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Submitted by Brian Ahier, OECD Nuclear Energy Agency - CRPPH/EGIR
   Commenting on behalf of the organisation
Document Emergencies
General Comments

The CRPPH Expert Group on the Implications of ICRP Recommendations (EGIR) performed a detailed review of the ICRP draft document on Application of the Commission’s Recommendations for the Protection of People in Emergency Exposure Situations. It is hoped that these general comments and proposed text modifications will assist the ICRP in better focusing this document towards addressing the needs of radiological protection community, and in particular emergency management authorities.

The EGIR felt that the document will make an important contribution in providing necessary elaboration of the new guidance for emergency exposure situations as described in ICRP Publication 103. Specifically, it covers many important aspects that can be used by national authorities and operators of nuclear installations, etc in planning protective strategies, and will provide a basis against which national emergency management arrangements can be compared.

However, the Group felt that while the underlying concepts in the document are important, the draft would be substantially improved through a more logical, simplified and consistent structure. It is not clear whether the document intends to provide guidance on implementing the system of radiation protection as described in ICRP 103, or whether it intends to (broadly) address the development of overall emergency response arrangements. The group felt that the former objective was the intent of the ICRP Task Group, and thus these general comments, as well as those in the text, have been directed along this line.

To this end, the EGIR felt that the scope, audience and objective of document need to be identified and/or clarified, and then adhered to consistently through the document. For example, while the draft states that it is applicable to all emergency exposure situations, the text has been largely written with nuclear power plant emergencies in mind. The guidance should be more generic in terms of applicable scenarios, and apply to all emergency exposure situations as well across different approaches to emergencies management. It was broadly noted that language of the document needs to be simplified (more active and less descriptive) and made more practical.

The theoretical approach taken in the document is recognised as valuable, but links to practical aspects and how to integrate the guidance into practical emergency arrangements would also be appreciated. The EGIR appreciated the practical aspects that are included, but noted that several important aspects, such as the descriptions of stakeholder involvement or simultaneous optimisation, are more academic than practical.

The new aspects as described in ICRP 103 represent a major change in emergency management, and should be adequately and clearly addressed, rather than placing emphasis on established and broadly-adopted aspects. The new focus on protective strategies and optimisation represents an importance evolution from ICRP 63, and is a new complexity that still needs to be sorted out in terms of practical implementation. It is noted that the participants from industry felt that the added complexity in the approach may reduce the effectiveness of the response. Contradictions in the presentation of these concepts have been noted throughout the document, and this must be resolved. The EGIR stressed the importance of being accurate and consistent, rather than trying to cover everything in confusing manner. In this regard, the linkages with, and role of, other existing related ICRP documents (such as 63, 82, 96) should be clarified.

There needs to be a better description of optimisation and the role of reference levels (Section 1.4.2). This should also address when optimisation is to be done, and when it should be stopped because it will impact the effectiveness and timeliness of the emergency response (benefit vs. effort). The role of optimisation needs to be strengthened, as the focus seems to be on reference levels, which are component in the optimisation process. The presentation of the concept of a reference level is not clear, and used inconsistently throughout document. There is a need to clarify choice, use and number of reference levels, including in different “phases”. An example or case study (in an annex) of constrained optimisation, and how this fits into the overall planning, would be useful. The draft should recognise that in addition to radiological protection, there are other important criteria in an overall emergency response.

A practical view on how stakeholders should be included could be useful. It was also agreed that in addition to the public, stakeholders also included exposed workers/professionals, responders, industry, etc. There should be a better definition of stakeholder that includes these aspects. The role of these other stakeholders in developing and implementing protective strategies is not adequately reflected in the text.

The importance of consistent, clear and defined terminology throughout the document was stressed. Terminology for workers should be made more precise since in this case, they refer to emergency responders. It was noted that the use/definition of phases is not clear.

The document could note that there are practical tools already in place in many countries, such as decision support systems.

The document makes several references to planning for all scenarios. The EGIR felt that it is important to include the need to undertake a threat assessment as part of the emergency planning basis, and for establishing which scenarios will be planned for in detail. In addition, the mention of severe accidents should be preceded by “low-probability”

The distinction between planning protective strategies for all relevant scenarios and implementing these according to the identified scenario should be clear, with the planning aspects clearly elaborated in Section 2 (Planning), and the implementation aspects clearly elaborated in Section 3 (Implementation), without mixing the concepts. As currently written, Section 3 largely repeats what was already discussed in Section 2, without bringing in new aspects.

Finally, it is noted that it is difficult to provide comments on Section 4: Transition to Rehabilitation in the absence of the other document. The concepts and wording in this section need to be consistent with the concepts in the other document.

Detailed comments on the draft report have been submitted separately for consideration (Note: Detailed comments have not been made on the executive summary. However, the comments noted in the rest of the text apply).