Draft document: Emergencies
Submitted by Marcel LIPS, Goesgen Nuclear Power Plant
Commenting on behalf of the organisation

1. The report is consistent with the ICRP general recommendations aiming toward extra stringency and therefore not compatible with the repeated commitment by the ICRP chairman that its new recommendations do not trigger any practical change for the nuclear industry and that the current practices and regulations stay adequate for the industry, thus maintaining stability in the RP system. In this context a very serious issue is the tendency to restrict radiation exposure levels to values well below the reference levels not taking into account the annual probability of occurrence – a concept that has been adapted in many countries from ICRP64 "protection from potential exposure" (which is even not referenced in the actual report). For small countries with a high population density where it is not possible to build nuclear installations far away from towns and villages and where the maximum reference level itself can become an invincible hurdle, such an additional restriction will probably disallow to further operate existing or to build any new standard designed nuclear installations without additional expensive improvements or emergency countermeasures to keep the exposure in all situation far below the 100 mSv level. This could force these countries to abandon nuclear power generation because of economic reasons. In the coming times of shortage of power generation this is not a favorable situation. 2. The document is written in such details that it is becoming largely idealistic and academically. Real emergency responses, where initially rather unknown detail situations predominate and the response must deal with RP and maybe several other hazards, will fail with such a theoretical approach. Simple and flexible emergency response concepts adapted to practical aspects would help implementers to move straight forward in the response to a specific emergency situation. 3. I agree that optimization and justification can be well done in the planning stage of emergency situations as well as for existing exposure situations to reach the best protection taking into account the reference levels, as well as social and economic factors. In contrary I do not agree with the report, that optimization and justification can always be done during an emergency situation itself. Emergency situations can sometimes develop very quickly, not as foreseen and need immediate response with no time for a broad decision making process including several options. In such cases the response must be developed in a manner of common approach of all safety aspects, including RP, optimization, justification, fire hazard, insured ore dead persons, plant behavior, chemical hazards, and so on. Nevertheless RP should not override the overall view of the emergency response. 4. Consistency is not always given through the document. While the draft states that it is applicable to all emergency situations, the text has often been written with nuclear power plants in mind. 5. Stakeholder involvement has become an important factor in public acceptance of any kind of technology. So far stakeholders must be included in the discussion of the protection of people in emergency exposure situations. Nevertheless the scope of stakeholders and affected persons must be reassessed and reduced to a practicable level. Involving all those potentially exposed or affected people to the extent possible will end up in endless discussions of to parties slowing down or disallowing every project.