In general, fewer transposition issues were reported in connection with the transposition of 
Articles 69 (emergency response) and Article 70/71 (public information), than with Article 7 
(reference levels) and Article 17 (prior information and training for emergency workers); 
•  Articles  98(3)  and  99(4)  (transition  to  existing  exposure  situation)  were  identified  as 

challenging issues. 

An  overall  overview  of  the  level  of  difficulty  for  the  transposition  of  the  requirements  of  the  BSS 
Directive on EP&R is provided on Figure 4 [RISKAUDIT, 2016]. 

DRAFT 

Figure  4:  Answers  to  the  RiskAudit  question  “Do  you  see  any  difficulties  in  transposing  the 
requirements?” [RiskAudit, 2016] 

Answers  to  question  1  of the  questionnaire  (Annex 1)  give  an  update  of  the  status  of  the  national 
progress for the transposition of those provisions of the BSS Directive relevant to EP&R. According to 
their declaration, the 10 MS claim to be on schedule with the enactment of EP&R arrangements in 
line  with  the  BSS  Directive  in  the  national  legislative  basis  (Act,  Law,  Regulation,  Administrative 
Provision, etc.). No assessment has been made of the transposition of the new requirements of the 
BSS Directive. 

Beyond  the  transposition,  it  is  the  effective  implementation  of  the  BSS  Directive  that  should  be 
ensured. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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7  Need for guidelines or recommendations 

For the implementation phase of the BSS Directive, the development of “implementation guidelines” 
(in the form of non-binding guidelines, recommendations or codes of good-practice) at the EU level 
could be considered to help the practical implementation of the legal provisions and to facilitate the 
coherent and consistent implementation of the provisions on EP&R amongst MS. 

The  need  for  guidelines  or  recommendations  for  the  transposition  and  the  implementation  of  the 
BSS provisions on EP&R was evaluated in previous studies [ENCO, 2013], [RISKAUDIT, 2016]. It was 
re-evaluated in the frame of the present study, as documented in Annex 1.  

The 10 MS had to assess the need of guidance based on their experience of national transposition 
and  implementation  plans  and  strategies  for  the  BSS  Directive,  providing  a  rate  between  1  to  3 
(1=most useful, 2=moderately useful, 3=least useful) for the following topics: 

a.  Assessment  of  potential  emergency  exposure  situations  and  associated  public  and 

emergency occupational exposures 
b.  Health protection of emergency workers 
c.  Prior information and training for emergency workers and all other persons with duties and 

d. 

responsibilities in emergency response 
Information  to  the  public  (likely  to  be  affected  or  actually  affected  in  the  event  of  an 
emergency) 
Involvement of stakeholders 

e. 
f.  Transition from an emergency exposure situation to an existing exposure situation including 

recovery and remediation 

DRAFT 

g.  Reference levels for public exposure 
h.  Reference levels for emergency occupational exposure 
i.  Protection strategies for the public and optimisation approaches 
j.  Generic  criteria  for  particular  protective  measures,  default  triggers,  operational  criteria  for 

particular actions 
International cooperation 

k. 

The answers of the 10 MS are summarised below. 

  
 
 
 
 
 
 
 
 
 
 
 
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Table 1: Need for guidance expressed by the 10 MS 

Topic 

MS Rating 
(1= most relevant,2 or 3=least relevant) 

Average  Standard 
deviation 

a. 

b. 

c. 

d. 

e. 

f. 

g. 

h. 

i. 

j. 

k. 

1 

2 

2 

1 

1 

1 

1 

2 

1 

1 

1 

3 

3 

3 

3 

2 

1 

1 

2 

2 

1 

2 

1 

1 

1 

3 

3 

1 

1 

1 

1 

1 

2 

2 

3 

2 

2 

3 

1 

3 

3 

2 

2 

2 

2 

3 

3 

2 

1 

1 

1 

1 

1 

2 

3 

1 

2 

1 

2 

3 

2 

1 

1 

2 

1 

3 

2 

3 

3 

2 

1/2 

3 

2 

3 

2 

2 

3 

3 

1 

2 

2 

1 

1 

3 

1 

2 

1 

1 

1 

3 

3 

3 

2 

1 

1 

1 

1 

2 

3 

3 

2 

2 

1 

2 

1 

3 

3 

2 

2 

2 

1.9 

2.3 

2.2 

2.1 

1.85 

1.3 

1.7 

1.8 

1.6 

1.5 

2.2 

0.9 

0.8 

0.8 

0.7 

0.9 

0.7 

0.9 

0.9 

0.5 

0.5 

0.8 

There  is  a  large  variation  of  the  needs  expressed  by  the  10  MS  for  guidance.  This  reflects  in  some 
cases the advancement of the 10 MS with the implementation of the provisions of the BSS Directive 
on  EP&R.  However,  topics  for  which  non-binding  guidelines  or  recommendations  would  be 
welcomed are listed below according to the importance of the need expressed by the 10 selected MS 
(average of  the  scores  for each  topic),  starting  with guidelines  felt  most  useful.  It  should  be  added 
that  one  response  indicated  that  there  was  sufficient  guidance  available  internationally  and  there 
DRAFT 
was no need to develop anything at the EU level. 

Guidance 
most useful 

1.  Transition  from  an  emergency  exposure  situation  to  an  existing  exposure 

situation including recovery and remediation 

2.  Generic  criteria  for  particular  protective  measures,  default  triggers, 

operational criteria for particular actions 

3.  Protection strategies for the public and optimisation approaches 
4.  Reference levels for public exposure 
5. 
6.  Reference levels for emergency occupational exposure 
7.  Assessment  of  potential  emergency  exposure  situations  and  associated 

Involvement of stakeholders 

8. 

public and emergency occupational exposures 
Information  to  the  public  (likely  to  be  affected  or  actually  affected  in  the 
event of an emergency) 

9.  Prior information and training for emergency workers and all other persons 

with duties and responsibilities in emergency response 

10. International cooperation 
11. Health protection of emergency workers 

Guidance 
least useful 

Each of these topics is discussed in section 9.  

Other  topics  for  which  questions  were  raised,  a  need  for  guidance  was  identified,  or  a  need  for 
additional analysis was mentioned during the Workshop organized on 15-16 November 2016 include: 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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•  How to conduct a thyroid monitoring program after an emergency? 
•  What strategy for the use of face masks/respiratory protection? 
•  How to evaluate the source term (a kind of realistic worst-case) and define scenarios at the 

preparedness stage? 

•  To which extent do the MS intend to implement IAEA standards? Could EU guidance be more 

specific than available international standards and recommendations? 

•  How quickly do people shelter or evacuate?  
•  Should evacuation under the plume be conducted (which is not recommended in the HERCA-

WENRA approach)? 

•  How to assess non-radiological consequences of nuclear and radiological emergencies? 
•  What to do with contaminated rubble/waste? 

For some of the above listed topics, discussions are on-going at the IAEA. Involvement of EU MS's in 
these discussions should be encouraged to avoid duplication of work. The IAEA standards approval 
system  allows  comments  from  the  MS.  The  EU,  as  an  observer,  can  also  make  comments.  A 
suggestion  was  made  to  coordinate  the  response  of  the  EU  to  the  IAEA  proposals.  The  European 
Commission  could  coordinate  to  provide  a  common  EU-level  reaction  for  future  IAEA  documents, 
separately from national responses. 

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8  The HERCA working groups on EP&R
working groups on EP&R 

The  Council  Conclusions  on  EP&R  recognizes  the  work  carried  by  HERCA  and  WENRA  to  improve 
The  Council  Conclusions  on  EP&R  recognizes  the  work  carried  by  HERCA  and  WENRA  to  improve 
The  Council  Conclusions  on  EP&R  recognizes  the  work  carried  by  HERCA  and  WENRA  to  improve 
cross-border approaches. 

HERCA and WENRA have developed and agreed on an approach to further improve the response and 
developed and agreed on an approach to further improve the response and 
developed and agreed on an approach to further improve the response and 
border coordination for all types of possible accident scenarios including severe accidents, like 
border coordination for all types of possible accident scenarios including severe accidents, like 
cross-border coordination for all types of possible accident scenarios including severe accidents, like 
the one in Fukushima. It contains overarching principles and provides an incentive for joint actions 
overarching principles and provides an incentive for joint actions 
the one in Fukushima. It contains
gives  an  overview  of  the  progress  made 
between  neighbouring  countries  [HERCA,  2014].
between  neighbouring  countries  [HERCA,  2014].  Figure  5  gives  an  overview  of  the  pr
with the implementation of the HERCA-WENRA Approach. 
with the implementation of the HERCA

DRAFT 

Status of the work of HERCA 
: Implementation Status ENSREG Quick Survey 2016. Source: Status of the work of HERCA 

Figure 5: Implementation Status ENSREG Quick Survey 2016. Source
and WENRA on EP&R - WS on EP&R in the Euratom

WS on EP&R in the Euratom-BSS, Brussels, 15-16.11.16,by

,by Georges Piller. 

HERCA and WENRA consider that in Europe:  
HERCA and WENRA consider that in Europe: 

•  a general strategy should be defined in order to be able to extend 

•  evacuation should be prepared up to 5 km around nuclear power plants, and sheltering and 
evacuation should be prepared up to 5 km around nuclear power plants, and sheltering and 
evacuation should be prepared up to 5 km around nuclear power plants, and sheltering and 
ITB up to 20 km;  
a general strategy should be defined in order to be able to extend evacuation up to 20 km 
evacuation up to 20 km 
(think  in  advance  on  what  should  be  done  if  the 
and  sheltering  and  ITB  up  to  100  km  (think  in  advance  on  what  should  be  done  if  the 
and  sheltering  and  ITB  up  to  100  km
extension of protective action distances is needed);  
extension of protective action distances is needed)
•  nuclear  and  radiation  safety  authorities  in  Europe  should  continue  attempts  to  promote 
nuclear  and  radiation  safety  authorities  in  Europe  should  continue  attempts  to  promote 
nuclear  and  radiation  safety  authorities  in  Europe  should  continue  attempts  to  promote 
le  response  arrangements  and  protection  strategies  amongst  the  European 
le  response  arrangements  and  protection  strategies  amongst  the  European 
compatible  response  arrangements  and  protection  strategies  amongst  the  European 
countries.  

The HERCA-WENRA Approach promotes the principle of “We do the same as the accident country” in 
WENRA Approach promotes the principle of “We do the same as the accident country” in 
WENRA Approach promotes the principle of “We do the same as the accident country” in 
s  with  different  generic 
the  first  hours  of  the  accident.  This  principle  can  be  an  issue  for  countrie
the  first  hours  of  the  accident.  This  principle  can  be  an  issue  for  countries  with  different  generic 
criteria, trigger values and operational criteria.  
criteria, trigger values and operational criteria.

  
 
 
 
 
 
 
 
 
 
 
 
 
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The majority of the 10 MS to which the questionnaire was sent have considered or intend to consider 
the  HERCA-WENRA  Approach  in  their  implementation  plans  and  strategies.  However,  the  HERCA-
WENRA  position  seems  to  be  currently  shared  only  by  radiation  protection  and  safety  authorities. 
There is a need to engage discussion with the national authorities in charge of civil protection. 

HERCA and WENRA organized a workshop on the implementation of the HERCA-WENRA Approach, in 
Bled,  Slovenia  on  13-15  June  2016.  The  aim  of  this  workshop  was  to  discuss  operational  and 
pragmatic means to implement the HERCA-WENRA Approach with the key actors involved in nuclear 
emergency  planning  and  response  and  therewith  contribute  to  an  enhanced  protection  of  the 
population,  particularly  in  a  cross-border  context.  One  major  issue  which  was  highlighted  is  the 
alignment of planning zones and the alignment of protective actions during response: 

•  The  first  level  of  preparation  (Evacuation  up  to  5  km,  sheltering  and  ITB  up  to  20  km)  is 

implemented or at least considered in most countries. 

•  The second level of preparation (Extension of evacuation up to 20 km, sheltering and ITB up 
to  100  km)  is  fully/partially  implemented  or  agreed  by  most  countries  which  submitted 
relevant information. 

•  Some  countries  expressed  difficulties  in  extending  the  radius  for  the  implementation  of 

protective actions.  

Another issue coming out of the workshop is related to the need to better engage with national civil 
protection competent authorities. 

The proposed “general strategy” for evacuation up to 20 km and for sheltering and ITB up to 100 km 
needs very careful and critical consideration. Implementing urgent countermeasures in an area very 
DRAFT 
far from the NPP could provoke panic and cause more harm than benefit. 

Depending  on  their  design,  different  reactors  and  nuclear  facilities  present  different  radiological 
risks, e.g. some reactors have a double containment compared to single containment reactors. The 
distance  for  evacuation  in  function  of  the  design  was  questioned.  The  HERCA-WENRA  Approach 
avoids  differentiating  between  reactor  technologies  in  order  to  find  a  consensus  on  the  response 
strategy. 

In  2011,  the  HERCA  association  has  established  a  working  group  on  emergencies  which  currently 
aims at supporting the HWA principles and implementing it in an efficient manner in the MS. At the 
end of April 2016, HERCA Board approved a tracking system set up by the HERCA Working Group on 
Emergencies for following the implementation of the approach. 

Since  the  publication  of  [HERCA,  2014],  HERCA  has  published  other  documents  that  could  serve  as 
basis for the implementations of the provisions of the BSS Directive on EP&R: 

•  Guidance  for  Bilateral  Arrangements  [HERCA,  2015a].  This  new  guidance  supports  the 
implementation of  the “HERCA-WENRA  Approach  for  a  better cross-border coordination of 
protective  actions  during  the  response  in  the  early  phase  of  a  nuclear  accident”.  Bilateral 
arrangements are understood as an integrated set of agreed elements between the parties 
adhering  to  the  bilateral  arrangements.  These  elements  may  include  an  agreement, 
procedures, protocols and other documents. This new guidance is based on the following key 
statements: 

o  The parties commit to coordinate actions taken in response. 
o  The parties will aim at the alignment of protective actions along borders. 

  
 
 
 
 
 
 
 
 
 
 
 
 
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o  The parties will consider the whole affected area, independent of a national border, 

when making decisions. 

o  The parties will consider the emergency situation over time (early and later phase). 
o  The parties will define a clear attribution of responsibilities (e.g. for coordination, for 

decision taking 

•  The  document  “Common  understanding  of  the  provisions  related  to  emergency  workers.” 
The  document  identifies  a  rich  variation  in  interpretations,  although  there  is  general 
agreement  for  the  most  important  roles.  Wherever  differences  are  found,  the  bilateral 
impact  is  deemed  to  be  marginal  at  worst.  Therefore,  no  need  for  harmonisation  with 
respect to the concept of Emergency Workers is identified. 

HERCA  intends  to  finalise  the  first  version  of  “Country  fact-sheets”  on  national  EP&R  for  nearly  all 
countries  within  2016.  Those  fact-sheets  summarise  for  most  cases  on  2  pages  the  most  relevant 
issues  related  to  EP&R  of  the  individual  country  and  could  be  used  by  authorities  in  charge  of 
emergencies. MS has to take the initiative and can decide to make the information available or not, 
including upload to the IAEA EPRIMS system.  

The HERCA highlighted that while the scientific problem of finding appropriate dose criteria for the 
contamination  of  non-food  product  is  probably  solved,  the  regulatory  issue  for  transport  of  such 
products persists [HERCA, 2015c]. 

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9  Discussion on the topics related to EP&R of the BSS Directive 

In this section, each topic listed in section 7 is discussed on basis of the answers provided by the 10 
MS,  the  outcomes  of  the  Workshop  organized  on  15-16  November  2016,  the  ENCO  study  [ENCO, 
2013] and the work performed by RISKAUDIT [RISKAUDIT, 2016]. 

For each topic, issues that need to be further addressed for the implementation of the BSS Directive 
are presented. A first assessment is provided on whether available international guidance is sufficient 
for the implementation of the provisions of the BSS Directive. Where applicable, good-practices are 
recommended.  Good-practices  can  serve  as  examples  for  the  implementation  of  the  BSS  Directive 
provisions. 

Some  preliminary  guidance  or  recommendations  are  made  for  each  topic;  they  are  summarized  in 
section 10. The topics are listed in the order of importance as identified in section 7. 

In  the  following  discussion,  it  is  important  to  acknowledge  that when  comparing  the  guidance  and 
recommendations produced at the international or regional levels such as in IAEA Safety Standards 
or Safety Requirements, that there are some differences in concepts, terminology, guidance values 
or reference levels compared to the BSS Directive or other EU legislation. Such differences need to be 
carefully  interpreted  and  assessed  in  individual  cases,  ensuring  that  the  requirements  of  the  EU 
legislation are always met. 

9.1  Transition  from  an  emergency  exposure  situation  to  an  existing 
DRAFT 

exposure situation including recovery and remediation 

The transition from an emergency exposure situation to an existing exposure situation is seen as a 
major  concern  for  which  recommendations  would  be  welcomed  by  most  of  the  MS  to  which  the 
questionnaire was addressed. 

9.1.1 

Issues to be further addressed 

The  most  significant  gap  in  arrangements  already  identified  in  [ENCO,  2013]  “concerned  a  general 
lack  of  strategies  and  arrangements  for  longer  term  protective  measures  and  for  the  return  to 
normality  following  an  emergency.  These  issues  were  problematic  for  many  years  in  the  Former 
Soviet  Union  in  managing  the  aftermath  of  the  Chernobyl  accident  and  similar  problems  are  being 
encountered  in  Japan  post-Fukushima.  There  was  also  in  many  countries  an  absence  of  strategies 
and  arrangements  for  the  management  of  the  large  quantities  of  radioactive  waste  that  might  be 
generated, particularly from the contamination of foodstuffs but also from possible remediation of 
the  built  environment.  A  major  contributory  factor  in  these  gaps  is  that  criteria  for  longer  term 
protective measures are far less mature than those for urgent measures, with frequent changes to 
relevant  international  standards  and  recommendations  over  the  past  two  decades  and  a  lack  of 
broad consensus. The issue is complex, particularly as guidance and criteria need to be applicable to 
the  very  wide  range  of  circumstances  that  might  arise  in  practice.  Some  countries  prefer  the 
adoption of outline, flexible arrangements that can be adapted to the prevailing situation.” 

The  document  [RISKAUDIT,  2016]  identified  a  need  for  further  clarification  and  guidelines  on  the 
transition from an emergency exposure situation to an existing exposure situation as follows: 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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•  Criteria for lifting protective actions. 
•  Guidelines to obtain a harmonised transition from emergency to existing exposure situation. 
This item is important considering the possible large scale (i.e. several countries) of nuclear 
emergencies. 

•  Publish and discuss the adopted criteria for transition with other countries. 
•  Bilateral agreements or arrangements have to be extended. 

9.1.2  Available international guidance 

Some  guidelines  for  the  transition  from  an  emergency  exposure  situation  to  an  existing  exposure 
situation are available in ICRP 107, ICRP 109 and ICRP 111. 

The IAEA is currently preparing a new Safety Guide (DS474) on the arrangements for the termination 
of  a  nuclear  or  radiological  emergency.  The  IAEA  DS474  intends  to  help  eliminate  the  lack  of 
guidance  that  exists  in  this  area  by  providing  guidance  and  recommendations  on  emergency 
arrangements for the termination of an emergency and the subsequent transition to either a planned 
exposure  situation  or  an  existing  exposure  situation  for  meeting  the  relevant  safety  requirements 
established in IAEA GSR Part 7. The IAEA DS documents are only considered as working drafts in the 
present document as they could still change before they are finally adopted. 

Once  finalised,  this  new  safety  guide  could  serve  as  basis  for  a  coherent  implementation  of  the 
requirements  of  the  BSS  Directive  on  the  transition  from  an  emergency  exposure  situation  to  an 
existing exposure situation at the EU level: 

DRAFT 

• 

• 

It  intends  to  provide  guidance  on  how  to  include  provision  for  the  transition  from  an 
emergency  exposure  situation  to  an  existing  exposure  situation  in  an  emergency  response 
plan (Art. 98 & Annex XI of the BSS Directive): the section 4 of IAEA DS474 provides detailed 
guidance  on  the  aspects  to  be  addressed  at  the  preparedness  stage  when  establishing 
arrangements for the transition phase of a nuclear or radiological emergency. 
It  intends  to  provide  guidance  on  how  to  define  appropriate  references  levels  for  the 
transition from an emergency exposure situation to an existing exposure situation (Annex I of 
the BSS Directive) in §4.53 to 4.62, as well as guidance for lifting or adapting specific actions 
(e.g. in §4.85 for relocation). 

The Annex I of the IAEA DS474 provides case studies of the emergency response to: the Fukushima 
Daiichi  accident  (2011),  the  radiological  accident  in  Goiânia,  Brazil  (1987),  the  Paks  fuel  damage 
incident  in  Hungary  (2003)  and  the  incident  involving  a  stolen  radioactive  source  in  Hueypoxtla, 
Mexico  (2013).  They  briefly  cover  the  management  of  the  incidents  and  accidents  and  their 
consequences, from the declaration of emergency to the period of preparation for dealing with the 
recovery aspects and with the long-term consequences under a different exposure situation. 

The IAEA DS474 seems to be a good basis to implement the relevant provisions of the BSS Directive. 
However, it does not address the long term issues. Long term issues are covered in IAEA documents 
on  remediation,  e.g.  the  IAEA  DS468:  Remediation  Process  for  Areas  with  Residual  Radioactive 
Materials from Past Activities and Accidents (Revision of IAEA Safety Standard Series No. WS-G-3.1). 

  
 
 
 
 
 
 
 
 
 
 
 
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9.1.3  Preliminary guidance or recommendations 

MS are invited to analyze in detail the IAEA DS474. The DS474 is in its final review and it is too late to 
have  a  common  EU  response  to  the  proposal  (however,  EU  Member  States  have  been  actively 
engaged in its development and its review).  

It  is  difficult  to  make  detailed  arrangements  for  the  termination  of  a  nuclear  emergency  at  the 
planning  stage  due  to  the  large  number  of  possible  scenarios  to  be  considered.  At  least,  the 
responsible  organizations  for  the  transition  from  an  emergency  exposure  situation  to  an  existing 
exposure situation should be identified in advance and generic principles for the management of the 
transition should be defined. Identifying the responsible bodies is obviously a national responsibility. 
Generic principles are well defined in DS474. 

The  management  of  large  quantities  of  radioactive  waste  that  might  be  produced  in  case  of  an 
emergency is not the only topic for which further guidance would be welcomed but was identified by 
some  MS  as  a  main  concern.  There  is  a  need  to  identify  which  measures  and  decontamination 
strategies  are 
important  or  necessary  to  reduce  the  doses.  The  pertinence  of  systematic 
decontamination has been questioned. It may be preferable to leave contamination where it stands. 
However, contamination can migrate. Agreement may be needed on the acceptable contamination 
levels in case of an emergency. Some research is deemed necessary on this topic. Radioactive waste 
clearance  levels  in  case  of  an  emergency  could  be  raised  to  reduce  the  amount.  This  should  be 
agreed upon at the EU level. Provisions for storage and trans-boundary transport of waste is needed. 
DRAFT 
Guidance  on  the  management  of  large  quantities  of  radioactive  waste  produced  in  an  emergency 
may be found in Section IV of IAEA DS474. 

The social aspect of the transition shall be also be addressed. Some guidance may be found in IAEA 
DS474.  Citizens should be given some freedom to decide on their own. 

In  2005,  the  French  Nuclear  safety  authority  (Autorité  de  Sûreté  Nucléaire  -  ASN)  established  a 
Steering  committee  for  the  management  of  the  post-accident  phase  of  a  nuclear  accident  or  a 
radiological emergency (CODIRPA), at the request of the Government. This process involves a large 
number  of  stakeholders  affected  by  post-accident  management:  the  public  authorities,  operators, 
associations, experts, etc.  

The policy elements prepared by CODIRPA were drafted with regard to nuclear accidents of medium 
scale causing short-term radioactive release (less than 24 hours) that might occur at French nuclear 
facilities (for which an off-site emergency plan exists). They also apply to actions to be carried out in 
the  event  of  accidents  during  the  transport  of  radioactive  materials.  Following  definitions  of  each 
stage  of  a  nuclear  accident,  [ASN,  2012]  lists  the  principles  selected  by  CODIRPA  to  support 
management  efforts  subsequent  to  a  nuclear  accident.  Then,  it  presents  the  main  actions  to  be 
implemented  or  started  from  the  exit  from  the  emergency  phase  as  well  as  the  guidelines  for 
managing  the  transition  and  long-term  periods.  Three  appendices  have  been  included,  showing  in 
detail  the  actions to  be taken over  the  three  successive stages  formed  by  the exit  period  from the 
emergency phase and the transition and long-term periods. 

  
 
 
 
 
 
 
 
 
 
 
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The ongoing work performed by CODIRPA could be used as an example of good practices in the EU 
for  the  transition  from  an  emergency  exposure  situation  to  an  existing  exposure  situation.  The 
CODIRPA  approach  is  compatible  with  the  generic  principles  of  IAEA  DS474.  It  does  not  focus  on 
specific  issues.  The  CODIRPA  approach  was  recognized  during  the  Workshop  organized  on  15-16 
November  2016  as  a  good  example  by  some  MS.  However,  the  CODIRPA  approach  does  not 
sufficiently  address  neighboring  countries.  The  CODIRPA  approach  will  be  revised  (continuous 
improvement). 

9.2  Generic  criteria  for  particular  protective  measures,  default  triggers, 

operational criteria for particular actions 

The  BSS  Directive  provides  an  upper  value  of  the  reference  levels  for  emergency  and  existing 
exposure situations. The BSS Directive does not provide values for generic criteria, defaults triggers 
or operational criteria. A constrained (maximal values of the reference levels) optimization process 
should be applied for the selection of appropriate reference levels and the definition of criteria for 
protective actions.  

9.2.1 

Issues to be further addressed  

As result of the application of this optimization process, differences between the values for generic 
criteria, default triggers or operational criteria can appear between the MS or within a MS in function 
of  the  emergency  situation  to  be  considered.  Differences  between  MS  or  within  a  MS  for  specific 
situations  might  be  justified  from  a  technical  point  of  view.  However,  compatible  response 
DRAFT 
arrangements  between  MS  in  case  of  cross-border  events  are  desirable,  even  if  not  explicitly 
required in the BSS Directive. 

Once the protection strategy has been optimized and a set of generic criteria has been developed, 
default  triggers  and  operational  criteria  should  be  derived  from  the  generic  criteria.  Where  urgent 
action is required to reduce exposures, it may be necessary to commit resources in advance of the 
emergency  situation,  and  to  use  easily  identifiable  triggers  as  the  basis  for  decisions  to  implement 
the  options,  in  order  to  ensure  they  are  completed  within  the  necessary  timescales.  Operational 
criteria are quantities or observables that include operational intervention levels, emergency action 
levels,  specific  observables  and  other  indicators  of  conditions  on  the  scene  that  should  be  used  in 
decision making. If the numerical values of the generic criteria are expected to be exceeded, those 
actions, either individually or in combination, should be implemented. 

9.2.2  Available international guidance 

The  IAEA  GSR  Part  7  requires  the  development of  emergency  response  plan, of  generic criteria  for 
taking protective actions and other response actions, based on the outcome of the justification and 
the optimization of the protection strategy. Some guidance to define generic criteria for protective 
actions  in  the  event  of  a  nuclear  or  radiological  emergency,  as  well  as  values  for  these  criteria  are 
provided  in  Appendix  II  of  IAEA  GSR  Part  7.  The  values  are  generically  justified  and  optimized  on 
radiation protection grounds and do not consider national or local circumstances. 

Protective actions in the emergency planning zones around nuclear facilities will, in the early phase, 
be implemented primarily based on predefined triggers (e.g. plant status, emergency action levels). 

  
 
 
 
 
 
 
 
 
 
 
 
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Other actions will be implemented on basis of operational intervention levels or other criteria. These 
levels may be indicative: it may be appropriate to carry out actions at higher or lower levels. 

The  IAEA  Safety  Guide  GSG-2  addresses  the  criteria  for  initiating  protective  actions  and  other 
response  actions  and  criteria  to  support  decision  making  in  an  emergency.  Examples  of  default 
operational criteria for implementing protective actions and other response actions and guidance on 
the  use  of  the  operational  intervention  levels  are  also  provided.  The  method  used  for  the 
development of operational criteria is described only in general terms. 

As  the  IAEA  proposes  values  in  dedicated  publications  (e.g.  IAEA  GSR  Part  7  and  IAEA  GSG-2),  the 
opportunity of defining actions at the EU level was questioned during the Workshop organized on 15-
16 November 2016. In addition, two technical guides related to this topic were under development 
at the time of the workshop:  

•  Operational Intervention Levels for Radiological Emergencies and methodology for their 

derivation (EPR-RAD OILs) 

•  Operational Intervention Levels for Reactor Emergencies and methodology for their 

derivation (EPR-NPP OILs) – Published in 2017. 

Protective  actions  and  other  response  actions  are  not  based  on  attributes  relating  to  radiation 
protection  alone.  Decision  makers  should  consider  various  social,  economic,  environmental  and 
psychological  factors  before  making  any  final  decision  on  actions  to  be  taken  in  response  to  an 
emergency. However, the recommendations on generic and operational criteria relate solely to the 
radiation protection input into the decision-making process. 

Criteria  for  protective  actions  in  the  MS  were  provided  in  the  appendices  of  [ENCO,  2013]  and 
DRAFT 
compared  to  the  values  recommended  in  IAEA  GS-R-2.  They  are  reproduced  below  for  indicative 
purpose, although in particular cases the current situation may have changed since the publication of 
that report and the fact that values in IAEA GS-R-2 are no longer applicable as they were superseded 
by the generic criteria in GSR Part 7 and GSG-2. 

Underlying concepts/principles for the establishment of emergency planning zones and the values of 
generic  criteria  selected  in  different  countries  and  at  international  levels  span  a  wide  range;  such 
differences  are  not  surprising  as  the  values  adopted  reflect  a  mixture  of  scientific,  socio-economic 
and political judgments.  

  
 
 
 
 
 
 
 
 
 
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DRAFT 

Figure 6: Dose criteria for introducing sheltering in the EU [ENCO, 2013] 

  
 
 
 
 
 
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DRAFT 

Figure 7: Dose criteria for introducing evacuation in the EU [ENCO, 2013] 

  
 
 
 
 
 
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DRAFT 

Figure 8: Dose criteria for introducing iodine prophylaxis in the EU [ENCO, 2013] 

  
 
 
 
 
 
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DRAFT 

Figure 9: Dose criteria for introducing relocation in the EU [ENCO, 2013] 

  
 
 
 
 
 
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9.2.3  Preliminary guidance or recommendations 

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9.2.3.1  Alignment of criteria 
One difficulty to establish common criteria is that, in some cases, historical intervention levels were 
not  derived  on  basis  of  a  sound  optimization  process.  For  political  reasons,  adaptation  may  be 
difficult.  Nevertheless,  it  is  recommended  to  rely  on  the  values  of  the  IAEA  that  constitute  a 
consensus when no sound justification is available.  

The  alignment  of  reference  levels  and  common  generic  criteria,  triggers  values  and  operational 
criteria, although not technically required or required explicitly in the BSS Directive, would facilitate 
compatible response between MS. The problem of non-harmonised protective action criteria should 
however  not  be  over-emphasised.  Bilateral  or  multilateral  agreement  between  neighbouring 
countries  should  ensure  compatible  response  arrangement,  a  fortiori  between  MS  with  different 
criteria and triggers values.  

Generic criteria and operational criteria should be used as guidance during an emergency situation. 
They  have  not  to  be  seen  as  absolute  limits  during  response.  In  case  of  a  cross-border  event, 
different  criteria  between  impacted  MS  would  not  preclude  the  integrated  response  to  the 
emergency situation, unless the criteria are defined as absolute limits in the legislation. 

The differences between MS can contribute to reduce public confidence. The reason for the selection 
of (different) values of the criteria should be clearly communicated. The value of the dose criteria is 
not  necessarily  a  good  indicator  of  the  level  of  overall  protection:  the  focus  should  be  set  on  the 
optimization of the overall protection strategy rather than on the exact value of the residual dose. 
DRAFT 
Low  values  for  generic  criteria  for  particular  actions  would  not  necessarily  provide  a  better 
protection level. For example, low values of the generic criteria for evacuation may imply the need to 
evacuate  much  larger  areas  in  case  of  an  emergency,  with  a  risk  to  decrease  its  efficiency  and 
decrease the protection of the most exposed individuals. 

It  is  essential  to  clearly  communicate  on  the  methodology  followed  to  derive  the  dose  criteria.  An 
good example within the EU for the definition and clear communication of criteria related to EP&R is 
found in [NORDIC, 2014]. 

9.3  Protection strategies for the public and optimisation approaches 

Annex  XI  of  the  BSS  Directive  requires  including  in  an  emergency  response  plan  the  optimized 
protection  strategies  for  members  of  the  public  who  may  be  exposed,  for  postulated  events  and 
related scenarios. 

9.3.1 

Issues to be further addressed  

A need for further clarification and guidelines has been specified as follows [RISKAUDIT, 2016]: 

•  Definition (and harmonised interpretation) of what is meant by protection strategy (level of 
detail,  elements)  and  “common  practice”  for  practical  arrangements  for  use  of  reference 
levels. 

•  There  is  a  need  for  more  and  clear  information  and  guidelines  on  how  to  develop  the 

optimised response strategies for different radiological emergencies. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
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9.3.2  Available international guidance 

Elements to be included in the protection strategies can be found under the Requirement 5 of IAEA 
GSR  Part  7:  Protection  strategy  for  a  nuclear  or  radiological  emergency.  Generic  criteria  for  use  in 
emergency  preparedness  and  response  and  examples  of  protective  actions  and  other  actions  are 
provided in Appendix II of IAEA GSR Part 7. Guidance to identify an emergency situation and develop 
protection strategies can be found in IAEA GS-G-2.1. Actions to protect the public in an emergency at 
a light water reactor are found in IAEA EPR-NPP Public Protective Actions. The IAEA is also currently 
developing a technical guide on the optimisation of the protection strategies: Considerations in the 
Development  of  a  Protection  Strategy  for  a  Nuclear  or  Radiological  Emergency  (EPR-Protection 
Strategy). 

At the European level, in the event of nuclear accident, Council Regulation (EURATOM) No. 2016/52 
adopted on 15 January 2016 sets the maximum permitted levels of radioactive contamination in food 
and feed following a nuclear accident or other case of radiological emergency. 

Protection  strategies  for  taking  protective  actions  and  other  response  in  a  nuclear  or  radiological 
emergency  should  be  developed  for  potential  emergency  situations.  Generic  criteria  for  taking 
protective actions should be defined. 

Each protective action and the overall protection strategy should be justified and optimized, i.e. do 
more good than harm, with due account taken of other detriments than radiological exposure, but of 
those  associated  with  impacts of the  actions  taken on  public  health, the economy,  society and  the 
environment (IAEA GSR Part 7). The implementation of the recommendations of the ICRP concerning 
reference  levels  and  optimisation  is  discussed  in  [NEA,  2013].  Factors  for  consideration  in  the 
DRAFT 
justification and optimization of the protection strategy are provided in [NORDIC, 2014]. In addition 
to  radiation  protection,  the  assessment  of  the  scope  and  impact  of  protective  measures  before 
decision  making  should  also  include  the  influence  of  other  factors  such  as:  efficiency,  timing, 
resources, waste management, surroundings, economy, social and ethical aspects. These factors are 
reproduced below. 

The  optimization  of  the  protection  is  essentially  a  judgmental  process  ensuring  that  the  best  has 
been  done  in  the  prevailing  circumstances.  The  recommendation  for  the  optimisation  of  the 
protection  and  a  description  of  decision-aiding  techniques  commonly  used  for  practical 
implementation of the optimisation process are provided in [ICRP, 2006]. 

Off-site emergency zones (EPZ) and distances around a nuclear installation need to be identified in 
advance during the preparedness stage. This is to ensure that effective protective actions and other 
response  actions  can  be  promptly  implemented  to  protect  the  public  that  are  consistent  with  the 
hazard. 

Emergency  planning  zones  and  distances  should  also  be  defined  taking  into  account  the  hazards 
associated  with  the  concerned  installation  and  potential  consequences  of  an  emergency  should  it 
occurs  (e.g.  the  potential  amount  of  radioactivity  within  the  installation,  design  provision  such  as 
double  confinement  barrier  for  nuclear  reactors,  improvements  implemented  following  periodic 
safety reviews or stress tests, ...). 

  
 
 
 
 
 
 
 
 
 
 
 
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DRAFT 

Figure 10 : Factors affecting the choice of protective actions [NORDIC, 2014]. 

  
 
 
 
 
 
  
 
 
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The IAEA GSR Part 7 requires for the following areas to be specified:: 

•  Precautionary action zone (PAZ); 
•  Urgent protective action planning zone (UPZ); 
•  Extended planning distance (EPD); and 
• 

Ingestion and commodities planning distance (ICPD). 

The emergency zones (PAZ and UPZ) are areas where comprehensive arrangements are put in place 
at the preparedness stage to promptly, upon declaration of a General Emergency, implement urgent 
protective and other response actions. The PAZ and UPZ sizes are described in terms of the radius of 
a circle around the nuclear power plant. The emergency zones and distances are described in Table 2 
of  IAEA  EPR-NPP  Public Protective  Actions  and  the  suggested  sizes  for  the  zones  and  distances  are 
given  in  Table  3  of  IAEA  EPR-NPP  Public  Protective  Actions  for  nuclear  power  plants.  The  size  and 
boundaries of the zones and distances need to be site specific and due to the large variations in site 
and  nuclear  power  plant  characteristics.  It  is  beyond  the  scope  of  IAEA  EPR-NPP  Public  Protective 
Actions to provide a single set of specific distances that would be most effective for all nuclear power 
plants.  Therefore,  the  sizes  of  the  zones  and  distances  given  in  IAEA  EPR-NPP  Public  Protective 
Actions  are  to  be  considered  as  a  first  approximation  that  needs  to  be  adjusted  to  specific  plant 
designs,  emergency  scenarios  and  local  conditions.  The  PAZ  may  be  seen  as  the  zone  in  which 
precautionary  protection  actions  should  be  taken  before  of  shortly  after  release  to  avoid 
deterministic effect. The radius of the UPZ should be defined for taking protective actions to reduce 
the expected dose below the reference level to limit stochastic effects. 

The IAEA provides PAZ and UPZ radii for threat category I&II in IAEA GS-G-2.1. The suggested sizes 
are  based  on  expert  judgment.  They  are  not  the  result  of  a  systematic  optimization  process  that 
DRAFT 
takes account of national, site-specific and local circumstances. Guidance may be needed at the EU 
level  should  a  systematic  optimization  process  be  applied  at  the  planning  stage  and  taking  into 
account the factors mentioned in [NORDIC, 2014]. However, considerable effort would be needed to 
reach consensus on the way to assess values of the attributes of [NORDIC, 2014] and the weight to 
be used in a multi-attribute analysis at the EU level.  

Other useful guidance for the definition of protection strategies may be found in [EPA, 2016]. 

9.3.3  Preliminary guidance or recommendations 

9.3.3.1  Extent of the EPZ 
It should be noted that the optimal EPZ radius will depend strongly upon the accident of reference 
considered  for  a  nuclear  installation.  Guidance  could  be  needed  for  a  uniform  approach  to  assess 
emergency situations for various nuclear or radiological installations within the EU. The rationale for 
the selection of the EPZ in the MS are summarised in [ENCO, 2013]. In most cases, the distances have 
been determined on the basis that the estimated dose from an assumed release in assumed weather 
conditions  would  not  exceed  a  specified  intervention  level  or  other  level  of  dose.  Significant 
differences  are,  however,  apparent  between  countries  in  the  interpretation  of  these  three 
assumptions  or  quantities  (i.e.,  magnitude  of  assumed  release,  assumed  weather  and  intervention 
level adopted). Not surprisingly, therefore, that there are significant differences in the extent of the 
resulting  EPZ.  The  magnitudes  of  assumed  releases  vary  over  several  orders  of  magnitude  (see 
Appendix  G,  Section  20.2.5  of  [ENCO,  2013]  for  further  detail).  The  variation  in  assumed  weather 
conditions is also considerable ranging from ‘average’ to ‘adverse’ and in some cases to the ‘worst’ 

  
 
 
 
 
 
 
 
 
 
 
 
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(represented  by  the  99.5th  percentile  in  one  case).  The  assumed  intervention  levels  also  differ 
significantly,  varying  by  more  than  an  order  of  magnitude  between  countries,  the  type  of  nuclear 
installations they host and often relating to different dose quantities. 

The extent of the EPZ is not a necessarily good measure of the overall level of protection: 

• 

• 

Large EPZ for a same reference level value would imply a larger tolerance for releases and be 
contrary to the need to implement design safety measures and other operational measures 
at  the  nuclear  and  radiological  installations  to  reduce  the  likelihood  and  magnitude  of 
potential release. 
Large EPZ may complicate the protection of the most exposed individuals. 

It  seems  essential  to  adapt  the  size  of  the  EPZ  to  the  emergency  situation.  As  such,  it  is  not  the 
harmonization  of  the  EPZ  distance  that  should  be  promoted  within  the  EU,  but  of  the  method  to 
evaluate this distance (including the evaluation of the magnitude of assumed release). This could be 
done at the EU level, on a generic basis for a limited number of representative facilities. 

The  EPZ  are  typically  circular  areas  in  which  the  protection  strategies  (sheltering,  iodine  intake, 
evacuation...) should be prepared in advance to comply with the reference levels and enable a rapid 
and effective implementation of protective actions by the authorities. The protection areas are the 
areas in which the agreed actions are effectively implemented when the emergency plan is triggered. 
The  protection  areas  can  be  a  sector  determined  by  the  prevailing  winds  (actual  or  expected);  the 
distance over which actions are implemented can be smaller or larger than the distances defined in 
emergency  planning  zones.  Large  protection  zones  can  undermine  the  efficient  implementation  of 
protection actions, particularly of the most exposed individuals. Large protection zones therefore do 
DRAFT 
not  necessarily  contribute  to  an  optimal  overall  protection.  A  general  strategy  to  extend  the 
protection zone beyond the EPZ should also be prepared, following a graded approach. An example 
of the definition of the subdivision of the EPZ into protection zones (angular sectors) is provided in 
[SSK,  2014].  Belgium  promotes  an  approach  based  on  “blocks”  rather  than  angular  sectors 
[EUROSAFE, 2012]. 

9.3.3.2  Sheltering 
Sheltering  was  identified  during  the  Workshop  organized  on  15-16  November  2016  as  critical. 
Sheltering  is  not  a  nuclear  specific  issue,  except  for  timescale.  Of  particular  concern  is  the 
implementation of protective measures at critical installations (hospitals, specific industries…). Some 
industrial  activities,  such  as  glass  furnaces,  steel  and  chemical  plants  have  also  detrimental 
limitations in their response time and cannot afford to stop immediately. This is to be considered in 
the sheltering / evacuation decision process.  

The US EPA addressed the effectiveness of protective measures such as sheltering. Houses within the 
EU may have different sheltering characteristics (wood, stone, ...). Exposure reduction from external 
radiation from nuclear fallout as a function of building type and location is discussed in [EPA, 2016]. 

9.3.3.3  Alignment of protective actions 
Experience  has  shown  that  the  alignment  of  protective  actions  without  the  harmonization  of 
reference  levels  is  possible,  but  not  easy.  The  priority  should  be  set  on  nuclear  reactors  near  the 
borders (<20 km). Potential impacted countries should discuss to align measures. Full harmonization 
in the EU is unlikely to be achievable but the alignment of protective actions at a more regional level 
may be easier. Due to the limited time still available for the transposition and implementation of the 

  
 
 
 
 
 
 
 
 
 
 
  
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BSS  Directive,  one  has  to  focus  on  the  most  crucial  points.  One  of  these  crucial  points  is  the 
elaboration of the scenarios to be considered to develop emergency plans. Common approaches for 
the  definition  of  scenarios  and  assessment  of  the  source  term  would  be  valuable.  Norway  has  for 
example  6  scenarios  categorized  according  to  their  consequences  (including  the  fall  of  an  RTG 
powered satellite). Germany defined 10 scenarios and France has also defined a set of 8 scenarios for 
the  development  of  emergency  plans.  The  process  would  consist  in  identifying  the  scenarios  and 
their relevance for implementation. 

9.3.3.4  Test/Exercise 
The importance of exercises was stressed during the Workshop organized on 15-16 November 2016. 
The European Commission could be invited as an observer when common exercises take place. The 
crisis centre of DG ECHO should be involved in emergency exercises.  

The  IAEA  exercise  framework  should  be  used  preferentially.  For  example,  a  ConvEx  exercise  is 
planned  in  Hungary:  ConvEx-3  full  response  exercise  of  the  IAEA  where  Hungary  is  playing  the 
accident state. The IAEA Emergency Preparedness Review (EPREV) Service would be a good way to 
assess  EP&R  plans.  However,  all  EPREV Reports should  be  published  to enhance  public  confidence. 
Self-assessment  is  also  available  at  IAEA  to  test  compliance  with  GSR  Part  7,  as  reflected  with  the 
EPRIMS tool. 

9.3.3.5  Example of good practice 
An  example  of  good  practice  in  the  EU  for  the  definition  of  protection  strategies  is  the  French 
National Response Plan [SGDSN, 2014]. It was decided in France that this plan should address a very 
broad range of facilities and transport operations for which the French government and its partners 
DRAFT 
must be able to respond in case of a nuclear or radiological event: 

•  nuclear power plants, 
•  nuclear fuel cycle facilities, 
• 
•  naval nuclear propulsion systems and associated equipment, 
• 

research laboratories and reactors, 

transport of nuclear or radioactive materials for the aforementioned facilities. 

The operational part of the plan is more structured around reference situations (snapshots of a given 
moment  in  time)  than  around  scenarios,  which  would  consider  all  possible  assumed  event 
sequences. This approach allows the plan to be predicated on eight reference situations that are met 
by  a  comprehensive  response  strategy.  The  main  parameters  that  define  the  situations,  i.e.  which 
distinguish between the response and the actions to be taken, are as follows: 

•  The degree of uncertainty about the type of accident and its consequences; 
•  The environmental compartment (sea or land). This has a major influence on the necessary 

response and measures to be taken; 

•  The location of the accident: in France or abroad; 
• 

In the case of accidents that occur in other countries, the need or not to take measures to 
protect people in France; 

•  Whether the accident occurs in a fixed facility or for a mobile equipment / during transport. 
Unlike  with  accidents  during  transport  operations,  fixed  facilities  make  it  possible  to  plan 
actions in a known environment; 

  
 
 
 
 
 
 
 
 
 
 
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• 

In  the  case  of  accidents  at  fixed  facilities  in  France:  the  onset  (immediate  or  delayed)  and 
duration of the release. Delayed releases afford time to pre-emptively implement protective 
measures. 

The areas in which protective measures are to be implemented are defined using the response levels 
set  out  in  French  ASN  decision  2009-DC-0153,  approved  by  the  minister  of  health,  for  radiological 
emergencies.  This  decision  calls  for  the  prefect  (regional  governor  responsible  EP&R  and  civil 
protection) to be ready to order: 

•  an evacuation, if public-exposure predictions exceed a whole-body effective dose of 50 mSv, 
• 
shelter-in-place,  if  public-exposure  predictions  exceed  a  whole-body  effective  dose  of  10 
mSv, 
stable  iodine  prophylaxis,  if  thyroid-exposure  predictions  exceed  an  equivalent dose  to  the 
thyroid of 50 mSv. 

• 

The  decision  to  implement  protective  measures  is  taken  based  on  an  analysis  of  the  risks  and 
benefits for the population. This analysis is based on the natural hazards, local data (e.g. layout of the 
land,  population  density)  and  knowledge of  the  release,  the  weather  conditions  and  the estimated 
doses for each factor. It may be conducted to compare the radiological risks of evacuating the public 
against those of having the public shelter in place. The French National plan is considered as a good 
example  in  Europe.  The  plan  will  be  reviewed  next  year  to  include  the  dispositions  of  IAEA  GSR 
Part 7. This approach may inspire MS for the development of their own plans, although adaptation of 
the plan is not straightforward due the differences in states' organizations. 

9.4  Reference levels 

DRAFT 

The transposition and implementation of Art. 7 of the BSS Directive is seen as a concern for which 
recommendations  would  be  welcomed  by  most  of  the  10  MS  to  which  the  questionnaire  was 
addressed. 

Art.  7  requires  to  establish  references  levels  according  to  the  range  set  out  in  Annex  I  of  the  BSS 
Directive. 

Annex  1  of  the  BSS  Directive  provides  a  range  of  reference  levels  for  existing  and  emergency 
situations.  For  emergency  and  existing  exposure  situations  the  maximum  reference  levels  for  the 
public  imposed  at  the  EU  level  are  effective  doses  of  100  mSv  (acute  or  annual)  and  20  mSv/a 
respectively.  

The overall aim is that the residual radiation dose should not exceed the reference level of 20 – 100 
mSv  (acute  or  annual),  including  all  radiation  pathways  and  protective  measures,  and  that  the 
protective actions that are applied, are optimized. 

As  the  selection  of  a  reference  level  should  fit  the  type  of  emergency  exposure  situation  and  the 
protection  strategy  to  which  it  will  be  applied,  generic  criteria,  default  triggers  and  operational 
criteria should be defined in function of the emergency exposure situation. 

MS  are  free  to  adopt  more  stringent  reference  levels.  MS  are  also  free  to  define  unique  reference 
levels for all types of emergency situations, to define a range of values or a maximum value for the 
references  levels  to  cope  with  various  emergency  situations  and  allow  for  the  flexibility  of  the 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

emergency  planning  and  response  in  function  of  the  prevailing  circumstances.  When  opting  for  a 
range  of  values,  the  upper  and  lower  values  of  the  range  could  be  set  equal  to  the  maximum  and 
minimum reference levels for all emergency situations. 

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9.4.1 

Issues to be further addressed 

A  need  for  the  development  of  a  common  understanding  of  the  concept  of  reference  levels 
concerning EP&R was identified [RISKAUDIT, 2016]. MS have established different references levels 
for  emergency  exposure  situations  and  existing  exposure  situations,  as  shown  in  Table  2.  The 
development of general principles for setting the reference level seems necessary [RISKAUDIT, 2016]. 

Different appreciations exist between MS on whether to use one reference level for every situation 
or to adopt scenario-specific reference levels. 

The surveys [ENCO, 2013] and [RISKAUDIT, 2016] identified the need for a pragmatic approach based 
on  compatible  reference  levels  for  neighbouring  countries  (via  cross-border  cooperation)  and  on 
common operational intervention levels, observables and trigger levels, as these are more likely to 
be used during the early stages of a release. 

Clarification seems needed on what extent the concept of reference levels should be introduced into 
national legislation and the need to validate existing emergency response plans against the chosen 
national reference levels. 

Table 2: Reference levels in the MS [RISKAUDIT, 2016] – values indicate the number of states adopting 
the reference level. 
DRAFT 

Reference levels 

1mSv/a 

10mSv/a 

20mSv/a 

100mSv/a  No value 

in 
advance 

Not yet 
defined 

Reference  levels  of  the 
BSS Directive 

Emergency exposure 
Transition  emergency-
>existing exposure 
Existing exposure 

Existing exposure situation 

Emergency exposure 
situation 

0 

0 

4 

0 

1 

0 

2 

7 

1 

6 

0 

0 

1 

3 

2 

9 

10 

10 

9.4.2  Available international guidance 

The reference levels for public exposure of the BSS Directive are based on the recommendations of 
the International Commission on Radiological Protection 103. 

The basic principles for setting reference levels are provided in ICRP 103 and ICRP 109. Guidance can 
also be found in IAEA GSR Part 7 and [NEA, 2013]. 

Reference  levels  have  a  role  in  both  planning  and  response.  Countermeasures  are  triggered  by 
predefined generic criteria, default triggers or operational criteria. 

The reference levels define a level of dose above which it is generally unacceptable to plan to allow 
exposures to occur (ICRP 109). The reference levels are not absolute limits during an emergency or 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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an existing exposure situation. Reference levels allow for a constrained and optimized protection of 
the  public  as  well  as  consideration  of  other  societal  and  economic  factors  in  a  similar  way  as  for 
planned exposure situations. 

Whilst the general intent of the ICRP’s advice is that no residual doses should be planned to exceed 
the  reference  level,  there  may  be  circumstances  in  which  this  is  either  not  practicable  or  not 
possible. In particular, where an emergency results from a malicious act, or where an accident occurs 
that results in very high exposures being received during or shortly after the initiating event with very 
low probability, it is not practicable to plan to prevent all doses above the reference level (ICRP 109). 

As stated in ICRP 109, the selection of a reference level should fit the type of emergency exposure 
situation and the protection strategy to which it will be applied. The type of reference level that is 
selected should thus be tailored to meet the type of accident scenario under consideration. Ideally, 
regulatory authorities and operators will assess all credible risks, and authorities will be able to pre-
select appropriate reference levels for the various accident scenarios that they judge to be relevant. 

Each  protective  action,  in  the  context  of  the  protection  strategy,  and  the  protection  strategy  itself 
shall be demonstrated to be justified (i.e. to do more good than harm), with account taken not only 
of  those  detriments  that  are  associated  with  radiation  exposure  but  also  of  those  detriments 
associated  with  impacts  of  the  actions  taken  on  public  health,  the  economy,  society  and  the 
environment (IAEA GSR Part 7). 

The  optimum  reference  level  of  dose  for  introducing  a  particular  protective  action  will  be  very 
dependent  on  the  nature  of  the  accident,  the  weather  conditions,  the  available  resources  and  the 
site-  specific  factors,  such  as  the  characteristics  of  the  population,  housing  and  industry.  Multi-
DRAFT 
attribute analysis has been used since a relatively long time to define reference levels considering the 
major factors which are likely to influence the balance of harm and benefit in a particular situation, 
and  for  particular  protective  actions,  such  as  averted  individual,  collective  risk,  the  reassurance 
provided by taking action, disruption, the collective and individual risks, anxiety, worker risk and the 
monetary  cost  involved,  see  e.g.  [NRPB,  1990].  However,  reference  levels  were  mostly  based  on 
expert judgement rather than on a systematic optimisation approach [NEA, 2013]. 

An  emergency  exposure  situation  becomes  an  existing  exposure  situation  once  the  government 
and/or  regulatory  authority  has  decided,  presumably  based  on  extensive  discussions  with  affected 
stakeholders, that a new reference level is appropriate as a benchmark for judging the optimisation 
of protection strategies for a given geographic area or exposure circumstance (ICRP 109). 

9.4.3  Preliminary guidance or recommendations 

9.4.3.1  Harmonization of reference levels 
There  were  numerous  attempts  to  harmonize  the  reference  levels  across  the  EU.  However, 
differences  might  be  technically  justified  as  reference  levels  have  to  be  optimized  for  the  various 
emergency  situations  in  function  of  the  prevailing  circumstances.  As  stated  in  [ENCO,  2013],  these 
differences  in  levels  are  a  source  of  public  and  political  concern  and  disquiet  due  to  the  implied 
differences  in  the  levels  of  protection  being  aimed  for,  and/or  achieved,  between  countries.  When 
differences occur between neighbouring countries, such concerns are further exacerbated. It is clear, 
according to the work carried out by HERCA, that a generic approach to reference levels is unlikely to 
be  achievable.  The  BSS  Directive  leaves  room  for  national  interpretation  to  be  used  by  MS.  A 
pragmatic  approach on  reference  levels  is  recommended  by  HERCA members  such  as  cross  border 

  
 
 
 
 
 
 
 
 
 
 
 
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cooperation  to  achieve  compatible  references  levels  for  neighbouring  countries  and  to  harmonize 
protection strategies. The alignment of protective actions at a more regional level may be easier than 
across the EU. 

Reference levels are related to the acceptable residual dose. The residual dose is an indication of the 
level  of  the  radiological  detriment  expected  to  be  incurred.  Optimization  of  the  overall  protection 
strategy (which encompasses the radiological detriment) should prevail over the minimization of the 
residual dose expected to be incurred. 

For  cross-border  events,  compatible  response  arrangements  should  be  ensured  between 
neighbouring countries and particularly for the early response during which there will not be time to 
carry  out  a  detailed  analysis  and  quantification  of  all  the  relevant  factors  influencing  the  optimum 
protection level. The response arrangements depend on the reference levels. 

9.4.3.2  Definition of reference levels 
References  levels  should  be  tailored  to  the  need.  The  impact  of  potential  emergency  situations  in 
neighbouring  countries  should  be  considered.  Differences  will  appear  between  MS  because  of  the 
difference  between  the  nuclear  and  radiological  emergency  situations,  particularly  between  MS's 
with and without nuclear power plants.  
Reference levels are more used at the planning stage for dimensioning the response system, rather 
than absolute levels during a real emergency situation. Ranges of reference levels would be easier to 
agree upon.  

The importance of reference levels should not be over-emphasized. It seems that too much attention 
DRAFT 
is paid to the values. There are conservatisms and uncertainties in the evaluation of the doses, thus 
defining  absolute  levels  is  not  that  important.  There  is  a  tendency  to  overestimate  doses:  this  can 
lead to the implementation of unnecessary protective actions. The planning and consequences of the 
protection actions is of upmost importance. 

The reference levels in the legislation should be compatible with established bilateral or multilateral 
arrangements and allow for an integrated response to an emergency situation without violating the 
legislation  of  impacted  countries.  The  reference  levels  for  specific  potential  emergency  or  existing 
exposure  situations  could be  further  specified  (not  necessarily  in  the  legislation)  on  a  case  by  case 
basis  in  each  MS  for  events  not  likely  to  have  an  impact  on  neighbouring  countries  and  through 
bilateral  or  multilateral  arrangements  for  potential  cross-border  emergency  or  existing  exposure 
situations. The derivation of situation specific reference levels would be in this last case the outcome 
of  bilateral  or  multilateral  cross  border  cooperation  and  would  depend  on  the  radiological  source 
term and other local parameters. 

Luxembourg  has  for  example  opted  for  flexibility  in  their  arrangements,  opting  for  rather  upper 
bound  reference  levels  and  relatively  large  planning  zones  to  align  protective  measures  during  an 
emergency with the other countries. 

The  strategy  in  Ireland  is  to  keep  the  detail  out  of  the  legislation  to  allow  for  flexibility,  e.g.  for 
reference levels: the Environmental Protection Agency (EPA) will set reference levels but values will 
not be in legislation. 

  
 
 
 
 
 
 
 
 
 
 
 
 
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9.5  Involvement of stakeholders 

As stated in [NEA, 2011], the radiological protection profession can benefit from increased outreach 
and  involvement  with  its  stakeholders  in  order  to  provide  more  effective  post-emergency 
management,  in  particular  for  preparedness  and  response  aspects  associated  with  consequence 
management  and  transition  to  recovery  and  rehabilitation.  Previous  exercises  addressing 
consequence  management  following  a  nuclear  or  radiological  emergency  have  demonstrated  that 
the 
involvement  of  a  range  of  governmental  and  non-governmental  stakeholders  presents 
opportunities for better identifying and implementing sustainable approaches to long-term recovery.  

9.5.1 

Issues to be further addressed 

The  definition  of  stakeholders  should  be  clarified:  a stakeholder  is  an  individual  who  is  affected  by 
the  decisions  made  (or  not  made)  by  emergency  managers  and  policymakers  in  his  or  her 
community.  Since  all  citizens  are  likely  to  be  affected  by  emergency  management  policies,  this 
definition  implies  all  citizens  are  stakeholders.  Although  this  is  true,  it  is  not  very  helpful  because 
stakeholders differ in the ways they are affected by emergency management policies and, even more 
important,  they  differ  in  the  times  at  which  they  are  affected  and  the  magnitude  of  the  impacts 
policy has on them.  

9.5.2  Available international guidance 

The IAEA draft DS474 provides guidance on involvement of and consultation with stakeholders. 

9.5.3  Preliminary guidance or recommendations 

DRAFT 

By “stakeholder” in the present section we mean primarily the individuals and the organizations that 
will have an active role in case of an emergency, either in managing the emergency, or having to act 
as a result of the decisions of the emergency managers.  

An  important  way  to  involve  stakeholders  is  to  work  with  citizens’  groups.  Fostering  citizen 
involvement  requires  emergency  managers  to  initiate  contacts  throughout  the  community.  The 
experience  of  French  “Local  Commissions  of  Information”  (CLIs)  and  their  national  federation  the 
(ANCCLI) represent an interesting and original example of local actors’ empowerment. 
While nuclear and radiological emergency planning remains mostly the responsibility of nuclear and 
radiation  safety  authorities,  the  stakeholders  should  be  involved  at  the  preparedness  stage  (e.g. 
during exercises).  

The involvement of stakeholders is regularly discussed, e.g. in the frame of the NERIS platform7 and 
by other civil society organization. It was recommended to take initiatives at national, regional and 
international  levels  to  promote  the  integration  of  nuclear  emergency  preparedness  and  response 
within  civil  protection  arrangements  more  generally,  to  identify  potential  synergies  that  would 
improve  the  overall  level  of  preparedness  and  response,  the  impediments  to  achieving  integration 
and how they might be overcome, and where savings can be made by avoiding duplication. 

7 The NERIS-TP project aimed to help achieving a greater harmonisation in Europe by improving European decision 
support systems and establishing a sustainable platform that combines all important players in emergency and post-
accident preparedness and management in one single organisation. It promoted in particular the usefulness of 
modelling tools and stakeholder involvement in the preparedness processes 

  
 
 
 
 
 
 
 
 
 
 
 
 
                                                             
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The  support  of  the  Directorate-General  for  European  Civil  Protection  and  Humanitarian  Aid 
Operations  (DG  ECHO)  in  promoting  awareness  amongst  civil  protection  organisations  would  be 
valuable. DG ECHO is developing exercises with the civil protection organisations in the MS. 

Various European research projects (e.g. FARMING, EURANOS, PREPARE) considered the involvement 
of  the  stakeholders.  A  significant  experience  was  also  gained  through  the  ETHOS  project  on  the 
rehabilitation of living conditions in the territories contaminated by the Chernobyl accident. 

All countries (but one exception) state that the roles, responsibilities and interactions between the 
key stakeholders in off-site EP&R are clearly defined and formally agreed by all parties. Similarly, all 
countries  (with  one  exception)  have  a  national  coordinating  authority  to  ensure  that  the  functions 
and responsibilities of all parties are clearly assigned and understood [ENCO, 2013]. 

[ENCO,  2013]  already  recommended  to  include  EP&R  arrangements  for  nuclear  (and  radiological) 
emergencies  in  the  larger  system  of  response  to  all  disaster  types,  including  chemical,  biological, 
radiological, natural and man-made. Integrating nuclear EP&R fully into civil protection mechanisms 
at European level would increase the preparedness level of European civil society, ensure clarity of 
command structures and consistency of response, and contribute to more effective use of resources. 
The same recommendation is made by the International Federation of Red Cross and Red Crescent 
Societies [IFRC, 2015]. 

9.6  Reference levels for emergency occupational exposure 

DRAFT 
Reference levels for emergency occupational exposure are provided in Art. 9 and Art. 53 of the BSS 
Directive.  

Emergency  occupational  exposure  shall  remain,  whenever  possible,  below  the  dose  limits  for 
occupational  exposure.  For  situations  where  this  is  not  possible,  reference  levels  for  emergency 
exposures of maximum 100 mSv shall be set, however in exceptional circumstances this may be set 
up  to  500  mSv.  In  these  cases,  emergency  workers  shall  be  subject  to  appropriate  radiological 
monitoring and special medical surveillance.  

9.6.1 

Issues to be further addressed  

The  understanding  of  “emergency  workers”  is  not  identical  in  all  MS.  The  value  for  the  reference 
level of Art. 53 should take precedence over 'guidance values' mentioned in international guidance, 
for example in GSR Part 7.  

9.6.2  Available international guidance 

The  HERCA  document  “Common  understanding  of  the  provisions  related  to  emergency  workers” 
identifies  a  rich  variation  in  interpretations  of  what  is  understood  in  MS  by  "emergency  worker", 
although  there  is  general  agreement  for  the  most  important  roles.  But  wherever  differences  are 
found, the bilateral impact is deemed to be marginal at worst.  

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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9.7  Assessment of potential emergency exposure situations and associated 

public and emergency occupational exposures 

Differences  in  national  models,  differences  in  weather  prediction  methods,  and  differences  in 
national  emergency  management  strategies  can  result  in  different  assessments  of  radiological 
exposure  between  MS.  This  may  complicate  the  compatible  response  to  cross-border  emergency 
situations. 

Differences in national long-range dispersion forecasts may cause problems at the European level, as 
National emergency management strategies based solely on national forecasts may not be coherent 
with  those  in  neighbouring  countries.  The  JRC  ENSEMBLE  project  has  the  potential  to  address  the 
issue of harmonisation and coherence of assessments and decision-making in relation to long range 
atmospheric dispersion modelling. 

9.8  Information  to  the  public  (likely  to  be  affected  or  actually  affected  in 

the event of an emergency) 

Although  the  provisions  are  essentially  unchanged  in  the  new  BSS,  it  is  clear  from  the  experience 
from Fukushima that effective implementation of the provisions is essential. 

9.8.1 

Issues to be further addressed 

DRAFT 
An EP&R working group was established together with the creation of Nuclear Transparency Watch 
(NTW) in November 2013 with the aim to: 

• 

carry out an evaluation of the existing European and national EP&R provisions from the civil 
society point of view, identifying key challenges,  
inform the public on the findings, and  

• 
•  provide guidance for further activities of the interested public.  

NTW  highlighted  that  communication  and  notification  lines  are  not  entirely  working  and  EP&R  is 
dealt at national level, with little transboundary cooperation.  

As stated in [IAEA, 2016], examples of previous emergencies show how failure of addressing public 
communication  properly  can  lead  to  unwarranted  reactions  by  the  public,  possibly  resulting  in 
hampering protective actions. The ways in which experts and non-experts perceive the same risk are 
completely different. The non-expert audience tends to react considerably more emotionally. It was 
pointed  out  that  relevant  audiences  and  communication  channels  need  to  be  identified  at  the 
preparedness  stage.  A  special  focus  needs  to  be  placed  on  the  new  media  and  the  online 
communication. Potential spokespersons need to be thoroughly trained. 

One additional issue at the EU level is the need to have information available in different languages. 

9.8.2  Available international guidance 

Guidance for the information to the public can be found in IAEA EPR-Public Communications 2012 or 
in chapter 7 of IAEA EPR-NPP Public Protective Actions. The IAEA is currently preparing a new Safety 
Guide (DS475, target publication date end 2017) on the Arrangements for Public Communications in 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Preparedness  and  Response  for  a  Nuclear  or  Radiological  Emergency.  This  new  safety  guide  could 
serve  as  basis  for  a  coherent  implementation  of  the  requirements  of  the  BSS  at  the  EU  level.  MS 
could  share  their  point  of  view  on  the  way  the  European  Commission  could  coordinate  the 
comments on the draft DS475, in order to provide a common EU position. 

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9.8.3  Preliminary guidance or recommendations 

A pro-active communication strategy should identify which issues of the emergency plan should be 
disseminated  through  information  campaigns,  which  will  take  advantage  from  being  additionally 
assessed by a public consultation and which issues related to emergency planning could be subject to 
a more demanding participative process.  

The extent and method of communication must also be linked to the target groups, i.e. the audience 
to  whom  the  communication  is  addressed.  Besides  the  general  public  and  more  particularly  the 
public living in the vicinity of nuclear installations, some target groups can be of specific interest and 
require  a  dedicated  approach:  rescue  commanders  and  staff,  medical  rescue  staff,  practitioners 
(family doctors) and physicists. Attention should also be paid to officials, school teachers, journalists. 
It is necessary to ensure that the information which is provided to the public is well understood. 

There  is  a  common  understanding  that  the  relevance  of  values  chosen  for  the  references  levels, 
operational  criteria  and  EPZ  distances  should  not  be  over-emphasised.  They  do  not  necessarily 
constitute  good  indicators  of  the overall  level  of  protection.  The  focus  should rather  be  set on  the 
optimisation of the protection strategy. A communication effort is necessary to inform members of 
the public on the rationale behind the selection of values and on the overall protection approach. 

DRAFT 
An  efficient  and  rapid  communication  towards  the  public  should  be  ensured.  Official  information 
should be made available ahead of unreliable information. 

To  speed  the  communication  stream,  Germany  decided  for  example  to  drop  the  quality  assurance 
process  on  the  estimated  dose  during  an  emergency  to  speed-up  the  calculations.  To  ensure  a 
sufficient level of accuracy, automation of calculations should be encouraged (as it can be validated 
in advance). 

ECURIE is considered by most MS as being a useful tool for information exchange between Member 
State  authorities  via  the  Commission,  but too  slow  for  providing  a  quick  first  information (not that 
the application is too slow, but the way it is used in practice). For this reason, the suggestion is made 
that the operator of the installation concerned, as part of bilateral agreements,  provides a first alert 
directly to the neighboring countries.  

Gaining  public  confidence  before  an  emergency  is  essential  to  have  an  optimal  behaviour  and  to 
avoid panic. Guiding principles of the national emergency plans should be made publicly available. An 
example of good practice within the EU may be found in [SGDSN, 2014]. 

EU level guidance for information management related to emergencies is found in [EC, 2011]. 

FAQs should be prepared. This point is addressed in IAEA DS 475. Examples of FAQs are provided in 
[FEMA, 2013]. A FAQ list could be considered at the EU level. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
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9.9  Prior  information  and  training  for  emergency  workers  and  all  other 

persons with duties and responsibilities in emergency response 

Prior  information  and  training  for  emergency  workers  and  all  other  persons  with  duties  and 
responsibilities  in  emergency  response  is  not  seen  as  a  major  issue  for  the  transposition  and 
implementation of the BSS Directive. 

9.9.1 

Issues to be further addressed 

The  need  for  further  clarification  and  guidelines  respectively  has  been  specified  as  follows  in 
[RISKAUDIT, 2016]: 

•  Common  understanding  for  adequate  and  regular  training,  shared  approaches  concerning 

individual protection. 

•  Resource-related difficulty for ongoing need to provide training. 
•  Prior  training  is  mostly  not  very  effective.  Indeed,  emergency  workers  normally  forget  the 
basic  concepts  soon  after  they  receive  the  training.  An  ad  hoc  short  repetition  of  main 
messages at the beginning of an emergency seems therefore necessary. 

•  A Rulebook on training programmes needs to be developed and training centres need to be 

established. 

9.9.2  Available international guidance 

DRAFT 
Elements to consider for the training of emergency workers can be found in § 6.28–6.33 of IAEA GSR 
Part 7.  

9.9.3  Preliminary guidance or recommendations 

MS with no or few nuclear installations would benefit from collaborating with MS with an extended 
nuclear industry for the training of potential emergency workers. 

9.10  International cooperation 

It appears from the answers of the 10 MS that international cooperation is mostly addressed through 
bilateral arrangements between neighbouring countries. 

However, it is clear that different approaches are in place and there may be no agreement on what is 
adequate in terms of content and level of detail. This issue is central to the theme of closer cross-
border cooperation and ensuring coherence for protecting populations.  

The  BSS  Directive  addresses  the  importance  of  international  cooperation  in  case  of  an  emergency 
which  may  affect other  MS  or  third  countries,  in  order  to  facilitate the  organisation  of  radiological 
protection  in  all  countries  affected.  In  case  of  an  emergency,  this  cooperation  should  allow  to 
promptly  establish  contacts  with  countries  likely  to  be  affected,  share  the  assessment  of  the 
exposure  situation,  coordinate  protective  measures  and  inform  the  public  by  using  bilateral  and 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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international  information  exchange  and  coordination  systems.  MS  should  also  cooperate  in  the 
transition from an emergency exposure situation to an existing exposure situation. 

Exchange  of  information  is  very  important,  particularly  during  the  early  phase.  The  efficiency  of 
communication channels should be ensured. Periodical interaction between MS is very important for 
the  management  of  potential  cross-border  issues.  MS  should  be  aware  of  changes  in  the 
organizations and of the responsible persons. 

The need for international cooperation can also be found under the Requirement 22 of IAEA GSR Part 
7: 

•  When several different organizations of the State or of other States are expected to have or 
to  develop  tools,  procedures  or  criteria  for  use  in  the  response  to  an  emergency, 
arrangements  for  coordination  shall  be  put  in  place  to  improve  the  consistency  of  the 
assessments  of  the  situation,  including  assessments  of  contamination,  doses  and  radiation 
induced health effects and any other relevant assessments made in a nuclear or radiological 
emergency, so as not to give rise to confusion. 

•  Arrangements shall be made to coordinate with other States in the event of a transnational 
emergency any protective actions and other response actions that are recommended to their 
citizens and to their embassies in order either to ensure that they are consistent with those 
recommended in other States, or to provide an opportunity for them to explain to the public 
the basis for any differences. 

9.10.1  Issues to be further addressed 

DRAFT 

in  place.  Formal  arrangements  and  the  clear 

The  answers  of  the  10  MS  to  the  questionnaire  indicated  that  not  all  MS  have  formal  bilateral  or 
multi-lateral  arrangements 
identification  of 
responsibilities  are  however  essential.  The  levels  of  formalism  of  bilateral  and  multilateral 
arrangements differ amongst the MS. Discussion was held during the Workshop organized on 15-16 
November  2016  whether  to  have  formal  bi-/multilateral  arrangements  or  bi-/multilateral 
agreements. Although arrangements would allow more flexibility, it is important to have a sufficient 
level of formalism to ensure that common arrangements will be effectively followed.  

9.10.2  Available international guidance 

The guidance for Bilateral Arrangements issued by HERCA [HERCA, 2015a] could serve as the basis for 
these arrangements. 

9.11 Health protection of emergency workers 

9.11.1  Issues to be further addressed 

The  need  for  further  clarification  and  guidelines  respectively  has  been  specified  as  follows  in 
[RISKAUDIT, 2016]: 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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•  Emergency  workers  versus  emergency  helpers  that  may  be/feel  differently  protected  is  an 

issue. 

•  Concerning emergency workers, there has to be a clear distinction between those classified 
as  occupationally  exposed  workers  of  the  undertaking  and  the  emergency  workers  of  the 
organisations involved in the National Management System. 

9.11.2  Available international guidance 

The  IAEA  GSR  Part  7  sets  the  framework  for  protecting  emergency  workers  and  helpers.  The  IAEA 
DS474  provides  further  guidance  in  particular  for  protection  of  helpers  and  emergency  workers 
during the transition phase (who may not be occupationally exposed workers before). 

The HERCA has issued a document on emergency workers [HERCA, 2015b]. A HERCA task group has 
conducted  an  inquiry  to  assess  what  was  understood  by  'emergency  workers'  in  the  EU.  From  this 
inquiry,  some  significant  differences  appear  in  the  interpretation.  [HERCA,  2015b]  concludes 
however that there is no real need for harmonisation. 

DRAFT 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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10 Proposal for guidelines 

This section provides the recommendations of VNS in the light of the discussion in section 9, and the 
proposals for the key measures that should be addressed in any possible EU 'non-binding guidelines'.  

Available  international  guidance  is  generally  not  prescriptive  enough  to  set  up  detailed  and 
consistent  EP&R  arrangements  throughout  the  EU.  International  guidance  provides  a  basis  for 
developing EP&R arrangements. They should therefore be used as a starting point for the consistent 
implementation of the EP&R provisions throughout the EU. 

In  each  of  the  following  cases,  and  where  international  guidance  is  considered  to  support  national 
arrangements,  the  consistency  of  such  guidance  with  the  requirements  of  the  EU  legislation 
(including  the  BSS  Directive)  in  terms  of  terminology  and  guidance  values  should  be  assessed  in 
detail.  Where  differences  exist,  the  requirements  of  EU  legislation  in  the  field  should  take 
precedence.  

10.1 Transition  from  an  emergency  exposure  situation  to  an  existing 

exposure situation including recovery and remediation 

•  Follow  Requirement  18  of  GSR  Part  7  on  Terminating  a  Nuclear  or  Radiological  Emergency 
and Requirement 46 of GSR Part 7 on Transition from an emergency exposure situation to an 
existing exposure situation. 

•  Define  generic  principles  for  the  transition  from  an  emergency  exposure  situation  to  an 
existing  exposure  situation  including  recovery  and  remediation  on  basis  of  the  IAEA  draft 
safety  guide  DS474  on  the  arrangements  for  the  termination  of  a  nuclear  or  radiological 
emergency. 

DRAFT 

•  Prepare the  management of  social  aspects  of  the transition:  citizens  should  be given  some 

freedom to decide on their own. 

•  The  ongoing  work  performed  by  CODIRPA  in  France  could  be  used  as  an  example  of  good 
practices  in  the  EU  for  the  transition  from  an  emergency  exposure  situation  to  an  existing 
exposure  situation  for  nuclear  accidents  of  medium  scale  causing  short-term  radioactive 
release (less than 24 hours). 

10.2 Generic  criteria  for  particular  protective  measures,  default  triggers, 

operational criteria for particular actions 

•  Use the values provided in Appendix II of IAEA GSR Part 7 and IAEA GSG-2 unless a systematic 

optimisation process has been applied to define the values.  

•  Make  the  criteria  and  the  rational  for  their  selection  publicly  available.  Example  of  good 
practice within the EU for the definition and clear communication of criteria related to EP&R 
is found in [NORDIC, 2014]. The communication effort should focus on the overall protection 
strategy rather on the specific values of generic or operational criteria. 

•  Avoid defining absolute limits in the legislation to allow an integrated response in case of an 
emergency  situation.  Generic  criteria  and  operational  criteria  should  serve  as  reference 
values for response. 

•  For  potential  cross-border  emergency  situations,  the  generic  criteria,  default  triggers  or 
operational criteria should be agreed upon at a regional level considering the optimization of 
the overall cross-border protection strategy. 

  
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

• 

It should be noted that basis of the maximum permitted levels of radioactive contamination 
of food and feed in the Council Regulation (Euratom) 2016/52 is a reference level of 1mSv. 
Different assumptions apply to the generic criteria of 10mSv for restriction of  food, milk and 
drinking water as recommended in Table II.3 of GSR Part 7. 

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10.3 Protection strategies for the public and optimisation approaches 

• 

•  Follow the requirements of § 4.27–4.31 of IAEA GSR Part 7 on the protection strategy for a 
nuclear or radiological emergency, and use the guidance provided in §4.11–4.31 of IAEA GS-
G-2.1. and section 5 of IAEA EPR-NPP Public Protective Actions. 
It is very difficult to plan an optimal, detailed protection strategy due to the large number of 
situations that can be encountered in case of an emergency. Therefore, it seems essential to 
define  the  principles  to  be  followed  during  an  emergency  and  to  test  periodically  the 
effectiveness of the plans in various situations. This would allow assessing whether the level 
of  detail  is  sufficient.  It  is  the  optimisation  of  the  response  that  is  of  upmost  importance, 
rather  than  the  optimisation  of  the  protection  actions  at  the  planning  stage  for  a  set  of 
hypothetical  scenarios.  Here  the  objective  is  to  provide  sufficient  flexibility  during  an 
emergency for an adequate response. 

•  A  good  example  in  the EU  for the  definition of  protection  strategies  is  the  French  National 

Response Plan [SGDSN, 2014]. 

•  An unbalanced cross-border implementation of protective actions may lead to public distrust 
and  panic.  Attempts  to  explain  rationale  for  this  imbalance  have  little  chance  of  success 
during  the  emergency:  it  is  essential  to  clearly  communicate  on  the  rationale  of  the 
protection strategy in advance. 

•  Use  the  generic  EPZ  distance  of  Appendix  II  of  IAEA  GS-G-2.1.  unless  a  more  detailed 
assessment of the nuclear or radiological emergency situation has been performed. In such 
case, it is essential to adapt the size of the EPZ to the specific emergency situations. It is not 
the  harmonization  of  the  EPZ  distance  that  should  be  promoted  within  the  EU,  but  of  the 
method to evaluate this distance (including for the definition of scenario for releases). 

DRAFT 

•  Clearly  communicate  on  the  rationale  for  the  selection  of  EPZ  distances  and  associated 
protection strategies. The distance of EPZ is not necessarily a good indicator of the level of 
the  overall  protection.  The  focus  should  be  on  the  optimal  character  of  the  protection 
strategy. 

•  Define accident scenario's, in analogy to what is already done in several EU MS. 
•  Define  at  the  planning  stage  the  operational  subdivision  of  the  EPZ  into  protection  zones 
demarcated  by  features  readily  identifiable  by  people  within  that  area,  taking  into  account 
the prevailing wind direction, atmospheric stability, and the duration of potential releases. 
•  A  general strategy  to  extend  the  protection  zone  beyond the EPZ  should also be  prepared, 

following a graded approach. 

•  For potential cross-border emergency situations, the protective actions should be arranged 
through a sound bilateral or multilateral optimization process for the integrated protection 
strategy, by considering the local specific attributes influencing the protection strategies. 
•  Test/exercise periodically the emergency response plan to ensure effectiveness and identify 
where  improvement  is  needed.  This  is  particularly  important  for  potential  cross-border 
emergency  situations.  Periodical  test/exercise  is  a  means  to  assess  whether  the  level  of 
detail of the emergency plan is sufficient.  

  
 
 
 
 
 
 
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10.4 Reference levels for public exposure 

•  Consider that the reference levels are not absolute limits during an emergency or an existing 
exposure situation. They represent a level of dose above which it is generally unacceptable 
to plan to allow exposures to occur.  

•  The  selection  of  a  reference  level  should  fit  the  type  of  emergency  exposure  situation  and 
the protection strategy to which it will be applied. The type of reference level that is selected 
should  thus  be  tailored  to  meet  the type of  accident  scenario  under  consideration.  Ideally, 
regulatory authorities and operators will assess all credible risks, and authorities will be able 
to pre-select appropriate reference levels for the various accident scenarios that they judge 
to be relevant.  

•  Potential  emergency  situations  in  neighbouring  countries  should  be  considered  to  set 

• 

national reference levels. 
It is recommended to adopt an upper reference value for an emergency situation of 100 mSv 
acute or annual, unless a sound optimisation exercise has been performed, to allow enough 
flexibility (Luxemburg example).  

10.5 Involvement of stakeholders 

•  Nuclear  and  radiological  EP&R  should  be  integrated  into  civil  protection  mechanisms,  they 
should be a sub-set of the larger system of response to all disaster types, including chemical, 
biological,  radiological,  natural  and  man-made.  Capacities  of  the  EU  MS  and  synergies 
between them should be identified. 
Integration within the civil protection mechanisms of DG ECHO should be explored. 

• 

10.6 Reference levels for emergency occupational exposure 

• 

If not yet fixed, define and clarify the roles of what is considered in the emergency plan as 
'emergency worker'. Apply the reference levels in Art. 53 of the BSS Directive. 

DRAFT 

10.7 Assessment of potential emergency exposure situations and associated 

public and emergency occupational exposures 

•  For cross-border events, arrangements for a coherent way of assessing exposures (modelling 
tools and calculation methods) should be made at the preparedness stage between MS.  
It  is  recommended,  during  the  early  phase  of  an  accident,  to  rely  on  the  assessment  of 
potential emergency situation and exposures of the country in which the emergency occurs. 

• 

10.8 Information  to  the  public  (likely  to  be  affected  or  actually  affected  in 

the event of an emergency) 

•  Use the IAEA DS475 (once finalised) as a working basis to develop arrangements for public 
communications in preparedness and response for a nuclear or radiological emergency. 
•  Gaining  public  confidence  before  an  emergency  is  essential  to  have  an  optimal  behaviour 
and to avoid panic. Not only the national emergency plans but also their guiding principles 
should  be  made  publicly  available.  A  communication  effort  is  necessary  with  the  public  on 
the  rationale  behind  the  selection  of  values  and  on  the  overall  protection  approach.  The 
emphasis  should  be  set on  the optimal  character  of  the  protection  strategy  rather  than on 

  
 
 
 
 
 
 
 
 
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values  of  the  reference  levels,  operational  criteria  and  EPZ  distances.  The  latter  are  not 
necessarily good indicators of the overall level of protection. 

•  A  pro-active  communication  strategy  should  identify  which  issues  of  the  emergency  plan 
should  be  disseminated  through  information  campaigns,  which  will  take  advantage  from 
being additionally assessed by a public consultation and which issues related to emergency 
planning could be subject to a more demanding participative process.  

•  The extent and method of communication must also be linked to the target groups, i.e. the 
audience  to  who  the  communication  is  addressed.  Besides  the  general  public  and  more 
particularly the public living in the vicinity of nuclear installations, some target groups can be 
of specific interest and require a dedicated approach: rescue commanders and staff, medical 
rescue staff, practitioners (family doctors). Attention should also be paid to officials, school 
teachers, journalists. 

10.9 Prior  information  and  training  for  emergency  workers  and  all  other 

persons with duties and responsibilities in emergency response 

•  Follow the requirements of §6.28 – 6.33 of IAEA GSR Part 7 on training, drills and exercises 

for emergency preparedness and response. 

•  MS  with  no  or  few  nuclear  installations  should  collaborate  with  MS  with  a  larger  nuclear 

industry for the training of potential emergency workers. 

10.10 International cooperation 

•  Follow the requirements of §5.93 - 5.94 and §6.12 – 6.15 of IAEA GSR Part 7 on international 
assistance  for  emergency  preparedness  and  response,  and  the  coordination  of  emergency 
preparedness and response. 

DRAFT 

• 

•  Adopt the principle of “We do the same as is proposed by the accident country in the first 
hours of the accident” of the HERCA initiative for cross border arrangements [HERCA, 2014]. 
Implement  arrangements or  agreements  between  neighbouring  countries where  no  formal 
explicit  agreement  exist  today.  Consider  for  this  the  HERCA  guidance  for  bilateral 
arrangements [HERCA, 2015a]. 
Identify  the  existing  arrangements  and  agreements  between  MS  at  national  and  regional 
level.  Each  MS  should  be  well  aware  of  the  arrangements  for  EP&R  in  neighbouring 
countries, especially if there is a potential for cross-border event: maintain country fact sheet 
up to date. 

• 

•  Regular  exercises  should  be  conducted  to  test  and  improve  the  EP&R  strategies  for  cross-
border  events,  a  fortiori  between  MS  with  different  EP&R  arrangements.  These  exercises 
should include all the stakeholders likely to be involved in a real event and should simulate a 
realistic source terms. 

•  Consider to develop an integrated multi-country level emergency response plan for potential 
multi-country  emergency  situations.  Provision  to  implement  this  cooperation  should  be 
stipulated and competent offices should be identified. 

10.11 Health protection of emergency workers 

•  Follow the requirements of §5.49 – 5.61 of IAEA GSR Part 7 on the protection of emergency 

workers and helpers in an emergency. 

  
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

•  Define  and  clarify  the  roles  of  emergency  workers,  emergency  helpers  and  that  of 

occupationally exposed workers in those emergency situations. 

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DRAFT 

  
 
 
 
 
 
 
 
 
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11 Conclusions 

The  BSS  Directive  offers  strengthened  requirements  on  emergency  preparedness  and  response, 
taking due account of the lessons learned from the Fukushima accident. 

The BSS Directive fosters the harmonization of the safety objectives for EP&R at the EU level, not of 
the  protection  strategies  and  criteria  for  EP&R.  The  BSS  Directive  requires  optimizing  the  overall 
protection to define EP&R protection strategies for each emergency or existing exposure situation. 
The harmonization of protection strategies and criteria is beyond the scope of the transposition and 
the  implementation  of  the  BSS  and  can  be  conflicting  with  the  need  for  optimization  of  the  EP&R 
strategies for each emergency or existing exposure situation. 

The  BSS  Directive  has  introduced  the  concept  of  reference  levels  for  emergency  and  existing 
exposure situations. The requirements on EP&R in the BSS Directive can be considered as the highest 
level of consensus that was reached in the Council discussions. Efforts for the further harmonization 
of criteria are conducted by different organizations such as WENRA, HERCA and promoted through 
the NERIS platform. 

The requirements of the BSS Directive are generic in nature. Different standards are used by the MS 
for  their  implementation.  Same  standards  can  be  interpreted  differently,  a  fortiori  as  the 
optimization  process  to  be  conducted  is  essentially  a  judgmental  process.  The  lack  of  detailed 
guidelines to implement the BSS Directive results in differences in the EP&R arrangements and their 
level  of  details.  Such  differences  could  complicate  the  integrated  response  to  cross-border 
emergency  situations.  However,  the  problem  of  non-harmonised  protective  actions  and  criteria 
should not be over-emphasised. In fact, pushing for harmonised protective actions and criteria while 
DRAFT 
requiring the action and criteria to be optimised depending on the situation is a contradiction. It is 
the harmonization of the approaches to define protection strategies and criteria that could be better 
promoted.  As  stated  in  the  HERCA-WENRA  Approach,  aligning  protective  actions  along  adjacent 
national  borders  is  highly  desirable,  but  this  does  not  mean  that  there  should  be  a  European 
harmonization.  The  protective  actions  can  be  harmonised  for  each  NPP  using  local  cross-border 
cooperation  arrangements  on  a  regional  basis.  Harmonization  could  facilitate  the  integrated 
management of emergency issues, but it is at first the compatibility of EP&R for cross-border events 
that  should  be  ensured  between  MS.  However,  it  should  be  noted  that  specific  EU  legislation 
relevant to EP&R, for example in Council Regulation 2016/52, laying down maximum permitted levels 
of radioactive contamination of food and feed already contain harmonised values regarding products 
to be placed on the market in order to protect the EU population.   

Section  10  of  the  present  report  proposes  non-binding  guidelines  that  should  facilitate  a  coherent 
approach to EP&R through EU MS, referring also to existing good practices in MS.  

The transposition of the EP&R provisions of the BSS Directive in the legislation should allow enough 
flexibility  to  set  up  bilateral  or  multilateral  arrangements  for  cross-border  emergency  situations 
without violating the legislation of impacted MS.  

Further actions may be beneficial at the EU level for: 

• 

• 

the coordination of a more integrated EU response to the development of IAEA standards, in 
line with established processes and policies for doing so; 
the  development  of  a  more  harmonized  approach  to  the  application  of  international 
standards  and  recommendations  while  ensuring  transparency  regarding  any  rationale  for 
differences taking account of national and local circumstances; 

  
 
 
 
 
 
 
 
 
 
 
 
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• 

• 

• 

• 

• 
• 

the  identification  of  a  limited  set  of  scenarios  at  the  EU  level  to  be  considered  for  the 
definition of protection strategies, generic criteria, default triggers, and operational criteria 
by the MS; 
the integration of the nuclear and radiological EP&R into the civil protection mechanisms and 
involvement of DG ECHO; 
the  identification  of  synergies  between  MS  (in  particular  between  MS  with  few  capacities 
and countries with large capacities); 
the transfer of contaminated goods within the EU and the potential adaptation of clearance 
levels in case of an emergency; 
the development of FAQs at the EU level, in all official languages of the MS; 
to  ensure  that  bilateral  or  multilateral  agreements  are  in  place  and  that  the  protective 
actions are compatible at the regional level; 

•  and to conduct further research at EU level on effectiveness of protective measures such as 
sheltering and evacuation under accident situations, taking account of specific circumstances 
in EU countries.  

DRAFT 

  
 
 
 
 
 
 
 
 
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12 References 

ASN, 2012. Policy elements for post-accident management in the event of nuclear accident. 
CORDIPA, November 2012.  

EC, 2011. European Commission. Health and Consumers Directorate-General. Strategy for Generic 
Preparedness Planning. Technical guidance on generic preparedness planning for public health 
emergencies, 2011. 

ENCO, 2013. Review of Current Off-site Nuclear Emergency Preparedness and Response 
Arrangements in EU Member States and Neighbouring Countries. ENCO FR-(13)-29. Final Report. 

EPA, 2016. PAG Manual. Protective Action Guides And Planning Guidance For Radiological Incidents.  
 U.S. Environmental Protection Agency. November 2016. 

EUROSAFE, 2012. Translation of the emergency planning zone to an intervention zone: a 
multidisciplinary approach improving common understanding and implementation of protective 
Actions., C. Vandecasteele (FANC), H. De Neef (ADCC/DGCC), D. Degueldre (Bel V). 

FEMA, 2013. Communicating During and After a Nuclear Power Plant Incident. 

HERCA,  2014.  HERCA-WENRA  Approach  for  better  cross-border  coordination  of  protective  actions 
during the early phase of a nuclear accident. 

HERCA, 2015a. HERCA Guidance for bilateral arrangements. 

DRAFT 

HERCA, 2015b. Common understanding of Emergency Workers. 

HERCA, 2015c. Contamination of non-food products. 

IAEA, 2016. Conference report. International Conference on Global Emergency Preparedness 
and Response, 19–23 October 2015, Vienna, Austria. 

ICRP, 1992. Principles for Intervention for Protection of the Public in a Radiological Emergency. ICRP 
Publication 63. Ann. ICRP 22 (4). 

ICRP, 2006. The Optimisation of Radiological Protection - Broadening the Process. ICRP Publication 
101b. Ann. ICRP 36 (3). 

IFRC, 2015. Nuclear and Radiological Emergency Guidelines. Preparedness, Response and Recovery. 
International Federation of Red Cross and Red Crescent Societies, Geneva, 2015. 

NEA,  2011.  Practices  and  Experience  in  Stakeholder  Involvement  for  Post-nuclear  Emergency 
Management. 

NEA, 2013. Discussion on Implementation of ICRP Recommendations Concerning Reference Levels 
and Optimisation. Radiological Protection NEA/CRPPH/R(2013)2. 

NORDIC, 2014. The Nordic Guidelines and Recommendations on Protective measures in early and 
intermediate phases of a nuclear or radiological emergency. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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NRPB,  1990.  Board  Statements  on  Emergency  Reference  Levels.  Document  of  the  National 
Radiological Protection Board. Volume 1 No 4 1990. 

RISKAUDIT, 
int.org/downloads/04_epr-survey-results_thorsten-stahl.pdf. 

Report. 

Survey 

2016. 

EP&R 

TR-T2-704.D3BSS-R2. 

http://www.riskaudit-

SGDSN, 2014. National response plan, Major nuclear or radiological accidents, Number 
200/SGDSN/PSE/PSN – February 2014. 

VNS, 2016a. Selection of the 10 MS. VNS-GM-16-039. 

VNS, 2016b. Proceedings of the workshop on the transposition and implementation of the provisions 
of the Directive 2013/59/Euratom on EP&R. Brussels, 15-16 November 2016. VNS-TR-16-061. 

SSK, 2014. Planning areas for emergency response near nuclear power plants, Recommendation by 
the German Commission on Radiological Protection. 

DRAFT 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
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Annex 1:  Questionnaire sent to the 10 selected MS on the transposition 
and implementation of the BSS provisions on EP&R 

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The present document collects the answers provided by AT, BE, BG, CZ, DE, DK, FR, HR, IE, and LU 
to  the  questionnaire  on  the  transposition  and  implementation  of  the  Emergency  Preparedness 
and Response (EP&R) provisions of the BSS and provides the status of the work done by HERCA 
and WENRA on EP&R. 

The  following  questions  refer  to  the  provisions  for  EP&R  in  the  BSS  Directive  (Directive 
2013/59/Euratom) as laid down in Articles 7, 17, 53, 69-71, 97-99 and Annexes I, XI, and XII. 

Questions on development of national transposition/implementation plans 

1. How would you describe the current status of your national progress for the transposition of 
those  provisions  of  the  BSS  Directive  relevant  for  EP&R,  in  view  of  the  transposition  date  of  6 
February 2018? 

Enactment  of  EP&R  arrangements  in  line  with  the  BSS Directive  in  the  national  legislative  basis 
(Act, Law, Regulation, Administrative Provision, etc) is: 

AT 
BE 

BG 

CZ 
DE 
DK 
FR 
HR 
IE 
LU 

DRAFT 

On-schedule for the transposition date 
On-schedule for the transposition date 
It  is  essential  to  remind  that  FANC/Bel  V,  being  the  ‘Regulatory  Body’,  is  not 
responsible  for  the  elaboration  and  the  coordination  of  the  nuclear  and 
radiological EP&R plans (NEP). This responsibility is entrusted to the Minister of 
Home Affairs and assumed by the General Directorate Crisis Centre (DG CC), under 
the Ministry of Home Affairs. The FANC and Bel V are only involved when nuclear 
and radiological matters are concerned, in which case they provide technical and 
scientific expertise and play a major role in the redaction of legal documents and 
procedures. 
Within the nuclear and radiological EP&R plans, the FANC has the responsibility of 
the organisation and chairmanship of the evaluation and measurement groups. 
On-schedule for the transposition date. expected to enter in force until December 
2016. 
Already in place 
On-schedule for the transposition date 
On-schedule for the transposition date 
On-schedule for the transposition date 
On-schedule for the transposition date 
On-schedule for the transposition date 
On-schedule for the transposition date 

2.  To  what  extent  are/have  the  transposition  and  implementation  plans  and  strategies  in  the 
neighbouring  EU  countries  being/been  taken  into  account  in  developing  your  own  national 
transposition and implementation plans and strategies? 

AT 

In the yearly bilateral meetings on cooperation and information exchange in the 
field  of  nuclear  safety  and  radiation  protection  of  Austria  with  the  neighbouring 
states the transposition of the BSS Directive has been a topic since 2014.  

This information exchange has been taken into account in the discussions of EP&R 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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regulations currently under preparation. This information exchange was important 
especially  concerning  the  definition  of  the  reference  level,  procedures  for 
optimisation, emergency plans, optimized protection strategies and the definition 
of operational intervention levels.  

Furthermore  it  is  expected  that  there  will  be  more  information  exchange  on 
different aspects of the practical implementation of the BSS Directive. 

Some  additional  national  arrangements  are  needed  to  ensure  the  provision  of 
assistance to other countries in a timely manner, when requested.  

Not taken into account. There is no information about the plans and strategies of 
the neighbouring EU concerning the implementation of the BSS Directive relevant 
for  EP&R,  except  the  declarations  during  the  meetings  that  will  keep  the 
scheduled by the Directive transposition date of 6 February 2018. 

The implementations plans of neighbouring countries are not known in the sense 
to have a document or draft of legislation however during the bilateral meetings 
which are regularly organized every year we have informed each other about our 
major  plans  and  changes.  We  also  know  each  other  personally  and  we  are 
meeting in many occasions in international meetings and events and we have an 
opportunity  to  discuss  also  informally  identified  issues.  It  must  be  taken  into 
account  that  we  are  not  starting  from  the  scratch  –  a  lot  of  requirements  are 
already in current legislation and they work well. 

DRAFT 

Transposition  and  implementation  plans  and  strategies  in  neighbouring  EU 
countries have been taken into account as far as possible: e.g. a HERCA workshop 
has been used for information exchange about the implementations plans among 
HERCA members; regular meetings of bilateral commissions – e.g. Swiss-German-
Commission,  French-German-Commission,  Dutch-German-Commission  –  have 
been used to inform partners about the progress in each country 

Recommendations  or  codes  of  good-practice  could  have  simplified  the  cross-
border coordination of the transposition. 

To  a  limited  extend  at  this  point.  However,  recurring  exchange  of  information 
within  the  Nordic  Working  Group  on  Emergency  Preparedness  serves  as  part  of 
the basis upon which Denmark develop and evaluated plans and strategies.  

FRANCE  takes  part 
in  several  working  groups  on  Emergency  situation 
preparedness and response with neighbouring countries such as Germany, Swiss 
and  Luxembourg  where  the  national  transposition  actions  are  discussed  and 
compared. 

Transposition  and  implementation  plans  as  such  in  neighbouring  countries  have 
not been taken into account at all. However, Croatia has spent more than a year in 
a workgroup with Slovenia trying to harmonize EPR systems while both countries 
were  revising  them.  Many  part  of  the  systems  were  harmonized  and 
communication  between  countries  has  been  improved,  but  some  parts,  most 
prominently emergency preparedness zones, have not been harmonized. 

BE 

BG 

CZ 

DE 

DK 

FR 

HR 

IE 

The BSS Directive has been discussed at meetings of the UK-Ireland Contact Group 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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on Radiological Matters and also at bilateral meetings between the Environmental 
Protection  Agency  (EPA)  and  the  Office  for  Nuclear  Regulation  in  the  UK.    In 
addition the views of EU neighbouring countries at different European fora such 
as European Commission and HERCA meetings have been considered.  

LU 

Knowing of the differences in the preparedness arrangement of our neighbouring 
countries  and  aware  that  further  changes  in  those  countries  are  likely,  we  have 
opted for flexibility in our arrangements. Opting for rather high reference values 
and  relatively  large  planning  zone  should  allow  us  to  align  protective  measures 
during an emergency with the other countries. 

3. To what extent has the guidance in IAEA safety standards and safety guides (e.g. IAEA Safety 
Standards, General Safety Requirements No. GSR Part 7 issued 2015; Safety Guide GSG-2 issued 
2011,  Safety  Guide  GS-G-2.1  issued  2007,  etc)  been  taken  into  account  in  the  development  of 
your transposition and implementation plans and strategies? 

AT 

BE 

BG 

CZ 

DE 

Mainly IAEA General Safety Requirements GSR Part 7 has been taken into account 
in  the  field  of  EP&R.  Additional  requirements  which  are  not  covered  by  the  BSS 
Directive  have  been  taken  into  account  in  the  current  transposition  of  the  BSS 
Directive.  Examples  are  the  emergency  preparedness  categorization,  the 
classification  of  emergencies  and  additional  criteria  for  the  hazard  assessment 
which will be now in compliance with IAEA GSR Part 7. 

Royal  decrees  on  emergency  preparedness  and  response  are  general  in  nature 
and are considered as a good entry-point documents.  

DRAFT 

All IAEA documents Safety Standards, General Safety Requirements No. GSR Part 7 
issued 2015; Safety Guide GSG-2 issued 2011, Safety Guide GS-G-2.1 issued 2007, 
etc) are fully implemented.  

IAEA GSR Part 7 has been taken into account during preparation of new national 
legislation  seriously  and  fully.  CZ  also  participated  actively  during  preparation  of 
this important SS.  

Mainly the IAEA GSR Part 7 has been taken into account in the development of the 
national  plans  and  strategies,  since 
it  contains  detailed  requirements  for 
emergency exposure situations in many areas.  

Furthermore,  the  IAEA  “EPR-NPP  Public  Protective  Actions”  document  (issued 
2013)  influenced  the  development  of  protection  strategies  for  NPP  accidents  in 
the early phase of an accident.  

The  Draft  General  Safety  Guide  DS474  “Arrangements  for  the  Termination  of  a 
Nuclear  or  Radiological  Emergency”  is  currently  being  taken  into  account  for 
developing arrangements for the transition from emergency to existing exposure 
situations, but this is impeded to some extent by the ongoing development of this 
Safety Guide.    

DK 

To  a  limited  extend  at  this  point.  The  following  IAEA  safety  guides  will  be  taken 
into account as a minimum: 
• 

IAEA,  GSG-2:  Criteria  for  use  in  preparedness  and  response  for  a  nuclear  or 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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• 

• 

• 

radiological emergency, 2011.  
IAEA  GSR  part  7:  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 
IAEA,  EPR-NPP  Public  protective  actions,  Actions  to  protect  the  public  in  an 
emergency due to severe conditions at a light water reactor, 2013. 
IAEA, EPR-Method, Methods for Developing Arrangements for Response to a 
Nuclear or Radiological Emergency, 2003. 

Most of the requirements of AIEA safety standards are already taken into account 
in French regulation linked with the BSS transposition. 

Those  documents  have  been  analysed  and  are  used,  especially  GSR  Part  7. 
Specifically, plans are to implement GSR Part 7 completely or almost completely, 
and GSG-2 and GS-G-2.1 to a high degree. 

Ireland  underwent  an  IAEA  IRRS  mission  in  September  2015  to  review  Ireland’s 
regulatory framework in terms of radiation safety.  Many of the recommendations 
and  suggestions  from  the  review  team  to  address  gaps  with  regard  to  IAEA 
emergency preparedness safety requirements and safety guides will be addressed 
in the transposition and implementation of the BSS. 

Ireland’s  National  Emergency  Plan  for  Nuclear  Accidents  (NEPNA)  is  currently 
being  reviewed  and  updated.    As  part  of  this  process,  the  revised  plan  was 
reviewed  against  the  BSS  Directive  and  IAEA  GSR  Part  7  to  ensure  that  the 
requirements of both were satisfied. 

We  have  assessed  it  and  believe  that  our  emergency  plan  our  proposals  for  the 
legislative  up-dates  are  coherent  with  GSR-7.  However  a  few  updates  of 
procedural documents that belong to the emergency plan may be necessary. 

DRAFT 

FR 

HR 

IE 

LU 

4.  To  what  extent  is  the  guidance  issued  by  European  associations  such  as  HERCA  and  WENRA 
(e.g. HERCA-WENRA Approach for better cross-border coordination of protective actions during 
the early phase of a nuclear accident, 2014) being taken into account in the development of your 
implementation plans and strategies? Which elements of the HERCA-WENRA Approach are being 
considered for implementation or will be implemented and which elements will not? 

AT 

According  to  the  regulations  (Ordinance  on  Interventions)  under  preparation  in 
addition to the reference level in emergency exposure situations of 100 mSv/year 
and  the  generic  criteria  for  protective  actions,  operational  criteria  have  to  be 
elaborated and will be part of the emergency plans in Austria. 

HERCA-WENRA  approach  is  taken  into  account  in  the  operational  criteria  as 
emergency  action  levels  in  the  pre-release  phase  of  a  severe  NPP  accident 
(protective actions based on judgement factors regarding the plant status). 

the  other  hand 

On 
the  HERCA-WENRA  approach  will  be  a  practical 
implementation of requirements of the BBS Directive on international cooperation 
in  the  preparedness  phase  and  in  case  of  a  transnational  emergency.  The  BSS 
requirements  regarding  international  cooperation  are  currently  part  of  the  BSS 
transposition into Austria regulations (Ordinance on Interventions). 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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BE 

BG 

CZ 

DE 

DK 

FR 

We  support  the  HERCA-WENRA  approach.  This  approach  will  be  taken  into 
account in the next revision of the NEP. 

in  consideration  during  the 
is  also  taken 
The  HERCA-WENRA  Approach 
implementation of the BSS Directive relevant for EP&R. At the present evaluation 
is done form BNRA of all recommendations relevant for EP&R – EU BSS Directive, 
IAEA  GSR-Part-7  and  HERCA-WENRA  Approach.  The  purpose  of  evaluation  is  to 
prepare the right legal articles describing the application off all this requirements 
in a proper and correct way. 

HERCA  is  currently  doing  a  detailed  survey  of  implementation  of  HERCA  WENRA 
approach  recommendations  –  so  maybe  you  can  cooperate  with  them.  They 
distributed  a  questionnaire  –  see  attachment.  Czech  Republic  has  most  of  these 
recommendations already included in national legislation, and has developed very 
sophisticated  system  for  evaluation  of  situation  during  emergency –  incl.  SW  for 
prognosis based on the source term assessed. We are not going to enlarge EPZ at 
the moment – we don´t see an urgent need for this and we agree with EC position 
that  such  step  could   be  interpreted  as   'official'   re-evaluation  of  the  risks  of 
nuclear  power  by  the  public  and  would   therefore   support   the  irrational   anti-
nuclear   sentiment.   Implementing  urgent  countermeasures  in  an  area  very far 
from the NPP  could provoke panic and cause more harm than benefit.  

have 

HERCA 

guidelines 

especially 
All 
-  Practical  proposals  for  further  harmonisation  of  the  reactions  in  European 
countries 
(2013) 
-  HERCA-WENRA  Approach  for  a  better  cross-border  coordination  of  protective 
(2014) 
actions 
(2015) 
- 

to  any  distant  nuclear  or 

nuclear 
Arrangements 

radiological  emergency 

during 
Guidance 

of 
Bilateral 

DRAFT 
early 
for 

considered, 

accident 

phase 

been 

the 

a 

is 

to 

intended 

implement 

It 
the  HERCA-WENRA-Approach,  especially. 
- underlying principles: shared technical understanding, coordination and mutual 
trust 
-  simplified  schemes  for  protective  actions  for  the  initial  stage  of  a  highly 
improbable  severe  accident  (i.e.  Fukushima-like),  requiring  rapid  decisions  for 
protective actions while very little is known about the situation. 

To  a  limited  extend  at  this  point.  However,  all  HERCA-WENRA  guidance  relevant 
for  the  development  and  implementation  of  emergency  plans  and  strategies  for 
countries  without  nuclear  power  plants  will  be  considered  –  (HERCA-WENRA 
rapport  2014:  Approach  for  a  better  cross-border  coordination  of  protective 
actions during the early phase of a nuclear accident) 

France  is  finalizing  a  reflection  on  the  possible  improvements  of  bilateral  and 
multilateral  arrangements,  the  contents  of  data  which  could  be  exchanged  and 
the procedures for improvement. Country fact sheets have been developed.  

The  French  national  plan  and  operational  procedures  take  into  account  severe 
accidents.  The  local  decision-making  process  would  be  based  on  the  available 
information,  on 
and  nuclear  emergency  experts 
recommendations, taking into account exchanges with neighbouring countries. 

authorities 

safety 

The recommendations of the HERCA / WENRA approach have been integrated in 

  
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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HR 

IE 

LU 

the currently reconsidering of the local response plans process and are faced to all 
civil security preoccupations, as recommended. 

Croatian plans for an emergency will contain triggers for early protective actions in 
the  early  phase  of  an  emergency  which  are  in  accordance  with  HERCA-WENRA 
Approach  for  better  cross-border  coordination  of  protective  actions  during  the 
early phase of a nuclear accident. Also, radii of emergency preparedness zones will 
be in accordance with recommendation in the HERCA-WENRA Approach for better 
cross-border coordination of protective actions during the early phase of a nuclear 
accident. 

Guidance  from  European  associations  such  as  the  HERCA-WENRA  Approach  for 
better cross-border coordination of protective actions during the early phase of a 
nuclear  accident 
in  the  development  of 
is  being  taken 
implementation plans and strategies. 

into  account 

Ireland is a non-nuclear country and the nearest nuclear power plant is over 100 
km  away.    Ireland  will  continue  to  maintain  and  test  its  bilateral  arrangements 
with its nearest neighbour, the UK, on the early exchange of information.  Ireland 
will  also  recommend  that  Irish  citizens  in  the  accident  country  follow  the  advice 
being given by the accident country. 

Decisions regarding the selection and implementation of protective measures will 
be  based  on  independent  assessments  performed  in  Ireland  in  addition  to  the 
advice being given in the accident country. 

DRAFT 

The alignment of protective actions with neighbouring countries have already for 
approximately 15 years been the main criteria in decision taking. We had before 
intervention  levels  in  a  range  of  values,  now  we  have  defined  them  with  a  high 
degree of flexibility. 
We have updated information exchange protocols with France to implement the 
HWA and discuss it with Belgium. 
All recommendations of the HWA for the preparedness that we need to be able to 
align  our  decisions  are  in  place.  E.g.  we  do  not  need  access  to  the  expertise 
products of IRSN, since we trust in their expertise and the results out of it. 
The  information  exchanges  according  to  the  HWA  now  only  take  place  between 
the  nuclear/radiological  safety  authorities.  It  will  be  important  that  the  decision 
taking  bodies  between  our  neighboring  states  and  us  will  adhere  to  the  same 
principles. 

On the second part of the HWA, we are coherent with the extend of the planning 
zones: 

a)  We  have  now  a  15km  planning  zone  for  evacuation  (for  before 
release) and have stared works on post accidental preparedness 
to enlarge this area after release to 30 km. 

b)  We have distributed Iodide tablets through the full country, plus 
stockpiles  in  the  25  km  zone,  and  stockpiles  in  the  schools 
concerning the full country. 

c)  We  have  25  km  planning  zone  for  sheltering.  If  needed  a 
recommendation for sheltering the full country could be given in 
an emergency. 

What is still not formalized is a fast “alerting” mode for triggering a fast response 

  
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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based on the JEF’s described in the HWA). We also believe that in such a situation, 
a  common  evacuation  plan  of  all  regions/countries  along  the  NPP  would  be 
needed with priority on the 5 km, then a stepwise enlargement as long as releases 
do not occur. (principle of no evacuation under the plume) 

If not being implemented, what are the reasons? 

AT 
BE 
BG 
CZ 

DE 

DK 

FR 

HR 
IE 

LU 

- 
- 
- 
- 

- 

- 

The final French government position is not defined yet as many work is still under 
progress. 

- 
Protective  actions  such  as  evacuation  and  Iodine  Thyroid  Blocking  will  not  be 
implemented in Ireland due to our distance from the nearest nuclear power plant. 

Not  everybody  who  has  responsibilities  has  yet  been  involved,  the  declination 
from  capitals  to  the  regions  takes  time;  the  HWA  has  no  binding  character,  not 
everybody  is  convinced,  a  local  seminar  will  be  planned  for  2017  in  the  larger 
region to discuss implementation on the local level. 

DRAFT 

5.    Is  other  national,  regional,  or  international  level  guidance  being  taken  into  account  in  the 
development  of  national  plans  and  strategies  for  enactment  of  the  BSS  provisions,  and  if  so 
which? 
AT 

For  the  development  of  emergency  plans  the  following  international  guidance 
documents also have been taken into account: 

•  Emergency  Notification  and  Assistance,  Technical  Operations  Manual, 

IAEA, EPR-ENATOM 2012. 

•  Preparation, Conduct and Evaluation of Exercises to Test Preparedness for 

a Nuclear or Radiological Emergency, IAEA, EPR-EXERCISE 2005. 

•  Method  for  Developing  Arrangements  for  Response  to  a  Nuclear  or 
IAEA-

IAEA,  EPR-METHOD  2003  (Updating 

Radiological  Emergency, 
TECDOC-953). 

•  Manual  for  First  Responders  to  a  Radiological  Emergency,  EPR-FIRST 

RESPONDERS 2006. 
IAEA Response Assistance Network – RANET, IAEA, 2006. 

• 
•  A  model  national  emergency  response  plan  for  radiological  accidents, 

IAEA-TECDOC-718, IAEA, 1993. 

•  COUNCIL  REGULATION  (Euratom)  87/600  of  14  December  1987  on 
Community  arrangements  for  the  early  exchange  of  information  in  the 
event of a radiological emergency. 

•  COUNCIL  REGULATION  (Euratom)  2016/52  of  15  January  2016  laying 
down  maximum  permitted  levels  of  radioactive  contamination  of  food 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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and  feed  following  a  nuclear  accident  or  any  other  case  of  radiological 
emergency,  and  repealing  Regulation  (Euratom)  No  3954/87  and 
Commission Regulations (Euratom) No 944/89 and (Euratom) No 770/90. 
•  HERCA  Report:  Practical  proposals  for  further  harmonisation  of  the 
reactions  in  European  countries  to  any  distant  nuclear  or  radiological 
emergency 

BE 

For  the  development  of  emergency  plans  the  following  international  guidance 
documents also have been taken into account: 

•  HERCA  Report:  Practical  proposals  for  further  harmonisation  of  the 
reactions  in  European  countries  to  any  distant  nuclear  or  radiological 
emergency 
French CORDIRPA 

• 

BG 

CZ 

DE 

DK 

FR 

HR 

IE 

Yes, the Ministry of Health and General Directorate Fire safety and Civil Protection 
are  involved  in  the  discussions.  The  Regional  Directorate  Fire  safety  and  Civil 
Protection on local level (within the emergency planning zone) are also involved. 
The  HERCA-WENRA  approach  is  under  implementation  in  the  National  and 
Regional off-site emergency plan. 

IAEA   GSG2.1.(2007),  GSG  2  (2011),  Method  for  Developing  a  Communication 
Strategy and Plan for a Nuclear or Radiological Emergency (2015) 

ICRP 109,  111 

Results, feedbacks from national or international emergency exercises  

DRAFT 

None 

ICRP 109: Application of the Commission’s recommendations for the protection of 
people in emergency exposure situations, Vol. 29, No 1, 2009. 

Protective Measures in Early and Intermediate Phases of a Nuclear or Radiological 
Emergency, Nordic Guidelines and Recommendations, 2014. 

No 

Results  of  the  working  group  Delovna  skupina  za  pripravo  podlag  ocene 
ogroženosti  za  jedrsko  nesrečo  v  NEK,  organized  by  Slovenia  with  Croatian 
participation. Croatia could not agree to a full conclusion and has issued Separate 
opinion, but many parts of the EPR systems were agreed upon. 

National 
National Emergency Plan for Nuclear Accidents 

A Framework for Major Emergency Management 

A  Protocol  for  Multi-Agency  Response  to  Radiological-Nuclear  Emergencies, 
working draft 

Guidance  Notes  on  Intervention  Planning  and  Emergency  Preparedness  for 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Radiological Accidents 

Strategic Emergency Planning Guidance 

 Report VNS-TR-16-035 v1 

Page 73/100 

Guidelines for Co-ordinating a National-Level Emergency/Crisis Response 

LU 

French CORDIRPA 

Questions on development of guidance to support implementation 

For  the  implementation  phase  of  the  BSS  Directive,  the  development  of  'implementation 
guidelines' (in the form of non-binding guidance, recommendations or codes of good-practice) at 
the EU level is under consideration to help the practical implementation of the legal provisions 
and to facilitate the coherent and consistent implementation of the provisions on EP&R amongst 
EU Member States. 

6.  Based  on your experience  of  national  transposition and  implementation  plans  and  strategies 
for  the  BSS  Directive  (in  particular  questions  or  issues  arising  during  transposition  phase,  or 
difficulties in interpretation of the legal provisions, foreseen difficulties in implementation at the 
national level), please give a rating of the following topics for which could be considered for the 
development of 'implementation guidelines' at the EU level as described above.  

Please rate between 1 to 3 (1=most useful, 2=moderately useful, 3=least useful) 

Topic 
 (Based on Articles 17, 70,71 97, and Annex XI, Part A) 

DRAFT 

a.  Assessment  of  potential  emergency  exposure  situations  and  associated  public  and 
emergency occupational exposures 

b. Health protection of emergency workers 

c.  Prior  information  and  training  for  emergency  workers  and  all  other  persons  with 
duties and responsibilities in emergency response 

d. Information to the public (likely to be affected or actually affected in the event of an 
emergency) 

e. Involvement of stakeholders 

f.  Transition  from  an  emergency  exposure  situation  to  an  existing  exposure  situation 
including recovery and remediation 

Topic 
(Based on Articles 7, 98, 99 and Annex XI, Part B) 

g. Reference levels for public exposure 

h. Reference levels for emergency occupational exposure 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

i. Protection strategies for the public and optimisation approaches 

j.  Generic  criteria  for  particular  protective  measures,  default  triggers,  operational 
criteria for particular actions 

 Report VNS-TR-16-035 v1 

Page 74/100 

k. International cooperation 

Topic 

a. 
b. 
c. 
d. 
e. 
f. 
g. 

h. 
i. 
j. 
k. 

AT 
1 
2 
2 
1 
1 
1 
1 

2 
1 
1 
1 

BE 
3 
3 
3 
3 
2 
1 
1 

2 
2 
1 
2 

BG 
1 
1 
1 
3 
3 
1 
1 

1 
1 
1 
2 

MS Rating (1,2 or 3) 

DE 
2 
3 
3 
2 
1 
1 
1 

1 
1 
2 
3 

DK 
1 
2 
1 
2 
3 
2 
1 

1 
2 
1 
3 

FR 
2 
3 
3 
2 
1/2 
3 
2 

3 
2 
2 
3 

HR 
3 
1 
2 
2 
1 
1 
3 

1 
2 
1 
1 

CZ 
2 
3 
2 
2 
3 
1 
3 

3 
2 
2 
2 

IE 
1 
3 
3 
3 
2 
1 
1 

1 
1 
2 
3 

LU 
3 
2 
2 
1 
2 
1 
3(too 
late 
now) 
3 
2 
2 
2 

7. Based on your national experience and plans for transposition and implementation of the BSS 
provisions,  which  recommendations,  guidance  or  standards  that  already  exist  at  European  or 
international  level  should  be  taken  into  consideration  in  order  to  formulate  any  EU-level 
guidelines, in the following areas: 

DRAFT 

a) Article 7 (Reference levels) 

AT 

BE 

BG 

CZ 

DE 

•  Radiation  Protection  and  Safety  of  Radiation  Sources:  International  Basic 
2011 
IAEA 

Standards, 

Safety 

Part 

GSR 

3, 

•  Protective  measures  in  early  and  intermediate  phases  of  a  nuclear  or 
radiological  emergency,  Nordic  Guidelines  and  recommendations,  « Nordic 
Flaggbook » 

•  Guidelines  for  Iodine  Prophylaxis  following  Nuclear  Accidents,  1999,  World 

Health Organization (WHO), Geneva 

- 

• 

• 

• 

IAEA  GSG-2  Criteria  for  Use  in  Preparedness  and  Response  for  a  Nuclear  or 
Radiological Emergency, 2011 
IAEA  GS-G-2.1  Arrangements  for  Preparedness  for  a  Nuclear  or  Radiological 
Emergency, 2007 
IAEA  EPR-NPP  PUBLIC  PROTECTIVE  ACTIONS-2013,  Actions  to  Protect  the 
Public in an Emergency Due to Severe Conditions at a Light Water Reactor 

ICRP 103,109 

Planned update of the ICRP publications 109 and 111 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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DK 

FR 

HR 

IE 

ICRP,  Publication  103,  The  2007  Recommendations  of  the 
Commission on Radiological Protection 

International 

ICRP Publication 109: Application of the Commission's Recommendations for the 
Protection of People in Emergency Exposure Situations 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

ICRP  Publication  103:  The  2007  Recommendations  of  the 
Commission on Radiological Protection, 2007 

International 

ICRP Publication 109: Application of the Commission's Recommendations for the 
Protection of People in Emergency Exposure Situations, 2009 

IAEA  GSG-2  Criteria  for  Use  in  Preparedness  and  Response  for  a  Nuclear  or 
Radiological Emergency, 2011 

LU 

If there is any, we would be happy to know 

b) Article 17 (Prior information and training for emergency workers) 

AT 
BE 

BG 

CZ 
DE 

DK 

FR 

HR 

IE 

- 
 HERCA Common Understanding of Emergency Workers, 2015 

DRAFT 

IAEA  GSR  Part  7  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 

• 

• 

IAEA-EPR-First Responders, 2006 Manual for first responders to a radiological 
emergency  
IAEA  GSG-2  Criteria  for  Use  in  Preparedness  and  Response  for  a  Nuclear  or 
Radiological Emergency, 2011 
IAEA  EPR  -  First  Responders  2006  Manual  for  First  Responders  to  a 
Radiological Emergency 

- 
- (we are not aware of such recommendations or guidance) 

IAEA,  EPR-FIRST  RESPONDERS,  Emergency  Preparedness  and  Response:  Manual 
for First Responders to a Radiological Emergency, 2006. 

US  Department  of  Transportation,  Pipeline  and  Hazardous  Materials  Safety 
Administration: 2016, EMERGENCY RESPONSE GUIDEBOOK 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

HERCA Common Understanding of Emergency Workers, 2015 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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IAEA  GSR  Part  7  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 

Manual for First Responders to a Radiological Emergency, IAEA 2006 

LU 

HERCA – Common understanding of emergency workers 

c)  Article 70 (Information  to  members  of  the  public  likely  to  be  affected  in  the event  of  an 
emergency) 

AT 
BE 
BG 

CZ 

DE 

DK 

FR 

HR 

IE 

LU 

See d) Article 71 
- 
• 

IAEA  EPR-Public  Communications  2012  Communication  with  the  Public  in  a 
Nuclear or Radiological Emergency 
IAEA  EPR-NPP  PUBLIC  PROTECTIVE  ACTIONS-2013,  Actions  to  Protect  the 
Public in an Emergency Due to Severe Conditions at a Light Water Reactor 

• 

IAEA communication document 

IAEA 

- 
(2013) 
-  Draft  IAEA  Safety  Guide  DS  475  -  Arrangements  for  Public  Communications  in 
Preparedness and Response for a Nuclear or Radiological Emergency 

Communication 

Public 

EPR 

IAEA, EPR Public Communications, Communication with the Public in a Nuclear or 
Radiological Emergency, 2012 

IAEA,  EPR  Public  Communication  Plan,  Method  for  Developing  a  Communication 
Strategy and Plan for a Nuclear or Radiological Emergency, 2015 

DRAFT 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

Communication with the public in a Nuclear or Radiological Emergency, IAEA IEC 
2012 

Method  for  developing  a  communication  strategy  and  plan  for  a  nuclear  or 
radiological emergency, IAEA IEC 2015 

To  our  knowledge  there  exists  nothing  recent  that  would  take  into  account 
modern  communication  technologies  and  takes  into  account  the  sensitivities  of 
the populations. 

d)  Article  71  (Information  to  members  of  the  public  actually  affected  in  the  event  of  an 
emergency) 
• 

IAEA, Communication with the Public in a Nuclear or Radiological Emergency, 
IAEA EPR communications 2012 

AT 

•  WHO/CDS/2005.31,  Effective  Media  Communication  during  Public  Health 

Emergencies, A WHO HANDBOOK, 2005     

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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• 

IAEA,  EPR-Public-Communication-Plan-2015  Method 
for  Developing  a 
Communication  Strategy  and  Plan  for  a  Nuclear  or  Radiological  Emergency, 
2015  

•  US EPA, Communicating Radiation Risks, crisis communication for emergency 

responders, 2008 

- 
• 

• 

IAEA  EPR-Public  Communications  2012  Communication  with  the  Public  in  a 
Nuclear or Radiological Emergency 
IAEA  EPR-NPP  PUBLIC  PROTECTIVE  ACTIONS-2013,  Actions  to  Protect  the 
Public in an Emergency Due to Severe Conditions at a Light Water Reactor 

IAEA communication document 

(see above) 

IAEA, EPR Public Communications, Communication with the Public in a Nuclear or 
Radiological Emergency, 2012 

IAEA,  EPR  Public  Communication  Plan,  Method  for  Developing  a  Communication 
Strategy and Plan for a Nuclear or Radiological Emergency, 2015 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

Communication with the public in a Nuclear or Radiological Emergency, IAEA IEC 
2012 

DRAFT 

Method  for  developing  a  communication  strategy  and  plan  for  a  nuclear  or 
radiological emergency, IAEA IEC 2015 

BE 
BG 

CZ 

DE 

DK 

FR 

HR 

IE 

LU 

(CORDIRPA) 

e) Article 97 Emergency management system 

AT 

BE 

BG 
CZ 

DE 

DK 

• 

• 

IAEA,  Preparedness  and  Response  for  a  Nuclear  or  Radiological  Emergency 
General Safety Requirements GSR Part 7, 2015 
IAEA,  draft  document:  Arrangements  for  the  Termination  of  a  Nuclear  or 
Radiological Emergency, 2016 

IAEA,  Preparedness  and  Response  for  a  Nuclear  or  Radiological  Emergency 
General Safety Requirements GSR Part 7, 2015 

- 
IAEA GSR Part7 

IAEA GSR Part 7 

IAEA,  EPR-Method,  Methods  for  Developing  Arrangements  for  Response  to  a 
Nuclear or Radiological Emergency, 2003. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Report VNS-TR-16-035 v1 

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VINÇOTTE NUCLEAR SAFETY 

FR 

HR 

IE 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

IAEA  GSR  Part  7  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 

Method  for  Developing  Arrangements  for  Response  to  a  Nuclear  or  Radiological 
Emergency, IAEA 2003 

LU 

?? 

f) Article 98 Emergency Preparedness 

AT 

BE 

BG 

CZ 

DE 

DK 

FR 

HR 

IE 

EPR-METHOD-2003:  Method  for  developing  arrangements  for  response  to  a 
nuclear or radiological emergency, 2003.  

EPR-FIRST-RESPONDERS-2006,  Manual  for  First  Responders  to  a  Radiological 
Emergency, 2006. 

- 

EPR  –Method  2003  Method  for  Developing  Arrangements  for  Response  to  a 
Nuclear or Radiological Emergency Updating IAEA-TECDOC-953 

IAEA GSR Part 7, ICRP 109 

DRAFT 

IAEA GSR Part 7 

IAEA,  GSG-2:  Criteria  for  use  in  preparedness  and  response  for  a  nuclear  or 
radiological emergency, 2011.  

IAEA  GSR  part  7:  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

N/A 

IAEA  GSR  Part  7  Preparedness  and  Response  for  a  Nuclear  or  Radiological 
Emergency, 2015 

LU 

- 

g) Article 99 International cooperation 

AT 

HERCA: Guidance for Bilateral Arrangements, 2015 

HERCA-WENRA  Approach  for  a  better  cross-border  coordination  of  protective 
actions during the early phase of a nuclear accident, 2014 

HERCA: Practical proposals for further harmonisation of the reactions in European 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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BE 

BG 
CZ 
DE 

DK 

FR 

HR 

IE 

countries to any distant nuclear or radiological emergency 

HERCA - Guidance for Bilateral Arrangements 

- 
- 
HERCA guidance: 
-  Practical  proposals  for  further  harmonisation  of  the  reactions  in  European 
countries 
(2013) 
-  HERCA-WENRA  Approach  for  a  better  cross-border  coordination  of  protective 
(2014) 
of 
the 
actions 
- Guidance for Bilateral Arrangements (2015) 

to  any  distant  nuclear  or 

radiological  emergency 

accident 

nuclear 

during 

phase 

early 

a 

None specified 

For all the areas listed : ICRP publications and AIEA  safety standards (GSR Part 7…) 

Scandinavian Flagbook 

HERCA-WENRA  Approach  for  a  better  cross-border  coordination  of  protective 
actions during the early phase of a nuclear accident, 2014 

HERCA Guidance for Bilateral Arrangements, 2015 

LU 

HERCA - Guidance for Bilateral Arrangements 

DRAFT 

8.  Based  on  your  national  experience  on  the  implementation  of  the  BSS  provisions,  which 
standards  or  best  practices exist  at  national  level  could  serve  as  example  in  order to  formulate 
any EU-level guidelines, in the following areas: 

a) Article 7 (Reference levels) 

AT 
BE 
BG 

CZ 

DE 

DK 

FR 

- 
- 
Finland experience 
German experience 

The  best  way  is  to  follow  ICRP  103  and  to  understand  the  sense  and  role  of 
reference levels.  We always will apply optimization and will try to keep exposure 
of  any  person  ALARA,  so  even  if  we  will  have  RL  100mSv  it  doesn´t  mean  that 
doses  finally  will  be  on  such  level  but  it  depends  on  circumstances  and  it  is  not 
good to establish RL on 20mSv if I know in advance that there could be a scenario 
when  it  is  not  possible  to  keep  doses  on  this  level –  this  will  limit  us  in  decision 
making and to push us to do measures which finally could not be justified – and 
this would be irresponsible step from the regulators  

Future German Law on Radiation Protection (under development) 

Protective Measures in Early and Intermediate Phases of a Nuclear or Radiological 
Emergency, Nordic Guidelines and Recommendations, 2014. 

None 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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HR 

IE 

LU 

N/A 

None 

Derivation of flexible intervention levels and OIL’s in the same spirit as RL: above 
one should/shall, below one can 

Defining  an  RL  for  the  first  year  taking  into  account  exposure  during  the 
emergency and during the transition phase) 

b) Article 17 (Prior information and training for emergency workers) 

AT 

BE 
BG 

CZ 

DE 
DK 

FR 

HR 

IE 

LU 

Austrian  Ordinance  on  Interventions,  §  12  and  Annex  7,  2007  (in  German): 
www.bmlfuw.gv.at/umwelt/strahlenatom/strahlenschutz/rechtsvorschriften/intV 

- 
Finland experience 
German experience 

- 

- 
Danish  Health  Authority,  Radiation  Protection:  Handling  of  Accidents  with 
Radioactive Materials, 2001. (Guidance material in Danish) 

Danish  Health  Authority:  Guidance  on  the  Planning  of  Health  Measures  in 
Emergency  Situations,  2011  (Guidance  material  in  Danish  on  the  managing  of 
hospital emergency rooms and ambulances) 

DRAFT 

Danish Emergency Management Agency: Guidelines for Emergency Management at 
CBRNE incidents, 2016. (Guidance material in Danish) 

Arrêté  du  8/12/2005  relatif  au  contrôle  d'aptitude  médicale,  à  la  surveillance 
radiologique  et  aux  actions  de  formation  ou  d'information  au  bénéfice  des 
personnels 
la  gestion  d'une  situation  d'urgence 
radiologique (Annexe 1) 

intervenants  engagés  dans 

N/A 

Incidents Involving Ionising Radiation Standard Operational Guidance 7.07 (National 
Directorate for Fire and Emergency Management) 

Since  emergency  works  will  not  remember  what  they  have  once.  learned  the  day 
they  need  it,  we  have  compiled  (additionally  to  their  training)  a  set  of  simple 
messages how to protect themselves in a zone. They receive this together with the 
protection equipment, immediately before they are mobilized. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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c)  Article 70 (Information  to  members  of  the  public  likely  to  be  affected  in  the event  of  an 
emergency) 
- 
- 
Finland experience 
German experience 

AT 
BE 
BG 

CZ 
DE 
DK 

FR 

HR 

IE 

LU 

- 
Perhaps  with  more  pertinence  to  EU-BSS  articles  16  and  92:  Guidance  on 
Radioactive Materials in Scrap Yards, 2002 (Guidance on small scale emergencies 
involving the detection of orphan sources at scrap yards - in Danish) 

Arrêté  du  4  novembre  2005  relatif  à  l’information  des  populations  en  cas  de 
situation d’urgence radiologique 

N/A 

N/A 

www.infocrise.lu    (it  has  not  yet  been  translated  in  sufficient  languages  –  but  it 
exists in simple language for people with deafness) 

d)  Article  71  (Information  to  members  of  the  public  actually  affected  in  the  event  of  an 
emergency) 
- 
- 
Finland experience 
German experience 

AT 
BE 
BG 

DRAFT 

CZ 

DE 
DK 

FR 

HR 

IE 

- 

- 
None specified 

Arrêté  du  4  novembre  2005  relatif  à  l’information  des  populations  en  cas  de 
situation d’urgence radiologique 

N/A 

A  Framework  for  Major  Emergency  Management  Guide  to  Working  with  the 
Media 

A  Framework  for  Major  Emergency  Management  Inter-Agency  Communication 
Plan 

Preparing for Major Emergencies Handbook 

LU 

- 

e) Article 97 Emergency management system 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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AT 

BE 
BG 

CZ 

DE 

DK 

FR 

HR 

IE 

• 

see answer to f) Article 98  

- 
Finland experience 
German experience 

- 

Future federal nuclear and radiological emergency plans 

Danish Emergency Management Agency. Crisis Management in Denmark, 2015 

Guidance  on  the  Planning  of  Health  Measures  in  Emergency  Situations,  2011 
(Guidance material in Danish on the managing of hospital emergency rooms and 
ambulances) 

The  national  plan  for  responding  to  a  major  nuclear  or  radiological  accident 
(SGDSN) 

N/A 

A  Protocol  for  Multi-Agency  Response  to  Radiological-Nuclear  Emergencies, 
working draft 

Guidance  Notes  on  Intervention  Planning  and  Emergency  Preparedness  for 
Radiological Accidents, Radiological Protection Institute of Ireland 

DRAFT 

Guidelines for Co-ordinating a National-Level Emergency/Crisis Response  

LU 

- 

f) Article 98 Emergency Preparedness  

AT 

Austrian  off-site  emergency  planning  documentation  (in  German  language): 
www.bmlfuw.gv.at/umwelt/strahlen-atom/notfallplanung/behoerdliche-
vorkehrungen/notfallvorsorge 

•  Emergency plan for NPP accidents 
•  Emergency plan for Austrian installations 
•  Emergency plan for radiological terror 
•  Emergency plan for radiological emergencies with dangerous sources 
•  Emergency  plan  for  diagnoses  and  medical  treatment  after  radiation 

accidents  

•  Austrian  catalogue  of  counter  measures  (as  example  of  an  optimized 

• 

protection strategy) 
Sampling  and  laboratory  measurement  plans  for  emergencies  with  large 
scale and small scale contamination 

BE 

Cutting up concept of the EPZ in predefined blocks and development of associated 
exchange  mechanisms  between  licensees,  experts,  decision  makers  and  local 
authorities 

BG 

Finland experience 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

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CZ 

DE 

DK 

FR 

HR 

IE 

German experience 

- 

Future federal nuclear and radiological emergency plans 

None specified 

Directive interministérielle du 7 avril 2005 sur l'action des pouvoirs publics en cas 
d'événement entraînant une situation d'urgence radiologique 

N/A 

National Emergency Plan for Nuclear Accidents 

A Framework for Major Emergency Management 

Strategic Emergency Planning Guidance 

LU 

- 

g) Article 99 International cooperation 

AT 

•  Bilateral  cooperation  of  Austria  with  its  neighbouring  countries  based  on 

bilateral arrangements including:  
(cid:1) 
(cid:1) 
(cid:1) 

regular bilateral experts meetings,  
DRAFT 
joint bilateral and reagional exercises,  
automatic  exchange  of  measurements  data  from  automatic  radiation 
monitoring stations and automatic aerosol monitoring stations,  

(cid:1)  exchange  of  relevant  data  to  decision  support  systems  (source  terms, 

meteorology,..) 

• 

See:  Review  of  Current  Off-site  Nuclear  Emergency  Preparedness    and  
Response  Arrangements    in  EU  Member  States  and    Neighbouring  States, 
ENER/D1/2012-474,  Final  report  and  appendices  (21.2  Bilateral  cooperation 
between  the  Czech  Republic  and  Austria  in  the  field  of  nuclear  and 
radiological EP&R (prepared by SÚJB and BMLFUW) 

BE 

BG 

CZ 

DE 

DK 

HERCA-WENRA approach 

Finland experience 
German experience 

- 

- Examples for bilateral agreements (e.g. Dutch-German agreement, etc.) 

The  Nordic  Manual  (NORMAN):  Co-operation  between  the  Nordic  Authorities  in 
Response  to  and  Preparedness  for  Nuclear  and  Radiological  Emergencies  and 
Incidents, 2006 (revised 2015) 

FR 

Bilateral and multilateral arrangements,  

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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HR 

IE 

LU 

HERCA recommandations 
N/A 

None 

(HERCA-WENRA approach) 

9.  Please  indicate  any  other  topic  areas  which  could  be  considered  for  development  of 
'guidelines' at the EU level: 

AT 

BE 

BG 

CZ 

DE 

•  Guideline  for  stakeholder  involvement  in  the  frame  of  the  emergency 

management system 

-  Harmonization of active dosimeters to be used by emergency workers 
-  Helpers 

Radioactive waste management in emergency 
Conducting Exercises 
Emergency Response Centre – requirements and equipment 

I think that the valuable output could be an overview how MS finally implemented 
the relevant requirements of Directive  

DRAFT 

-  Definition  of  minimum  standards  for  the  justification  and  the  performance 
(technical, organizational and communication) of early screening programs 
- Guidance on health monitoring programs for the potentially affected population 
(e.g. thyroid monitoring) 
-  Guidance  on  optimal  equipment  for  first  responders,  minimum  standards  for 
individual  protection,  ad  hoc  training,  dose  recording,  and  identification  of 
possible cooperation between Member States in this respect 
- Guidelines for linking operational intervention levels with generic reference level 
and generic dose criteria 
- Guidance on the assessment of the effectiveness of protective actions 
-  Guidance  on  the  development  of  optimized  protection  strategies  and  good 
practices for the optimization process during response 
-  Guidelines  for  integrating  new  monitoring  techniques  (unmanned  airborne 
monitoring, spectrometric gamma dose rate probes, etc.) into existing emergency 
monitoring capabilities and strategies 
-  Definition  of  good  practice  and  of  minimum  requirements  for  crisis 
communication 
-  Guidance  on  the  development  of  criteria  and  practical  provisions  for  the 
transition from an emergency exposure situation to an existing exposure situation 
- Guidance on how to consider non-radiological consequences of nuclear accidents 
and of protective actions in decision making 

DK 

FR 
HR 

None specified 

- 
N/A 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

IE 

LU 

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N/A 

a)  Guidance for sheltering: Sheltering is the most effective measure in a nuclear 
accident,  however  most  efforts  of  the  planning  and  the  public  perception 
concentrate on evacuation and ITB. While sheltering is “easy” for most people 
(you just stay at home) it is not the case for everybody. A few examples: 

a.  Infrastructures  that  need  to  continue  functioning  (hospitals ;  industries  that 

cannot stop rapidly ; maintaining electricity and telecommunications) 

b.  Infrastructures that need physical protection (e.g. SEVESO) 
c.  People  that  need  medical  care  (e.g  alone  living  elderly  persons  that  receive 

care at their home few times per day) 

b)  Contamination of non-foods. 

10. In the context of provisions of the BSS Directive, what other specific issues could be helped by 
further clarification or guidance to be developed at the EU level? 

AT 

• 

Further  guidance 
implementation  of  the  EU  Directive 
requirements  for  existing  exposure    situation  after  a  nuclear  or  radiological 
emergency  

for  practical 

•  Criteria  for  the  transition  of  an  emergency  exposure  situation  to  an  existing 

exposure situation 

- 
- 
No idea – if related to EPR 

DRAFT 

see also answer to question 9 

None specified 

Setting  reference  levels  taking  into  account  societal  criteria  and  involving 
stakeholders. 

N/A 

N/A 

- 

BE 
BG 
CZ 

DE 

DK 

FR 

HR 

IE 

LU 

11. What are the gaps in international level guidance where further work would help contribute 
to  transposition  and  effective  implementation  of  the  BSS  provisions  in  EP&R  and  in  which 
particular topics? 

AT 

BE 

BG 

Elaboration  of  generic  optimized  protection  strategies  for  different  radiological 
emergencies such as dangerous sources, radiological terror, transport accidents,…. 

draft DS474 of the IAEA. 

Radioactive waste management 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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CZ 

DE 

DK 

FR 
HR 

IE 

LU 

Conducting Exercises 
Emergency Response Centre – requirements and equipment 

In  my  opinion  there  is  enough  relevant  documents  and  recommendations  for 
successful  transposition  and  implementation  of  EU  BSS    and  there  are  not 
dramatically different requirements in comparison with previous legislation.  

see also answer to question 9 

None specified 

- 
Size of emergency zones 

N/A 

- 

DRAFT 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Annex 2:  Questionnaire on EP&R sent to HERCA and WENRA 

 Report VNS-TR-16-035 v1 

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The  ENCO-UJV  review  of  off-site  nuclear  EP&R  arrangements  (20148)  made  a  number  of 
recommendations  of  European  level  actions  to  make  improvements,  including  promotion  of 
harmonisation of criteria through the development of European guidance or Codes of Practice to 
address  issues  such  as  such  as  planning  zones,  criteria  for  protective  actions,  cross-border 
arrangements. 

Furthermore, the Council Conclusions on EP&R (20159) stresses the need for coherent protective 
measures along adjacent national borders for the effectiveness of emergency management, and 
recognizes  the  work  carried  by  HERCA  and  WENRA  to  improve  cross-border  approaches.  The 
Council invites the European Commission to organise workshops to facilitate the consistent and 
transposition and implementation of Council Directive 2013/59/Euratom (BSS Directive) including 
discussion of: 

Protection strategies and optimization approaches, including the use of reference levels, 

- 
-  Generic criteria, operational criteria, default triggers, 
-  Arrangements for the transition from emergency to existing exposure situations, 
- 

Emergency response arrangements and information to the public. 

One  concrete  output  of  such  workshops  could  be  the  development  of  'implementation 
guidelines'  to  help  support  Member  States  during  the  transposition  and  implementation  of  the 
BSS Directive. 

The  European  Commission  DG  ENER  has  selected  Vinçotte  Nuclear  Safety  (VNS)  of  Belgium  to 
help implement the above mentioned actions and activities. 

DRAFT 

Vinçotte  Nuclear  Safety  was  funded  in  2010  as  a  daughter  company  of  Association  Vinçotte 
Nuclear (AVN), the former TSO in Belgium, and SCK-CEN, the Belgian Nuclear Research Centre in 
Belgium. 

VNS is to conduct a survey within 10 EU Member States (and neighbouring countries) with a view 
to  determine  their  strategies  and  plans  for  transposition  and  implementation  of  the  EP&R 
provisions of Directive 2013/59/Euratom. 

VNS will consider the implementation plans in 5 nuclear and 5 non-nuclear countries. In particular 
the aim of this contract is to help develop an EU-level 'implementation guidelines' which would 
assist Member States to achieve better coherence and consistency in their emergency planning 
and  response  in  view  of  the  new  and  strengthened  requirements  of  the  new  Directive, 
particularly for cross-border issues. 

A  workshop  is  planned  later  in  2016  where  the  draft  guidelines  will  be  discussed  to  get  views 
from  all  MS's,  candidate  countries  and  EFTA  countries.  The  work  will  also  take  account  of  the 
recent Council Conclusions on this subject. 

A  lot  of  work  has  been  carried  out  by  expert  groups  such  as  HERCA,  TSO's  and  competent 
authorities. The project would benefit in having a comprehensive view of the status of the work 
performed within HERCA. A set of question that might help for that purpose is provided below. 

Review of Current Off-site Nuclear Emergency Preparedness and Response Arrangements in EU Member 

8  
States and Neighbouring Countries ENER/D1/2012-474, Final Report, Main Text, 
9  

Outcome of the 3439th Council meeting General Affairs Brussels, 15 December 2015, 15313/15 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                             
VINÇOTTE NUCLEAR SAFETY 

Your  cooperation  in  providing  answers  to  those  questions  would  be  highly  valuable  for  the 
outcome of a consensus based deliverable from this project 

 Report VNS-TR-16-035 v1 

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Questions on the implementation of the BSS EP&R provisions 

1)  What  activities  are  underway  or  what  work  has  HERCA  already  carried  out  to  support  the 

coherent implementation of the EP&R provisions of the BSS Directive? 

2)  How  could  the  work  carried  out  by  HERCA  usefully  contribute  to  the  development  of 
implementation guidelines that could be used as reference for the BSS Euratom provisions on 
EP&R?  Can  HERCA  suggest  topic  areas  and  the  way  to  define  those  guidelines  to  provide 
maximum benefit? 

3)  Are  there  common  views  or  consensus  within  HERCA  on  how  to  implement  the  more 

prescriptive provisions of the BSS on EP&R, i.e. the Annex XI, section B? 

Questions on the HERCA-WENRA Approach for a better cross-border coordination of protective 
actions during the early phase of a nuclear accident 

4) 

Is there an update/evolution regarding the transposition of the provisions of Art. 7 (reference 
levels) since the publication of the HERCA-WENRA document10? 

5) 

Is there an evolution towards the development of the guidelines for the implementation of 
the  HERCA-WENRA  approach  into  national  arrangements,  as  mentioned  in  the  HERCA  – 
WENRA document ? 

DRAFT 

6)  The HERCA-WENRA approach stresses the need for bilateral or multilateral arrangements. Of 
the  upmost  importance  is  the  management  of  interfaces  between  impacted  MS.  A  mutual 
understanding and a clear identification of the information to be provided should be part of 
emergency preparedness. In your opinion, do the MS intend to adopt the recommendations 
of  the  WGE  in  the  HERCA-WENRA  document  on  the  content  of  the  information  to  be 
provided by the accident country though its first message? 

7)  The  importance  of  promoting  compatible  response  arrangements  is  pointed  out  in  the 
HERCA-WENRA  document.  In  this  document,  it  is  written  that  the  WGE  should  develop 
guidelines for the establishment of bilateral / multilateral arrangements. What will serve as 
basis  for  those  guidelines  and  what  evolution  has  been  made  since  the  publication  of  the 
HERCA-WENRA  approach  ?  Is  the  aim  to  let  the  MS  ensuring  the  compatibility  of  their 
arrangements through bilateral or multilateral agreements or to have common guidance to 
ensure this compatibility within Europe? 

8)  The  work  performed  by  HERCA  focused  on  articles  99.1  and  99.2  of  the  BSS.  Has  the 
implementation  of  other  articles  of  the  BSS  Euratom  been  discussed  within  the  HERCA?  If 
yes, what have been the outcomes of the discussions or the recommendations issued? 

10 HERCA-WENRA Approach for a better cross-border coordination of protective actions during the early phase of a 
nuclear accident, Stockholm, 22 October 2014. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                             
VINÇOTTE NUCLEAR SAFETY 

Annex 3:  Compilation of the answers received by HERCA-WENRA to the 

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questionnaire 

Status of the work done within HERCA on EP&R 

A lot of work has been carried out by expert groups such as HERCA, TSO's and competent authorities. The 
project would benefit in having a comprehensive view of the status of the work performed within HERCA. 
A set of question that might help for that purpose is provided below. 

Since its creation, HERCA identified the need for a harmonised approach on Emergency Preparedness and 
Response  (EP&R)  in  Europe  as  a  top  priority.  The  events  at  the  Fukushima  Daiichi  NPP  in  March  2011 
dramatically  illustrated  that  similar  needs  for  a  common  understanding  and  approach  also  exist  for 
accidents  happening  at  great  distance  from  Europe.  The  work  of  HERCA  in  the  field  of  EP&R  started  in 
2008 whereas the current Working Group on Emergencies (WGE) was set up in 2011. 

The mandate of the WGE was to come up with practical and operational solutions leading to a uniform 
way of dealing with any serious radiological emergency situation, regardless of national border lines. Its 
aim  is  to  develop  a  comprehensive  approach  to  harmonisation,  not  only  limited  to  agreement  on 
individual parameters and concepts, such us reference levels. The final goal of the exercise is to obtain a 
uniform  cross  border  application  of  countermeasures,  thereby  supporting  public  credibility  in  the 
authorities’ recommendations and acceptance thereof. 

The heads of the national nuclear and radiation safety regulators in Europe (HERCA and WENRA European 
associations) have developed and agreed on a new approach to further improve the response and cross-
border coordination for all types of possible accident scenarios including severe accidents, like the one in 
DRAFT 
Fukushima. 

It  contains  overarching  principles  and  provides  an  incentive  for  joint  actions  between  neighboring 
countries. The regulators have committed to engage a cooperation at national level with the competent 
authorities in charge of civil protection for the implementation of the corresponding measures. 

The  HERCA  working  group  (WGE)  is  tasked  by  both  WENRA  and  HERCA  to  follow-up  the  HWA 
implementation in European countries. End April 2016, HERCA Board approved the tracking system set up 
for following the implementation of the HWA. HERCA members are expected to share within the WGE a 
first analysis by end of June 2016. In order to benefit from ENSREG work, this tracking will also integrate 
the ENSREG Quick survey. 

Questions on the implementation of the BSS EP&R provisions 

1)  What  activities  are  underway  or  what  work  has  HERCA  already  carried  out  to  support  the  coherent 
implementation of the EP&R provisions of the BSS Directive? 

Following the publication of the new BSS, Council Directive 2013/59/Euratom, which was published in the 
Official Journal of the European Union on 17th January 2014, HERCA established a Task Force in June 2014 
on the possible role of HERCA in the transposition of BSS. The composition of the Task Force included a 
member of the European Commission. 
In October 2014, during its 14th meeting, the Board of HERCA approved an Action Plan in relation to the 
transposition and implementation of the new Euratom BSS. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The approved Action Plan covers the following areas: 

• 

Identification  of  HERCA’s  role  in  the  transposition  of  the  new  EU  BSS  to  national  regulations 
defined; 

•  Definition of actions for HERCA in relation to the transposition of the BSS; 
•  Coordination  between  HERCA  and  the  European  Commission  in  relation  to  BSS  transposition 

activities considered. 

Regarding  the  EP&R  provisions  of  the  new  Euratom  BSS,  the  actions  identified  relate  to  the  following 
fields: 
• 
•  Emergency workers (Articles: 4 (31), 17 and 53). 
•  Reference levels for public exposures in an emergency situation. (article: 4 (84); 7). 

International Cooperation (Article 99). 

These  actions  have  been  included  in  the  works  of  the HERCA-WGE (working  group  on  emergency). The 
aim  was  to  have  a  common  understanding  of  the  Directive,  to  discuss  approaches  to  the  BSS 
implementation of the Directive and to define if a harmonization is needed on these topics. 

2) How could the work carried out by HERCA usefully contribute to the development of implementation 
guidelines that could be used as reference for the BSS Euratom provisions on EP&R? Can HERCA suggest 
topic areas and the way to define those guidelines to provide maximum benefit? 

HERCA  is  a  voluntary  association,  in  which  the  Heads  of  European  Radiological  Protection  Competent 
Authorities  work  together  in  order  to  identify  common  issues  and  propose  practical  solutions  for  these 
issues.  Though  HERCA  has  no  statutory  role  in  relation  to  the  transposition  of  the  Euratom  BSS  and 
uniform transposition or implementation in the Member States is not an objective of HERCA activities, the 
work  carried  out  by  HERCA  can  usefully  generate  reliable  guidelines  for  the  implementation  of  the  BSS 
DRAFT 
provisions on EP&R. 
To  this  regard,  several  topical  “Work  Package”  have  already  been  defined  within  the  activities  of  the 
HERCA-WGE whose results can be tailored into guidelines. These topical areas are: 
- the elaboration of a guidance document for bilateral agreements, 

- the elaboration of “Country fact-sheets” on national EP&R, 

- the assessment and prognosis in response to an emergency at a Nuclear Power Plant, 

- the development of a common understanding of the provisions related to emergency workers, 

- the contamination of non-food products, in relation to transport issues, 

-  the  follow-up  of  the  implementation  status  in  HERCA  countries  of  the  measures  for  distant  accidents 
proposed in the HERCA report “Practical proposals for further harmonization of the reactions in European 
countries to any distant nuclear or radiological emergency”, 

- the cross-border cooperation on protective actions, 

- the implementation of the HERCA-WENRA Approach at each national level. 

If  needed,  HERCA  may  release  common  understandings  of  the  Directive  and  if  it  is  judged  relevant  by 
HERCA members some guidelines or recommendation for harmonization may be provided. 

  
 
 
 
 
 
 
 
 
 
 
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3)  Are  there  common  views  or  consensus  within  HERCA  on  how  to  implement  the  more  prescriptive 
provisions of the BSS on EP&R, i.e. the Annex XI, section B? 

The Annex XI, section B of the BSS Euratom Directive presents provisions addressing the elements to be 
included in an emergency response plan. That is to say: 
-  During  the  preparedness  phase,  reference  level  for  public  exposure  and  for  emergency  occupational 
exposure, predefined generic criteria, optimized protection strategies for members of the public who may 
be  exposed,  arrangements  for  prompt  national  and  international  coordination,  arrangements  for  the 
emergency response plan to be reviewed and revised ; 

- During the response phase, promptly implementing protective measures, assessing the effectiveness of 
strategies and implemented actions and adjusting them as appropriate, comparing the doses against the 
applicable  reference  level,  focusing  on  those  groups  whose  doses  exceed  the  reference  level, 
implementing further protection strategies, as necessary. 

To  date,  there  is  a  consensus  on  the  principles  which  to  rely  on  (effectiveness  of  the  reference  levels, 
prompt  coordination,  further  protection  strategies),  but  not  on  the  way  to  implement  them  at  each 
national level. The difficulty to implement them lies in the diversity of the different political organization 
as well as each emergency management system. 

Questions on the HERCA-WENRA Approach for a better cross-border coordination of protective actions 
during the early phase of a nuclear accident 

4) Is there an update/evolution regarding the transposition of the provisions of Art. 7 (reference levels) 
DRAFT 
since the publication of the HERCA-WENRA Approach for a better cross-border coordination of protective 
actions during the early phase of a nuclear accident, Stockholm, 22 October 2014 ? 

It is clear, according to the  work carried out by HERCA, that a generic approach to RLs is unlikely to be 
achievable. The Directive leaves room for national interpretation to be used by Member States. A more 
pragmatic  approach  on  RL  is  recommended  by  HERCA  members  such  as  cross  border  cooperation  to 
achieve  compatible  RLs  for  neighboring  countries  and  to  harmonize  protection  strategies.  The  Board 
asked the WGE to develop a paper on how to address the issue of RLs. 

5) Is there an evolution towards the development of the guidelines for the implementation of the HERCA-
WENRA approach into national arrangements, as mentioned in the HERCA – WENRA document? 

Yes, the HERCA Board has approved on 10 November 2015 2 new documents: 
-  “Guidance  for  bilateral  arrangements”.  This  new  guidance  shall  support  the  implementation  of  the 
“HERCA-Approach for a better cross-border coordination of protective actions during the response in the 
early phase of a nuclear accident. Bilateral arrangements are understood as an integrated set of agreed 
elements  between  the  parties  adhering  to  the  bilateral  arrangements.  These  elements  may  include  an 
agreement, procedures, protocols and other documents. 

- “Common understanding of the provisions related to emergency workers.” The document shows a rich 
variation in interpretations, although there is general agreement for the most important roles. Wherever 
differences  are  found,  the  bilateral  impact  is  deemed  to  be  marginal  at  worst.  Therefore,  no  need  for 
harmonisation with respect to the concept of Emergency Workers is seen. 

Both documents are publicly available on the HERCA.org website. 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Above that the working group has made good progress on the fact sheets and should be able to finalise 
the first version for nearly all countries within 2016. Those fact sheet, to be used by authorities in charge 
of  emergencies,  summarise  for  most  cases  on  2  pages  the  most  relevant  issues  related  to  EP&R  of  the 
individual country. 

6)  The  HERCA-WENRA  approach  stresses  the  need  for  bilateral  or  multilateral  arrangements.  Of  the 
upmost importance is the management of interfaces between impacted MS. A mutual understanding and 
a  clear  identification  of  the  information  to  be  provided  should  be  part  of  emergency  preparedness.  In 
your  opinion,  do  the  MS  intend  to  adopt  the  recommendations  of  the  WGE  in  the  HERCA-WENRA 
document  on  the  content  of  the  information  to  be  provided  by  the  accident  country  though  its  first 
message? 

Yes, this is included in the document “Guidance for bilateral arrangements” mentioned under question n° 
5. 

7) The importance of promoting compatible response arrangements is pointed out in the HERCA-WENRA 
document. In this document, it is written that the WGE should develop guidelines for the establishment of 
bilateral / multilateral arrangements. What will serve as basis for those guidelines and what evolution has 
been made since the publication of the HERCA-WENRA approach? Is the aim to let the MS ensuring the 
compatibility  of  their  arrangements  through  bilateral  or  multilateral  agreements  or  to  have  common 
guidance to ensure this compatibility within Europe? 

The document “Guidance for bilateral arrangements” already mentioned in 5 and 6 has been approved by 
the  HERCA  Board  of  Heads.  It  is  up  to  the  Member  States  to  analyse  the  situation  and  to  take  the 
necessary  actions.  HERCA’s  WGE  will  perform  a  tracking  of  the  implementation  of  the  HERCA-WENRA 
DRAFT 
Approach. HERCA members should perform a first analysis up to end of June 2016. This tracking will also 
integrate  the  ENSREG  Quick  survey  that  is  presented  at  the  ENSREG  June  meeting.  There  will  be  no 
duplication  of  work.  The  implementation  in  the  different  countries  will  be  intensively  discussed  twice  a 
year in the meetings of WGE. 
HERCA-WGE is initiating a Work Package WP for dealing with Cross Border aspects of protective actions, 
the main tasks being to address: 
- Consistent protective actions, 

- Decision process (OIL, EAL, triggers, expertise, others…) for the recommendation of protective actions, 

- Implementation of the EU-BSS in relation with IAEA activities, 

- Compatible monitoring strategies, 

- General principle for the extension of planning zones in response. 

8) The work performed by HERCA focused on articles 99.1 and 99.2 of the BSS. Has the implementation of 
other articles of the BSS Euratom been discussed within the HERCA? If yes, what have been the outcomes 
of the discussions or the recommendations issued? 

  
 
 
 
 
 
 
 
 
 
 
 
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HERCA  has  set  up  a  Task  Force  for  the  transposition  and  the  implementation  of  Euratom  BSS.  Twelve 
Actions  were  identified  and  presented  in  the  document  “HERCA  Action  Plan  in  relation  to  the 
transposition and implementation of Directive 2013/59/Euratom (Euratom BSS)”. Three Actions concern 
Emergency preparedness and response, five Medical exposures, one Non-medical imaging exposures, one 
Radon, one RPE/RPO and one General exchange of information. 
Related documents: 

-  Practical  proposals  for  further  harmonisation  of  the  reactions  in  European  countries  to  any  distant 
nuclear or radiological emergency, June 2013 

-  HERCA-WENRA  Approach for  a  better  cross-border  coordination  of  protective  actions  during  the  early 
phase of a nuclear accident, October 2014 

- Guidance for Bilateral Arrangements, November 2015 

-  Summary  of  discussions  on  the  development  of  a  possible  common  understanding  of  the  concept  of 
Reference Levels for Emergency Planning and Response, August 2015, (H16- 9.c.4, for internal use only) 

- Report on the Workshop 13th and 14th April 2015 in Berlin, (H16-9.c.6, for internal use only) 

- Contaminated Non-Food Products, November 2015 

- Common understanding of Emergency Workers, November 2015 

-  HERCA  Action  Plan  in  relation  to  the  transposition  and  implementation  of  Directive  2013/59/Euratom 
(Euratom BSS), October 2014 

- HERCA-Approach for a better cross-border coordination of protective actions during the response in the 
early phase of a nuclear accident; development and practical testing, June 2014 

DRAFT 

  
 
 
 
 
 
 
 
VINÇOTTE NUCLEAR SAFETY 

Annex 4:  Provisions of the BSS Directive on EP&R 

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Reference levels - Article 7 
1.  Member  States  shall  ensure  that  reference  levels  are  established  for  emergency  and  existing  exposure 
situations. Optimisation of protection shall give priority to exposures above the reference level and shall continue 
to be implemented below the reference level. 
2.  The  values  chosen  for  reference  levels  shall  depend  upon  the  type  of  exposure  situation.  The  choices  of 
reference levels shall take into account both radiological protection requirements and societal criteria. For public 
exposure  the  establishment  of  reference  levels  shall  take  into  account  the  range  of  reference  levels  set  out  in 
Annex I. 
3. For existing exposure situations involving exposure to radon, the reference levels shall be set in terms of radon 
activity concentration in air as specified in Article 74 for members of the public and Article 54 for workers. 

Paragraphs  1  and  2  are  relevant  to  emergency  and  existing  exposure  situations.  In  line  with  the  ICRP 
recommendations, Publication 103, new concepts have been introduced in the BSS Directive relating to emergency 
management and rehabilitation. Previous guidance for the protection of the public in the event of a nuclear accident 
categorised  accidents  in  three  sequential  phases;  pre-release,  release,  and  post-release.  The  old  concepts  of 
practices  and  interventions  have  been  replaced  by  three  generic  exposure  situations,  which  cover  all  conceivable 
exposure situations: 
- planned exposure situations , 
- emergency exposure situations, 
- existing exposure situations. 
One  of  the  most  important  changes  in  the  new  recommendations  is  the  distinction  between  'dose  limits'  and 
'reference  levels'.  Dose  limits  only  apply  to  planned  exposure  situations,  whilst  emergency  and  existing  exposure 
situations call for reference levels. In the BSS Directive, the reference levels for public exposure are 1-20mSv/year for 
existing exposure situations and 20-100mSv as an acute or annual dose. For specific situations, reference level below 
these ranges may be considered. A flexible framework is provided for reference levels in the range 1 to 100mSv/year 
DRAFT 
in the phase of an existing exposure situations. 
Optimisation of protection demands that priority should be given to reducing exposures above the reference levels, 
and continue to apply below the reference levels. It is mentioned that the choice of reference levels shall take into 
account  both  radiological  protection  requirements  and  societal  criteria  as  well  as  features  of  the  prevailing 
situations.  
The concept of 'reference level' allows the BSS Directive to give an indication of acceptable range of exposures in an 
emergency exposure situation, and of annual exposures in an existing exposure situation. A certain level of flexibility 
is  allowed  in  the  establishment  of  reference  levels  which  would  be  a  national  responsibility,  but  there  is  firm 
indication  that  these  should  be  in  the  range  20-100mSv.  The  acceptability  is  framed  by  the  term  societal  criteria, 
which is not fully specified.  
Living in contaminated areas following the release of radioactive substances is regarded as an existing exposure, and 
the reference levels in Annex 1 would apply. The management of such areas would rely on the involvement of the 
stakeholders involved. 

Prior information and training for emergency workers - Article 17 
1.  Member  States  shall  ensure  that  emergency  workers  who  are  identified  in  an  emergency  response  plan  or 
management system are given adequate and regularly updated information on the health risks their intervention 
might involve and  on the precautionary measures to  be  taken in such an event. This information shall  take  into 
account the range of potential emergencies and the type of intervention.  
2.  As  soon  as  an  emergency  occurs,  the  information  referred  to  in  paragraph  1  shall  be  supplemented 
appropriately, having regard to the specific circumstances.  
3.  Member  States  shall  ensure  that  the  undertaking  or  the  organisation  responsible  for  the  protection  of 
emergency workers provides to emergency workers referred to in paragraph 1 appropriate training as provided for 
in the emergency management system set out in Article 97. Where appropriate, this training shall include practical 
exercises.  
4. Members  States shall ensure that,  in  addition  to  the emergency response training referred to in  paragraph 3, 
the undertaking or the organisation responsible for the protection of emergency workers provides these workers 
with appropriate radiation protection training and information. 

  
 
 
 
 
 
 
 
 
 
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This article emphasizes the role and information and training needs of emergency workers, i.e. those persons having 
a  defined  role  in  an  emergency  and  who  might  be  exposed  to  radiation  while  taking  action  in  response  to  the 
emergency. This category of worker is distinguished by the applicability of higher reference levels of dose than would 
apply to other occupationally exposed workers. The actual type of worker in this category is required to be identified 
beforehand, and should thus have a defined role and responsibilities. Typically, on a nuclear site, these may include 
firefighters,  rescue  personnel,  paramedics,  as  well  as  those  with  specialised  knowledge  of  the  plant,  or  personnel 
with specialised skills in incident and accident response. The scope can be quite wide, as it can cover also ancillary 
workers,  e.g.  crane  drivers,  bus  drivers  involved  in  supporting  remedial  efforts  or  evacuation  of  the  public.  The 
nature of the information on health risks and precautionary measures needed is associated with the intervention to 
be provided by the relevant emergency worker; and is linked to the emergency plan or management system, and to 
the range of potential emergencies and types of intervention that are identified beforehand.  
Recognising  the  limits  of  prior  information  provision  based  on  pre-planned  scenarios,  and  the  dynamic  nature  of 
actual emergencies, in case of an emergency there is a requirement to provide supplementary information based on 
the actual known characteristics of the emergency. 
In addition to provision of information, this article requires specific and appropriate training in emergency response 
to be provided to emergency workers in accordance with the emergency management system (Article 97). The value 
of  practical  exercises  is  recognised  as  part  of  the  training.  The  information  and  training  shall  also  cover  radiation 
protection  subjects,  particularly  in  view  of  anticipated  higher  reference  levels  that  would  apply  in  case  of  an 
emergency. 

Emergency occupational exposure – Article 53 
1. Member States shall ensure that emergency occupational exposures shall remain, whenever possible, below the 
values of the dose limits laid down in Article 9. 
2. For situations where the above condition is not feasible, the following conditions shall apply: 
a)  reference  levels  for  emergency  occupational  exposure  shall  be  set,  in  general  below  an  effective  dose  of  100 
mSv; 
b) in exceptional situations, in order to save life, prevent severe radiation-induced health effects, or prevent the 
development  of  catastrophic  conditions,  a  reference  level  for  an  effective  dose  from  external  radiation  of 
emergency workers may be set above 100 mSv, but not exceeding 500 mSv. 
DRAFT 
3. Member States shall ensure that emergency workers who are liable to undertake actions whereby an effective 
dose of 100 mSv may be exceeded are clearly and comprehensively informed in advance of the associated health 
risks and the available protection measures and undertake these actions voluntarily. 
4.  In  the  event  of  an  emergency  occupational  exposure,  Member  States  shall  require  radiological  monitoring  of 
emergency  workers.  Individual  monitoring  or  assessment  of  the  individual  doses  shall  be  carried  out  as 
appropriate to the circumstances. 
5. In the event of an emergency occupational exposure, Member States shall require special medical surveillance 
of emergency workers, as defined in Article 49, to be carried out as appropriate to the circumstances. 

This  article  also  emphasizes  the  role  of  emergency  workers,  and  recognises  that  due  to  the  nature  of  their 
responsibilities,  they  may  be  exposed  to  higher  levels  of  radiation.  Member  States  are  required  to  ensure  that 
exposures remain, to the extent possible, below the occupational dose limits. Reference level of dose for emergency 
occupational exposure may be set higher than for normal occupational dose limits, but should in general be below 
100mSv. However, in exceptional circumstance recognising the special role of emergency workers to save lives, and 
prevent emergency situations from deteriorating further, the article allows Member States may set a reference level 
for external exposure above 100 mSv but in any case not exceeding 500 mSv. Given the higher risks of health effects 
in this case, there is a requirement to ensure that where doses above 100mSv may be exceeded, that information on 
the health risks and applicable protection measures to reduce exposure are comprehensively provided, in advance, 
and that emergency workers undertake the tasks in an informed way and voluntarily. It is also made clear that the 
dose  quantity  subject  to  control  is  the  effective  dose  from  external  radiation,  and  not  doses  arising  from  internal 
intake of radioactive substances. 
In case of an emergency occupational exposure, radiological exposure monitoring is required, this being by individual 
measurement or other assessment, as well as appropriate medical surveillance of the exposed workers – in view of 
the higher than normal exposures and consequent health risks. 

Emergency response – Article 69 
1. Member States shall require the undertaking to notify the competent authority immediately of any emergency 
in  relation  to  the  practices  for  which  it  is  responsible  and  to  take  all  appropriate  action  to  reduce  the 
consequences. 

  
 
 
 
 
 
 
 
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2. Member  States shall ensure that, in the event of an emergency  on  their  territory, the undertaking concerned 
makes an initial provisional assessment of the circumstances and consequences of the emergency and assists with 
protective measures. 
3. Member States shall ensure that provision is made for protective measures with regard to: 
(a) the radiation source, to reduce or stop the radiation, including the release of radionuclides; 
(b) the environment, to reduce the exposure to individuals resulting from radioactive substances through relevant 
pathways; 
(c) individuals, to reduce their exposure. 
4. In the event of an emergency on or outside its territory, the Member State shall require: 
(a)  the  organisation  of  appropriate  protective  measures,  taking  account  of  the  real  characteristics  of  the 
emergency  and  in  accordance  with  the  optimised  protection  strategy  as  part  of  the  emergency  response  plan, 
whereby the elements to be included in an emergency response plan are indicated in Section B of Annex XI; 
(b) the assessment and recording of the consequences of the emergency and of the effectiveness of the protective 
measures. 
5.  The  Member  State  shall,  if  the  situation  so  requires,  ensure  that  provision  is  made  to  organise  the  medical 
treatment of those affected. 

This  article  gives  direction  to  the  principal  actions  required  for  emergency  response  in  the  event  of  an  emergency 
exposure situation. It indicates the need for the undertaking to notify the competent authority immediately and to 
take the necessary action to reduce the consequences of the emergency. 
The undertaking concerned is required to make an initial assessment of the known circumstances of the emergency 
and the possible consequences. It specifically requires the undertaking to provide (and if needed apply) protective 
measures. For this purpose, the article spells out the priority to be applied: 
Firstly, protective measures need to be available to address the source of the radiation (or radioactive substances), to 
reduce  or  stop  the  presence  of  the  radiation  source  (for  example,  through  its  extinction  (electrical  source), 
containment or shielding or other engineering means), including the release of radioactive substances.  
Secondly,  protective  measures  need  to  be  available  to  reduce  or  prevent  releases  to  the  environment,  which  may 
subsequently  give  rise  to  exposure  of  persons,  for  example  due  to  the  presence  of  contaminated  surfaces,  or  by 
intake of food and water that is contaminated. 
DRAFT 
Thirdly, protective measures should be available applying to individuals, so as to restrict their exposure to radiation 
and radioactive substances. 
In the event of an emergency, whether the origin is within the territory of the Member State or outside, the Member 
State  is  required  to  implement  appropriate  protective  measures  taking  account  of  the  actual  characteristics  of  the 
emergency and in accordance with the 'optimised protection strategy', which is part of the emergency response plan. 
No further description is provided of what constitutes a 'optimised protection strategy'. However, the reference to 
the  emergency  response  plan  implies  a  certain  degree  of  preparedness,  and  the  timely  implementation  of  these 
preparedness measures for the protection of the public.  
The  inclusion  of  emergencies  that  occur  outside  the  territory  of  the  Member  State  effectively  require  some 
preparation by all Member States to possible emergencies in neighbouring EU Member States or third countries. The 
elements to be included in such an emergency response plan are defined in Annex XI, B. 
In addition, the provision requires an assessment of the consequences of the emergency and the effectiveness of the 
protective  measures,  as  well  as  their  recording.  This  could  be  imply  both  the  prior  assessment  of  the  likely 
consequences and effectiveness of protective measures related to an emergency scenario, as well as the subsequent 
assessment of consequences and efficiency of the protective measures.  
Finally,  there  is  a  need  to  provide  for  the  organisation  medical  treatment  of  persons  affected  by  the  exposure  to 
radiation and radioactive substances in the course of an emergency. As the treatment of patients who have received 
large  doses  of  radiation  is  a  specialised  task,  and  therefore  the  'organisation  of  medical  treatment'  can  be  done 
through indigenous means or by access to specialised services elsewhere.  
Information to the members of the public likely to be affected in the event of an emergency - Article 70 
1. Member States shall ensure that the members of the public likely to be affected in the event of an emergency 
are given information about the health protection measures applicable to them and about the action they should 
take in the event of such an emergency.  
2. The information supplied shall include at least the elements set out in Section A of Annex XII.  
3. The information shall be communicated  to  the members of the  public referred  to  in paragraph 1 without any 
request being made.  
4. Member States shall ensure that the information is updated and distributed at regular intervals and whenever 
significant changes take place. This information shall be permanently available to the public. 

  
 
 
 
 
 
 
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This  article  specifies  that  members  of  the  public  likely  to  be  affected  by  an  emergency  are  given  information 
beforehand  about  health  protection  measures  applicable  to  them  and  the  action  they  should  take.  Section  A  of 
Annex XII lists the minimum type of information to be provided.  
Such information must be provided without it being solicited. It should also be regularly updated and distributed, and 
after significant changes.  

Information to the members of the public actually affected in the event of an emergency - Article 71 
1. Member States shall ensure that, when an emergency occurs, the members of the public actually affected are 
informed without delay about the facts of the emergency,  the steps to be taken and, as appropriate, the health 
protection measures applicable to these members of the public.  
2. The information provided shall cover those points listed in Section B of Annex XII which are relevant to the type 
of emergency. 

In a similar way,  this article requires that when an emergency occurs, the members of  the  public actually affected 
(which need not be the same group as the public who have received prior information) are informed forthwith of the 
emergency  and  of  the  protective  actions  required.  Section  B  of  Annex  XII  lists  the  information  to  be  provided, 
including  the  type  of  emergency,  its  prognosis,  and  advice  on  protection.  It  should  be  noted  that  Article  99 
(international cooperation) also includes a requirement for coordination of public information provision with other 
Member  States  and  third  countries  in  the  event  of  an  emergency  occurring  on  its  territory  or  likely  to  have 
radiological consequences on its territory. 

Contaminated areas - Article 73 
1. Member States shall ensure that optimised protection strategies for managing contaminated areas shall include, 
where applicable, the following:  
(a) objectives, including long-term goals pursued by the strategy and corresponding reference levels, in accordance 
with Article 7;  
(b) delineation of the affected areas and identification of the affected members of the public;  
(c)  consideration  of  the  need  for  and  extent  of  protective  measures  to  be  applied  to  the  affected  areas  and 
members of the public;  
DRAFT 
(d) consideration of the need to prevent or control access to the affected areas, or to impose restrictions on living 
conditions in these areas;  
(e)  assessment  of  the  exposure  of  different  groups  in  the  population  and  assessment  of  the  means  available  to 
individuals for controlling their own exposure.  
2. For areas with long-lasting residual contamination in which the Member State has decided to allow habitation 
and  the  resumption  of  social  and  economic  activities,  Member  States  shall  ensure,  in  consultation  with 
stakeholders,  that  arrangements  are  in  place,  as  necessary,  for  the  ongoing  control  of  exposure  with  the  aim  of 
establishing living conditions that can be considered as normal, including:  
(a) establishment of appropriate reference levels;  
(b)  establishment  of  an  infrastructure  to  support  continuing  self-help  protective  measures  in  the  affected  areas, 
such as information provision, advice and monitoring; 
(c) if appropriate, remediation measures;  
(d) if appropriate, delineated areas. 

This article concerns the protection strategy to be applied to contaminated areas including those that result from the 
aftermath  of  a  radiological  release.  It  chiefly  requires  a  optimised  protection  strategy  that  includes  a  number  of 
elements,  including  the  long-term  objectives,  the  demarcation  of  it  and  the  affected  members  of  the  public,  the 
nature  of  protective  measures  to  be  applied,  the  access  control  and  restrictions  on  habitation.  In  the  case  of 
decisions  to  allow  the  resumption  of  social  and  economic  activities,  a  consultation  of  stakeholders  involved  is 
required.  This  includes  the  decision  on  appropriate  reference  levels,  infrastructure  to  support  self-help  protective 
measures, remediation measures. 

Emergency management system - Article 97 
1. Member States shall ensure that account is taken of the fact that emergencies may occur on their territory and 
that  they  may  be  affected  by  emergencies  occurring  outside  their  territory.  Member  States  shall  establish  an 
emergency  management  system  and  adequate  administrative  provisions  to  maintain  such  a  system.  The 
emergency management system shall include the elements listed in Section A of Annex XI.  
2. The emergency management system shall be designed to be commensurate with the results of an assessment of 

  
 
 
 
 
 
 
 
 
 
 
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potential emergency exposure situations and to be able to respond effectively to emergency exposure situations 
in connection with practices or unforeseen events.  
3. The emergency management system shall provide for the establishment of emergency response plans with the 
objective  of  avoiding  tissue  reactions  leading  to  severe  deterministic  effects  in  any  individual  from  the  affected 
population  and  reducing  the  risk  of  stochastic  effects,  taking  account  of  the  general  principles  of  radiation 
protection and the reference levels referred to in Chapter III.  

Article 97 contains the essential basis of an emergency management system. It should be noted in this context that 
an emergency is defined as "a non-routine situation or event involving a radiation source that necessitates prompt 
action  to  mitigate  serious  adverse  consequences  for  human  health  and  safety,  quality  of  life,  property  or  the 
environment,  or  a  hazard  that  could  give  rise  to  such  serious  adverse  consequences".  Therefore  the  nature  of  the 
emergency could be of radiological or nuclear origin, for example whether it involves a high-activity radiation source 
used for medical purposes, a transport accident involving radioactive sources, or an accident at a nuclear installation.  
There  is  a  clear  requirement  to  prepare  for  emergencies  both  within  the  territory  of  a  Member  State  and  from 
outside which may affect the Member State. For this purpose the emergency management system (comprising the 
emergency  plans  and  the  administrative  provisions  to  support  them)  is  to  be  based  commensurate  with  an 
assessment of potential emergency exposure situations at the national level. The elements to be included is such an 
emergency management system are listed in Annex XI, and include the assessment of potential emergency exposure 
situations and the associated  public and emergency  worker exposures; the allocation of responsibilities of persons 
and organisations having a role in the preparedness and response; preparation of appropriate emergency response 
plans  related  to  a  specific  facility  or  activity;  provision  of  reliable  communications  and  effective  and  efficient 
arrangement for cooperation and coordination at the site of the emergency and at national and international levels; 
health protection measures of emergency workers; arrangements for information, training and exercises of involved 
persons; arrangements for exposure monitoring and dose recording; public information arrangements; transition for 
an emergency exposure situation to an existing exposure situation including the recovery and remediation phases; 
and finally the involvement of stakeholders. 
The  latter  provision  is  new  and  is  line  with  ICRP  recommendations  that  especially  in  the  case  of  recovery  from 
accidents,  for  areas  with  long-lasting  residual  contamination  in  which  the  Member  State  has  decided  to  allow 
DRAFT 
habitation  and  the  resumption  of  social  and  economic  activities,  Member  States  shall  ensure,  in  consultation  with 
stakeholders arrange for the ongoing control of exposure with the aim of establishing living conditions that can be 
considered as normal, including establishment of infrastructure to support continuing self-help protective measures 
in the affected areas, such as information provision, advice and monitoring. The meaning of stakeholders is therefore 
quite wide, as it may involve economic interests (business, industry, agricultural, fisheries, trade associations), civil 
society (public interest groups, NGO's, unions), expert groups, technical support organisations etc. However, whilst 
the  consultation  with  stakeholders  is  required  in  decisions  on  the  return  to  normality  -  their  involvement  in  the 
development of other parts of the emergency management system is not excluded.  

Emergency preparedness - Article 98 
1. Member States shall ensure that emergency response plans are established in advance for the various types of 
emergencies identified by an assessment of potential emergency exposure situations.  
2. The emergency response plans shall include the elements defined in Section B of Annex XI.  
3.  The  emergency  response  plans  shall  also  include  provision  for  the  transition  from  an  emergency  exposure 
situation to an existing exposure situation.  
4. Member States shall ensure that emergency response plans are tested, reviewed and, as appropriate, revised at 
regular  intervals,  taking  into  account  lessons  learned  from  past  emergency  exposure  situations  and  taking  into 
account the results of the participation in emergency exercises at national and international level.  
5.  The  emergency  response  plans  shall,  where  appropriate,  incorporate  relevant  elements  of  the  emergency 
management system referred to in Article 97. 

An  important  part  of  the  emergency  management  system  is  the  emergency  response  plan.  The  elements  to  be 
included  in  these  is  specified  in  Section  B  of  Annex  XI.  An  assessment  of  potential  emergency  exposure  situations 
shall  identify  when  the  drawing  up  of  emergency  response  plans  is  required.  The  types  of  credible  scenarios  for 
which detailed planning and preparedness should be derived from a comprehensive risk assessment that considers 
all possible nuclear and radiological emergencies arising from the failure of engineering and administrative controls 
designed for accident prevention, and considers their likelihood as well magnitude of impacts. The outcome of such 
assessment should provide some indication of the level of detail to which each scenario should be planned. As well as 

  
 
 
 
 
 
 
 
 
 
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covering the arrangements relating to the emergency itself, the plan shall also address the transition to an existing 
exposure  situation.  This  requirement  is  particularly  important  in  view  of  a  finding  from  the  European  Commission 
sponsored  study11  in  2013  which  found  that  amongst  EU  Member  States  "there  is  a  general  lack  of  strategies  and 
arrangements for longer term protective measures and for the return to normality following an emergency". 
A  key  requirement  is  that  emergency  response  plans  are  tested,  reviewed  and  revised  regularly,  with  a  view  to 
ensuring  they  remain  upto  to  date,  and  take  account  of  lessons  learnt  from  previous  emergencies  and  from 
exercises.  Emergency  response  plans  must  be  both  specific  and  sufficiently  detailed.  Plans  may  be  developed  at 
different  levels  of  local,  regional  and  national  responsibility,  and  may  cover  the  risks  associated  with  a  particular 
installation, or to a specific activity. 
In all cases, for emergency preparedness, the plans shall include details of the reference levels for public exposure 
and  emergency  occupational  exposure;  the  'optimised  protection  strategy'  that  would  be  applied;  the  re-defined 
criteria that will be used for the introduction of particular protective measures (in case of nuclear accident; this may 
include  iodine  prophylaxis,  sheltering,  or  evacuation  of  the  population,  food  and  water  intake  controls);  and 
operational  criteria  that  could  be  used  for  decision-making.  Furthermore,  the  arrangements  that  apply  to 
coordination  between  the  different  organisations  that  have  responsibilities  in  preparation  and  response,  and  with 
other Member States and third countries shall be specified. 
For emergency response, the Section B Annex XI goes on to describe the implementation strategy to be applied, i.e. 
the  timely  implementation  of  the  preparedness  arrangements  by,  for  example,  implementing  protective  measures 
before any exposure occurs, assessing the effectiveness of implemented actions and adjusting them to the prevailing 
situation,  optimising  protection  measures  to  those  whose  doses  exceed  the  reference  level,  and  applying  further 
protection measures based on the actual situation. 

International cooperation - Article 99 
1.  Member  States  shall  cooperate  with  other  Member  States  and  with  third  countries  in  addressing  possible 
emergencies  on  its  territory  which  may  affect  other  Member  States  or  third  countries,  in  order  to  facilitate  the 
organisation of radiological protection in those Member States or third countries.  
2. Each Member State shall, in the event of an emergency occurring on its territory or likely to have radiological 
consequences on  its territory, promptly establish contact with all  other Member  States and with  third countries 
which may be involved or are likely to be affected with a view to sharing the assessment of the exposure situation 
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and  coordinating  protective  measures  and  public  information  by  using,  as  appropriate,  bilateral  or  international 
information  exchange  and  coordination  systems.  These  coordination  activities  shall  not  prevent  or  delay  any 
necessary actions to be taken on a national level.  
3.  Each  Member  State  shall  promptly  share  information  and  cooperate  with  other  relevant  Member  States, 
relevant  third  countries  and  relevant  international  organisations  regarding  the  loss,  theft  or  discovery  of  high-
activity sealed sources, other radioactive sources and radioactive material of concern and regarding related follow-
up or investigations, without prejudice to relevant confidentiality requirements and relevant national legislation.  

The  BSS  Directive  calls  for  enhanced  cooperation  between  Member  States  especially  in  emergency  planning  and 
response  for  the  efficient  management  of  an  emergency  with  cross-border  consequences.  Specifically  on  dealing 
with emergency exposure situations and in the scope of an emergency management system, the Annex XI requires 
efficient and effective arrangements for cooperation and coordination at the installation and at appropriate national 
and international levels. This implies a high level of cooperation between MS's and with third countries. 
The EU has a developed legal framework and mechanisms for information exchange in case of nuclear or radiological 
accidents. Council Decision 87/600/Euratom requires Member States to inform the Commission if they plan to take 
widespread  measures  to  protect  their  population  from  the  effects  of  radiation  following  a  nuclear  emergency  on 
their territory (ECURIE Mechanism). It requires that the Commission forwards this information to all other Member 
States. The current system also includes some non-EU countries. In parallel, the European Commission operates the 
EURDEP environmental monitoring data system which receives data from monitoring stations in EU and neighbouring 
countries. The Commission can also activate food and feedstuffs for the protection of citizens at the EU level. 
Whilst urgent information exchange between Member States and the Commission in the event of an emergency is 
established  through  Council  Decision  87/600/Euratom,  BSS  Directive  requires  arrangements  for  information 
exchange  beyond  the  scope  of  this  Decision  to  allow  cooperation  with  all  other  Member  States  and  with  third 
countries which may be involved or are likely to be affected. 

11  Review  of  Current  Off-site  Nuclear  Emergency  Preparedness  and  Response  Arrangements  in  EU  Member  States  and 
Neighbouring Countries, ENER/D1/2012-474, 2014 

  
 
 
 
 
 
 
 
                                                             
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Under this article, Member States are required to cooperate with other Member States and with third countries in 
addressing possible emergencies on its territory which may affect other Member States or third countries, in order to 
facilitate the organisation of radiological protection in those Member States or third countries. 
Going further than Council Decision 87/600/Euratom, the provision requires each Member State, in the event of an 
emergency occurring on its territory or likely to have radiological consequences on its territory, to promptly establish 
contact with all other Member States and with third countries which may be involved or are likely to be affected with 
a  view  to  sharing  the  assessment  of  the  exposure  situation  and  coordinating  protective  measures  and  public 
information by using, as appropriate, bilateral or international information exchange and coordination systems.  
In  addition,  each  Member  State  shall,  where  appropriate,  cooperate  with  other  Member  States  and  with  third 
countries in the transition from an emergency exposure situation to an existing exposure situation. 
Many  EU  Member  States  and  some  EU  neighbouring  countries  have  bilateral  or  multilateral  agreements  in  place 
covering  cross  border  arrangements  in  case  of  a  nuclear  or  radiological  accident.  However,  the  study  mentioned 
earlier (footnote 3) observed that there are major differences in how they are implemented, both in the nature of 
arrangements in practice and in the extent to which they are governed by any binding legal basis or more substantive 
political accord. This lack of coherence could be addressed through the consistent implementation of this provision. 
However, as the study recommended, it may require the Commission to make recommendations to provide guidance 
on what constitutes good/best practice in Europe on cross border arrangements. 
Whilst  the  BSS  Directive  provides  a  comprehensive  framework  for  the  adequate  response  to  a  radiological 
emergency in individual Member States, and recognising the primary national responsibilities in this field, it is also 
clear that given the trans-frontier nature of significant accidents, a EU level approach to the implementation of these 
provisions  would  bring  improved  consistency,  and  coherence.  Whilst  the  BBS  Directive  has  retained  flexibility  in 
some  of  its  provisions,  there  is  scope  for  more  uniform  interpretation  of  certain  features,  for  example,  greater 
harmonisation of criteria, and guidelines on cross border agreements. However, the specificities of radiological and 
nuclear emergencies should be borne in mind, to maintain flexibility in the decision-making criteria or strategies for 
response  to  the  emergency  and  its  recovery,  so  as  to  be  able  to  respond  to  the  actual  circumstances  of  the 
emergency. 

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