EPR Workshop Revision · Modules 1 & 2

"Welcome. This first module assumes no nuclear background. By the end you should be able to follow what happens, minute by minute, when something goes wrong at a nuclear or radiological facility, and see where your own institution fits."

"Everything here comes from the national EPR documentary baseline, and sources are cited on the slides. We use IAEA GSR Part 7 as the yardstick in all four modules."

"The module has three movements. First, what the hazard is and why we prepare. Second, the machine: how a plant works, what is inside it, and how that material could reach people. Third, the response: how an emergency is declared, the zones, the protective actions, and who does what."

"The hinge is 'The Pivot'. Everything before it is about prevention and everything after it is about response."

"An emergency is any event that actually or potentially exposes the public, workers or the environment to ionising radiation. It is not only reactors."

"Kenya already lives with most of this list: sources in use, transport, orphan sources, and the risk of malicious use. There are more than 1,500 registered sources moving through hospitals, industry and roads today. The reactor scenarios are a future layer added on top of a hazard we already have."

"Nuclear safety is organised as defence in depth. Barriers are stacked, and each one assumes the one before it can fail: safe design and siting, safe operation and regulation, accident prevention systems, and on-site mitigation. EPR sits under all of them."

"EPR is not a prediction that accidents will happen. It guarantees that if every other barrier fails, the public is still protected. That is why the IAEA requires EPR arrangements to be in place and exercised before a facility operates, not afterwards."

"GSR Part 7 sets eight goals. The first ones are immediate: regain control, mitigate, prevent severe health effects, and treat the injured. The rest show that a response is judged over years, on health, environment, economy and public trust."

"Look at goal 6, non-radiological consequences. At Fukushima, panic, unwarranted evacuation, stigma and economic loss often did more harm than the radiation. Kenya must manage fear as deliberately as dose, and that is why public communication comes up throughout this series."

"GSR Part 7 (2015) is the master set of requirements. It has 26 requirements, addressed to government, the regulator and operators. It is co-sponsored by 13 international organisations, so it reaches health, food, aviation, maritime and policing, not only the nuclear sector. That is why this room holds far more than nuclear specialists."

"Below it sit the safety guides: GSG-2 on criteria, GS-G-2.1 on arrangements, GSG-11 on termination, GSG-14 on communication, and the EPR practical tools. Then there are the two 1986 conventions, the IAEA operational networks (USIE, RANET, the Incident and Emergency Centre), and peer reviews. Kenya hosted an EPREV mission in 2015."

"On the conventions, Kenya has already written the notification duty into law in NRA s.61. Module 2 comes back to treaty status."

"Under the graded approach, the preparedness effort scales with the hazard. There are five categories."

"Category I is nuclear power plants, where an on-site event could cause severe health effects off the site. That is our future Siaya plant, with construction from 2028 and commissioning in 2034. Category II covers research reactors and large-source facilities, where off-site doses could warrant urgent action but would not cause severe effects. That is the planned research reactor (about 2030) and large irradiators. Category III is smaller sources where action is needed on site only, such as hospital teletherapy, industrial radiography and cyclotrons. That applies now."

"Category IV is the one people miss. It applies to every State on earth: emergencies at unforeseeable locations such as lost sources, transport accidents and border detections. 'We have no reactor' has never meant 'we need no EPR'. Category V is areas near a foreign Category I or II facility, where the concern is contamination of food and commodities crossing the border."

"The 2015 EPREV reviewed Kenya as a Category III/IV State, and that is still our category today."

"Four questions, in order. How does a pressurised water reactor make electricity? Why is the material inside dangerous? How is it held in? And what happens when prevention fails? You don't need to be an engineer. You need just enough to see why the emergency classes are built the way they are."

"Follow the energy through the diagram. Fission splits uranium-235 and the energy becomes heat. Control rods and the moderator keep the chain reaction steady. In the primary loop, water under high pressure carries the heat away, and the pressure stops it boiling. In the steam generator, that water boils separate, clean water through thousands of tubes. The steam spins the turbine, and the generator sends electricity to the grid."

"The point for EPR: in normal operation, the radioactive primary loop and the steam that drives the turbine never mix. Keeping them apart is part of confinement."

"Splitting uranium creates hundreds of unstable atoms, the fission products, and neutrons make surrounding materials radioactive, the activation products. Almost all of it stays inside the fuel."

"The scale: about 5 billion curies in the core of a 3,300 MW(th) light-water reactor, 30 minutes after shutdown. Only the core holds enough material, and enough decay heat to drive it out, to cause injuries or deaths off the site."

"Not all of it moves the same way. Noble gases, krypton and xenon, are the most volatile, and up to 100% could escape in a severe accident with containment failure. Iodine and caesium come next, and iodine concentrates in the thyroid. Strontium, tellurium and the rest matter mainly for ground and the food chain."

"EPR exists because of this inventory, and because the most mobile part of it can travel on the wind."

"Radioactive material only harms people through a pathway, and every protective action later in this module closes one or more of these five."

"Cloudshine is radiation from the plume overhead, and it stops when the plume passes. Groundshine comes from material deposited on surfaces, and it keeps going. Skin dose comes from particles on skin and clothes. Inhalation means breathing the plume, and iodine then goes to the thyroid. Ingestion means contaminated food, milk or water. It is the slowest pathway, so it gives the most time to act."

"No single action closes all five. Sheltering and evacuation cut cloudshine, groundshine and inhalation together. Stable iodine blocks one inhaled nuclide and nothing else. Food restrictions close ingestion. That is why the response always uses several actions at once."

"Deterministic effects are the severe, early ones. They have a threshold, and below it the effect does not happen. They appear within hours to weeks: radiation sickness, organ damage, death. Early injuries begin around 0.5–1 Sv whole body. Early deaths are expected around 2.5–6 Sv. About 3 Sv would kill roughly half of those exposed within 60 days with minimal treatment, and supportive care raises that to about 4.5 Sv. The response goal is to prevent these outright."

"Stochastic effects are the long-term risk. There is no threshold, so any dose adds some probability of harm. They appear years later as cancer that looks exactly like any other case. A higher dose changes the odds, not the severity. They cannot be counted in one person. They are a population-level risk, managed by keeping doses low. The response goal is to reduce them as far as reasonably achievable, and that is why the response continues long after the release stops, through relocation, food controls and monitoring."

"Off-site harm is never the result of one failure. It needs three conditions together: the fuel melts on a substantial scale, AND containment fails or is bypassed, AND there is a path to the atmosphere with a push, usually steam. Only then are off-site injuries or deaths realistic."

"The plant also fights back. Inside an intact containment, gravity and natural settling remove most particles. If containment holds for several hours and the sprays or coolers work, early injuries or deaths are unlikely."

"Keep this in mind for later. Only the highest emergency class orders public protective action, because below it these three conditions are not all present."

"Every safety system in a plant serves one of three jobs. The first is to control reactivity: start, steady and stop the chain reaction. Lose it and power runs away. The second is to remove heat, from the reactor and the spent-fuel pool, long after shutdown. Lose it and the fuel overheats even when shut down. The third is to confine radioactive material. Lose it and the inventory starts to move."

"Lose any one of them for long enough and the physical barriers fail in order, from the inside out. That order is exactly what the classification system watches for."

"Four physical walls, from the inside out. ① The fuel matrix, a ceramic UO₂ pellet that locks in most fission products. ② The cladding, the sealed Zircaloy tube, where gases, iodine and caesium collect in the gap. ③ The reactor coolant pressure boundary: vessel, piping, pumps, pressurizer and steam-generator tubes. ④ The containment building, a low-leakage steel and concrete shell that is the final barrier. Its biggest threat is long-term pressurisation, not one sudden blow."

"Each barrier is assessed separately. An accident is graded by how many barriers are challenged or lost, and that is how the emergency class is decided."

"Five successive levels. Level 1 prevents abnormal operation through conservative design and good practice. Level 2 controls abnormal operation and detects failures. Level 3 controls design-basis accidents with engineered safety features. Level 4 controls severe conditions and mitigates severe accidents. Level 5 mitigates the radiological consequences of significant off-site releases, and Level 5 is EPR. That is where every one of you comes in."

"Everything before this slide was prevention: design, barriers, safety functions, and the three S's of safety, security and safeguards. Everything after it is response: classify, protect, inform, recover."

"It has happened three times at power plants: Three Mile Island in 1979, Chernobyl in 1986 and Fukushima Daiichi in 2011. Each happened in a country with a mature regulator. Planning for failure is not pessimism. It is the lesson of history."

"Operators don't diagnose the accident before they act. There are three steps. Observe: they watch a small number of critical safety functions on control-room instruments, and they don't need to know what happened to know the plant is unsafe. Compare: pre-set Emergency Action Levels turn readings into a class. The judgement was made in advance, in daylight, by people who were not under pressure. Declare: the declaration automatically starts the pre-planned response for that class, meaning notifications, staffing and protective actions."

"Both errors are dangerous. Over-classifying causes needless disruption and fear, and under-classifying loses time. Also, never wait for an INES rating. INES explains an event to the public afterwards. It does not decide what to do now."

"From the top. General Emergency (Cat I/II): an actual or projected substantial release. All protective actions in the inner zone, and the IAEA and affected States are notified. Site Area Emergency (Cat I/II): major degradation of safety functions, with off-site doses still below criteria. Full on-site activation, and off-site authorities on standby. Facility Emergency (Cat I/II/III): on-site response only, no off-site threat, regulator notified. Alert (Cat I/II/III): protection is uncertain or reduced. Assess, mitigate and raise readiness, with no public action."

"Then Other Nuclear or Radiological Emergency, for Cat IV/V. This is Kenya's daily reality: lost or stolen sources, transport accidents, malicious acts and transboundary events. The response is led from the scene using pre-set safe distances. It is the class most likely to be used in Kenya in the next decade."

"Classification triggers everything downstream, so it must be fast. The draft regulations require 15 minutes for reactor facilities. Defining the criteria is already a statutory duty on KNRA under NRA s.57(a)."

"Zones are planning tools, not fences. They define which arrangements must exist in advance, and where. PAZ (3–5 km): evacuation, sheltering and stable iodine before or shortly after release, planned and automatic, with sirens and pre-distributed iodine. UPZ (out to 30 km): actions guided by monitoring against OILs. EPD (about 100 km): early actions such as relocation and screening to reduce long-term effects. ICPD (about 300 km): controls on food, milk, water and commodities."

"For counties: Siaya hosts the site, but the UPZ and ICPD reach Kisumu, Busia, Homa Bay, Vihiga and beyond. This is a multi-county plan by nature."

"The toolkit has five actions. Shelter in place is often the first and safest. Evacuation is pre-planned in the PAZ and guided by monitoring in the UPZ. Iodine thyroid blocking works best if given early. Food, milk and water restrictions apply out to 300 km. Early relocation is based on measured deposition."

"Two teaching points. First, sheltering is often better than evacuation. Unwarranted mass self-evacuation can cause more harm than the release, so alerting must be geographically targeted. Second, decisions use three pre-set tools. Generic criteria are dose levels where action is justified, for example urgent action at 100 mSv projected in 7 days and ITB at 50 mSv to the thyroid. EALs are plant conditions that trigger classification without debate. OILs are field measurements (µSv/h, Bq) that trigger an action without further calculation. For source events there are safe distances, such as 30 m for a damaged package and 300 m for a suspected dispersal device."

"The whole system is pre-computed. In an emergency nobody should be doing dose arithmetic. Responders compare a reading to a table and act. And this criteria and OIL system is exactly what Module 2 shows Kenya has drafted but never brought into force."

"Here's the scenario. The plant loses off-site power. The emergency diesel generators start, but one fails. Feedwater to a steam generator is then lost, cooling degrades, fuel is damaged, and finally containment is challenged. It is one event that passes through four declarations: Alert, Facility Emergency, Site Area Emergency and General Emergency."

"For each class, watch the same six questions: trigger, actions, who, when, how, where. What to watch for is the circle of people involved growing at each step."

"Trigger: off-site power is lost and one diesel fails. The reactor is shut down and stable, but protection is reduced and uncertain, and nothing has been released. Actions: assess, mitigate and raise on-site readiness, with no public action. Who: the control room declares, the on-site emergency organisation staffs up, and KNRA and the national notification point are informed. Off-site responders are told, not activated. When: promptly. In US practice the Technical Support Centre is staffed in about 30 minutes. How: restore equipment, bring up support centres, brief off-site authorities and watch for escalation. Where: the facility only, with nothing in any zone."

"Trigger: cooling to the steam generator is lost, primary temperature and pressure rise, a leak develops inside the reactor building, and radiation rises inside the plant. Actions: mitigate and protect people at the facility and on site. GSR Part 7 says clearly that this class presents no off-site hazard. Who: the operator's full on-site organisation under the emergency director. The regulator monitors, and off-site agencies are still informed only. How: notify everyone on site, move people to assembly points with monitoring, account for all personnel, give first aid and take urgent on-site actions. Where: facility and site, with no zone activated."

"Note that the US uses four classes (Unusual Event, Alert, SAE, GE) and has no Facility Emergency. That class comes from the IAEA scheme Kenya has adopted."

"Trigger: core cooling can no longer be assured and fuel damage is possible, but there is no significant release yet. Actions: three things at once. Mitigate and protect on site, increase readiness for off-site action, and start off-site monitoring and sampling. Who: the off-site organisations now mobilise. The regulator, county and national responders staff emergency centres, monitoring teams are dispatched, and public information goes out through off-site authorities."

"When: promptly. The value of this class is the time it buys before anything is released. In US practice the off-site emergency operations facility is staffed within about an hour. How: staff all centres, dispatch teams, evacuate non-essential site staff, and put near-site evacuation personnel at their stations. Where: the site and its vicinity. The UPZ goes on standby and warning systems are readied but not necessarily sounded."

"Trigger: substantial core degradation is under way and containment is challenged. Both conditions from earlier are now present, and a significant release is happening or projected. Actions: precautionary urgent, urgent and early protective actions, on and off site, plus on-site mitigation."

"Who: the operator declares and recommends, because it sees core and containment conditions first. The off-site decision-maker orders public protective action, county and national responders carry it out, the regulator advises, and the IAEA and potentially affected States are notified. When: before or shortly after release, based on plant conditions, not waiting for measurements. PAZ actions are automatic. In US practice, recommendations reach officials within 15 minutes, the public is alerted within 15 minutes of that, and the regulator is told within one hour."

"Where: PAZ acts on plant conditions alone. UPZ acts on monitoring against OILs. EPD takes early actions. ICPD applies food and commodity controls."

"Evacuation is the single most effective action if done before or shortly after release. It avoids plume, ground and inhalation dose at once and clears the highest-risk area. Sheltering is useful but limited. A typical house cuts dose by about a factor of 2, a closed small dwelling by about 3 for a one-hour release, and large concrete buildings do far better. Iodine thyroid blocking only works if taken just before, or within 1–2 hours of, intake, and it supplements evacuation or sheltering but never replaces them."

"Food, milk and water restrictions usually allow hours to days, which is why they are planned nationally. Contamination control covers monitoring and decontaminating evacuees and controlling access. Early relocation finds hot spots after the plume passes; US practice uses a trip level of about 1 R/h. Improvised respiratory protection, such as a towel over the face, is secondary only. It helps against particles, not gases, and must never delay sheltering or evacuation."

"Emergency workers have their own guidance values, in Hp(10). Routine emergency response such as firefighting and monitoring: under 50 mSv, with full PPE, dosimetry and medical fitness. Averting a large collective dose: under 100 mSv, informed volunteers only, where the benefit clearly justifies it. Lifesaving and preventing severe effects: under 500 mSv, volunteers only, with informed consent, a full briefing, and no pregnant or breastfeeding workers. Helpers, meaning members of the public who volunteer: up to 50 mSv, registered, briefed and with dose recorded."

"The principle is that nobody is ordered into a high dose. Also: dosimeters for every worker, doses recorded, ITB where radioiodine is possible, medical advice above 200 mSv before any further exposure, and just-in-time briefing for workers not designated in advance."

"EPREV Recommendation 11 on responder dose control stays open until dosimeters actually reach first responders. Module 3 returns to it."

"Every institution in this room is on this slide. Government and Cabinet: policy, declaring a National State of Disaster, international assistance and treaties. KNRA: sets requirements, approves every operator plan (a licence precondition), sets classification criteria, gives technical advice, and is the IAEA contact point. The operator: classifies and declares, mitigates on site, and notifies the regulator, operations centre and county within 15 minutes. NDRMA and the national operations centre: all-hazards command and multi-agency coordination. Counties: carry out protective actions on the ground (evacuation, shelters, reception centres, local communication). Sector agencies: MoH and KNH, Police and KDF, fire and HAZMAT, NEMA, the Communications Authority, the Red Cross and St John."

"The architecture is standard worldwide. The operator acts on site, the regulator judges and advises, the all-hazards system commands off site, and counties carry it out. No one institution can respond alone, which is why GSR Part 7 Requirement 2 requires a national coordinating mechanism at the preparedness stage. Module 2 shows where Kenya's version has gaps."

"Module 2 in one sentence: Kenya has strong laws and a complete technical draft. But the technical layer is not in force, and the on-site and off-site sides are not connected. Most of this can be fixed with regulations under two Acts that already exist."

"Say the review date aloud: 30 August 2026. Everything is as of that date."

"Part 1 is the method, Part 2 the diagnosis, Part 3 the prescription. The big message: Kenya already knows what good EPR looks like. The task is to bring it into force and connect the on-site and off-site sides."

"A is the standard itself, GSR Part 7, with 26 requirements. B is the independent peer review Kenya requested in 2015: 14 recommendations, 5 suggestions and 5 good practices. We checked what has been resolved eleven years on. C is the US, UK and EU. They are not used to grade Kenya. They show at what level of law other States place the same duties, and that tells us the fastest lawful fix."

"One rule throughout: a draft shows intent. It never counts as compliance. Every finding was re-checked against the primary text of the instrument cited."

"T0 is the Constitution and treaties. T1 is Acts, which create bodies, powers, offences and funds. T2 is Regulations, made under a power in an Act. T3 is regulatory instruments, the regulator's guides and licence conditions. T4 is national plans, which are law only if an Act says so. T5 is administrative arrangements such as MoUs, SOPs and ToRs, which are not law."

"As you go down, legal force falls but speed rises. Under Constitution Art. 94(5), nothing below an Act has force unless the Constitution or legislation gives it. So for every gap, the question is: what is the lowest, fastest tier that still binds the body that has to act?"

"This is the one-picture answer. T0 shared: disaster management is shared between national and county government, and treaty status is unverified. T1 in force: the Nuclear Regulatory Act 2019 and the NDRM Act 2026, but neither mentions the other. T2 empty: the 2021 EPR Regulations were never signed, and nothing has been made under the NDRM Act. T3 empty: no KNRA guides or EPR licence conditions were found. T4 mixed: NERP 2020 is in force but silent on radiation, the CBRN Response Plan 2015 is still a draft, and the CBRN Action Plan 2025 is non-binding. T5 not law: the Working Group ToR is unsigned, plus the 2013 Presidential Directive and Executive Order No. 2 of 2023 (unverified)."

"The diagnosis is in the two red rows. Regulations and regulatory instruments carry the technical detail in every comparator State, and both are empty in Kenya. And because T0 makes disaster management a shared function, national rules alone cannot command county fire services or hospitals."

"Be generous here. NRA 2019, in force since January 2020: no licence without an approved emergency plan (s.58), on-site and off-site plans required and reviewed (ss.59–60), immediate IAEA notification with KNRA as contact point (s.61), and a national source register (s.39). Section 58 is broader than the US equivalent because it gates any authorization of any activity, facility or source, not only power reactors."

"NDRM Act 2026, in force since June 2026: a statutory disaster authority, legal classification and declaration of disasters (ss.29–30), a national responder database (s.27), annual drills (s.7(p)), and a power to protect responders that has never been used (s.55(2)(i))."

"Groundwork: the draft 2021 Regulations cover all 26 requirements, the National Incident Command System is in use, SMS tower alerting has been demonstrated, and radiation detection is in border, police and customs training. The 2015 good practices were verified in 2015, so present them as foundations to reconfirm, not current findings."

"Two headline numbers. Against GSR Part 7: 0 conformant, 15 partially conformant, 10 not conformant, and 1 not applicable. Requirement 3 is addressed to international organizations. 0 of 26 fully or largely met."

"Against EPREV 2015: 2 of 14 recommendations resolved (R5 and R6, both through the NRA 2019), 2 partly resolved, 10 unresolved, and 0 of 5 suggestions."

"The pattern: where a requirement is covered at all, it is by a law in force that ignores radiation, or by a radiation text that is not in force."

"These five gaps explain almost every score. 1. Nobody owns the off-site response. Operators have a rigorous on-site regime that hands off to nobody: no off-site strategy, no designated decision-maker and no prescribed off-site plan. This is the core gap. 2. Radiation is invisible in the national system. We verified zero references in NERP 2020 (166 pages) and the NDRM Act 2026, and KNRA and Health are not on the NDRMA Board. Until classified, every disaster is deemed a county disaster under s.29(6), which is the wrong default for a radiological release."

"3. No single answer on the day. Five documents give different answers to who declares, coordinates, commands on scene and orders protective actions. 4. The public is not medically covered. The draft rules cover operators' workers only, with no triage or casualty pathway for the public. 5. Alerting and funding are not in law. SMS alerting was never codified, and the Disaster Risk Management Fund has not been set up."

"This is the turning point of the module. Necessary: the draft holds every technical rule Kenya lacks, including categories, intervention levels, worker dose limits and plan outlines. It is a competent, one-to-one transposition of GSR Part 7, and it has been unsigned for about five years."

"Not enough: it was made under the NRA, so it can bind only KNRA and licensees, not NDOC, NDRMA, Health or counties. In the text, 'the operator' appears 172 times, and national bodies appear zero times."

"Settle first: s.98(1) gives the power to make regulations to the Authority, in consultation with the Cabinet Secretary, but the draft is expressed as made by the Cabinet Secretary. Say this clearly: it is a textual discrepancy, not a legal opinion. It is for the Attorney-General."

"The conclusion: the off-site duty-holder cannot come from these Regulations. It has to be created under the NDRM Act."

Read slowly. This is Part 2 in six lines.

"✓ A licensed operator with a KNRA-approved on-site plan, a real advance since 2015. ✗ A national system that never mentions radiation. ✗ Technical criteria unsigned since 2021. ✗ No one legally in charge of off-site protective actions. ✗ Hospitals with no radiological triage in law or in draft. ✗ An emergency fund that doesn't yet exist."

"One tick and five crosses. The good news is that most of the crosses can be removed without going back to Parliament."

"The two Acts reach two different sets of bodies. NRA s.98 reaches KNRA and licensed operators, covering emergency categories and criteria, worker dose limits, classification and 24/7 notification, and the form of on-site and off-site plans (s.59). NDRM Act s.55 reaches the disaster-management system, and the counties through consultation with the Council of Governors, covering off-site decision authority, the mandatory s.29(8) classification criteria, public warning and responder protection (s.55(2)(i))."

"Together they give a connected on-site and off-site framework without amending either Act, and neither Act is enough on its own. The UK did exactly this. Its 2019 REPPIR regulations were made under a 1974 Act and put a named off-site duty on a named local authority, and nobody amended the Act."

"Teach this. The Working Group will use it repeatedly. Step 1: is there a power in an Act to make rules on this? If not, amend the Act. Step 2: does it create a body, offence or fund, or change county roles? If yes, it needs Parliament or county law. Step 3: does the duty fall on a body governed by a different Act? If yes, use that Act's power, or an MoU or joint SOP. Step 4: otherwise, use the lowest tier that binds: regulations, then licence conditions, then plans and MoUs."

"Step 3 is the one people get wrong, and it is what went wrong in 2021. A good instrument was drafted to carry duties it had no power to impose on the bodies that needed to bear them. Applied to Kenya's gaps, the answer is almost always Step 4, regulations under the right Act."

Don't read every row. Point at the Time column.

"Row 4 is the fastest item on the whole roadmap. NRA s.57(a) already obliges KNRA to define emergency classification criteria. That has been in force since 10 January 2020 and does not depend on the draft Regulations being signed. Row 6: Parliament has already given the power to make responder-protection regulations, in NDRM s.55(2)(i). Row 7 is where we must be honest. County health is devolved, so national rules reach only part of it."

"7 of 8 gaps are regulation-level work. Gap 4 only needs KNRA to act on a duty that already exists."

"We looked for a workaround for each of these, and none exists at the regulation tier. P1: add KNRA and Health to the NDRMA Board, since membership is fixed in s.9. This is the one to press. The Board that classifies a radiological disaster has, by statute, neither the health ministry nor the nuclear regulator at the table. P2: create offences for off-site EPR failures, because neither Act gives that power."

"P3: make the fund mandatory. Section 45 only says it 'may' be established, but today the Treasury can set it up under s.45 with PFM Act s.24(4). P4: place duties directly on counties, since fire, disaster and health are devolved. For now, use county laws or an intergovernmental agreement. P5: name the national body in NRA s.57. For now, get the same effect by designating it in NDRM s.55 regulations."

"P3 and P5 are good news because each has a lawful route today. Naming these five stops the Working Group wasting a year trying them at the wrong tier."

"Immediate (0–3 months): KNRA asks the AG who makes the EPR Regulations. KNRA issues classification criteria under s.57(a). All members sign the Working Group ToR. The Treasury establishes the Disaster Risk Management Fund. Within 12 months: KNRA and the CS finalise and gazette the EPR Regulations. The CS and the Council of Governors make off-site regulations under s.55. The CS makes the mandatory s.29(8) classification regulations. Before commissioning: Foreign Affairs and KNRA confirm treaty status, and Health and the Council of Governors set medical and county arrangements through an intergovernmental agreement."

"Be honest about timing. Regulations are faster than an amendment, but not fast. They need consultation, possibly a regulatory impact statement, gazettement, laying before Parliament within 7 sitting days, and up to 28 sitting days of committee scrutiny. Gazettement is not the finish line: under Statutory Instruments Act s.11(4), an instrument that is published but not laid ceases to have effect."

"What we have: strong Acts and a complete technical draft, but the technical layer is not in force and the national system ignores radiation. What is missing: the off-site side, meaning someone legally in charge of off-site decisions, warnings, responder protection and public medical care. How we fix it: regulations under two existing Acts, NRA s.98 for operators and NDRM s.55 for the response system. Only five items need Parliament."

"Earlier editions said signing the Legal Notice was the single most consequential act available. The evidence says signature is necessary, not sufficient. It cannot reach off-site bodies, and it may not be the Cabinet Secretary's to give. Module 3 is next."