TO: THE INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION ===================================================== NEW ENGLAND COALITION [ON NUCLEAR POLLUTION, ENVIRONMENTAL COALITION ON NUCLEAR POWER, NUCLEAR POLICY RESEARCH INSTITUTE: BEYOND NUCLEAR Comments on “Application of the Commission’s Recommendations for the Protection of People in Emergency Exposure Situations“ 42/194/08 ============================================================ The following comments on this ICRP draft document are submitted on behalf of three public-interest citizens’ organizations two of which have been involved since 1970-1971 with nuclear reactor licensing, operations, and safety, with issues of radioactive waste management, and with issues of the adverse health effects of radiation exposures from all sources. Two of these organizations are the New England Coalition [on Nuclear Pollution] and the Pennsylvania-based Environmental Coalition on Nuclear Power. The third is a national group: Nuclear Power Research Institute: Beyond Nuclear. Some decades ago, an engineer with the U.S. Nuclear Regulatory Commission assured one of us that there was no reason to fear sabotage at a reactor or detonation of a nuclear bomb on our city streets. That age of innocence is now long gone. However, in the United States, those in the nuclear industry who are responsible for public safety have yet to conduct full-scale tests with ordinary people participating to demonstrate the ability of their emergency plans to perform successfully in a “real world” response of a full population to such a radiological event. We suggest that only those who had experienced their governor’s call for evacuation of women and children during the Three Mile Island accident in the U.S., and the actuality of evacuation of those affected by the Chernobyl accident in Ukraine can speak from those experiences of how citizens actually reacted to those perilous unanticipated events. The ICRP is commended for undertaking to address the significant need to develop better preparation, worldwide, for such future events. With regret, we conclude that these recommendations are lacking, and in the event of an accident or attack, confusing in some important ways. Of particular concern, in the Executive Summary is the application of the principle of “optimization” of radiological protection to the wide variety of accidents and/or intended contamination that might require immediate full scale evacuation or emergency medical treatment of large numbers of individuals. As we understand optimization, and had noted in prior comments on the earlier ICRP recommendations, this is a concept perhaps applicable to a particular situation of contamination and need for immediate medical care of the medical personnel, or an event that requires quickly assembling and evacuating a large population, or a situation requiring provision of lodging and uncontaminated food for contaminated evacuees. There are many other scenarios having quite different and incompatible response requirements. But it appears in the Executive Summary that the concept of optimization is being applied to differing categories of need – for immediate treatment, or for directions, evacuation, or a host of other early response requirements – that are not compatible with or suited to accomplishing the maximum effective assistance to all who are at risk. The principle of “justification” in such a situation in the prior ICRP report appears to have been “maximizing the margin of benefit over harm” – and this is to be accomplished by “restrictions on the overall doses or risks received by individuals” resulting from the radioactive emergency. How are such life and death decisions at the scene of a nuclear disaster to be determined? And by whom? What are the criteria? Who gets to choose at a moment of shock and disorientation? How long will it take and by whom and with what equipment at the site will exposures be determined to set “reference level doses or risks”? What priority is afforded to earliest possible decontamination of the site? Similar questions must be taken into account with “more good” versus “more harm” decisions, and with decisions on a victim of “severe deterministic injury” that leads to near-term premature death versus the victim who receives a similar or higher dose but lives for twenty or more years. The latter apparently less critical victim should not be dismissed with a less timely and acceptable treatment, only to suffer illness and premature death later. No matter how difficult triage decision-making may be at the scene and moment, decisions must be made. The ICRP’s principles should be applied without exclusions or prejudices toward any of those affected by the radiological event. If these interpretations of intent and impact are inaccurate, we respectfully recommend careful editing throughout the documents to clarify the authors’ meanings and intent. The Sections i, j,k, and l, by contrast, seem reasonably clear. In Section p, we note the reference to “plant conditions” which may indicate that the proposals may be primarily directed toward reactors or perhaps fuel fabrication or treatment facilities. Sections q through y address implementing protection strategies and transition to rehabilitation with the varied realities that may be encountered – unanticipated “real world” conditions that may differ greatly from anticipated scenarios. In these sections it is suggested that the various types of sources of radiological releases may require very different approaches in developing post-explosion or post-release planning. The early response process at the scene of the accident for those facilities may also differ from an attack scenario. All early decisions and actions must also take into account the restoration of order and, if needed, direct additional decontamination. The nuclear industry is currently proposing to construct additional reactors worldwide, to expand the uses of radioactive materials, to mine and enrich more uranium, to store or deregulate and recycle large amounts of radioactive wastes, and possibly -- or some say probably -- to develop additional nuclear weapons, and allow, or be unable to prevent, diversions of radioactive materials by those who would cause harm to civilian populations, purposely or by accident. The probability of serious accidental and/or intentional detonation of nuclear “dirty bombs” and/or releases of other radioactive materials appear to be increasing rapidly as more nations are led to believe that they need reactors and atomic weapons in our dangerous world. They are joined, and their threats increased, by the deadly actions of terrorists worldwide. In making the transition to rehabilitation described in Basic Principles, Section z indicates that ongoing dose levels -- varying from one mSv/year to as high as 20 mSv/year -- would be acceptable. Acceptable to whom? Who ultimately decides? After nearly a century of radiation health effects research, and in recent years a much greater understanding of low dose radiation impacts and damage, and with the acceptance by highly regarded scientists and scientific bodies of the Linear, No Threshold (LNT) relationship between dose and response, nuclear accident or attack decision-makers now should also conclude that there is indeed no safe radiation dose. Therefore, especially in the cases of radiological accidents or intentional attacks, the lowest achievable permissible doses – not merely ALARA: reasonably achievable doses – should be adopted by this organization for treatment and management goals. We respectfully urge the ICRP to do so. Additional Comments on the ICRP Document Version 6: Re: 1.1 – 1.2: Scope of this advice; Objectives of protection in emergency exposure situations: There may be discussion elsewhere in the document about litigation related to emergency exposure situations. If not, add descriptions of applicable laws in various nations. At 1.2(5): How does ICRP define the term “practicable effort”? In subsection !.2 (6) subpoint 4: The wording suggests an effort to claim that radiological consequences are, or may be ruled to be, more serious and important than health impacts of irradiation of an exposed person. This could be considered misleading to the public. 1.3 1.3.1(9): What is the basis or justification for the statement that “For malicious events…it is likely that criminal investigation will take priority over radiological considerations”? What differences do or could the change in priority make with respect to the legal status of individuals irradiated during or following the radiological event? 1.3.1 (10) p.14 lines 3-5: How can this statement square with LNT? 1.3.2: It is unclear how “planning of an appropriate response” that is undertaken during a pre-emergency phase can provide appropriate and adequate emergency assistance to persons irradiated at the start of the radiological event (accident or intentional). 1.3.2 (12) If “the early phase” (described in the previous subsection (12) ) “will normally last a few days to a few weeks” (stated on page 15, line 2 and 3), how can this statement be correct? 1.3.4: Does ICRP reject LNT altogether? If not, its impact on dose assessments and health consequences should be discussed. 1.3.5: How are past irradiations (for medical or other reasons or by accidental) factored into dose determination? 1.4 (31) In defining the principle of justification, who receives the “good” and who receives the harm? Who makes these decisions? Who determines what is “sufficient individual or societal benefit” for the person irradiated in the course of an accident or attack, and who determines the value of the offset and detriment that the radiation exposure causes? 1.4.1 (32): Justification and optimization must both be based on all aspects and protection measures, based most of all on minimizing physical harm to the radiation recipients. 1.4.2: (39): If high doses cannot be avoided, are populations at risk still advised to remain in closed structures? By whose authority? NRC, utility or other industry employee ? Or local, state, or just federal government official? Any other? 2.1.1 (45): Here it is stated that “… the Commission’s reference level for emergency exposure situations refers to the total residual dose received/committed over one year.” Are there advantages or drawbacks to producing “reports of dose(s) received/committed annually in future years? Would not this action be of utility to the dose recipients who may develop delayed health problems that require medical care? As more and more radioactive materials may be generated (if additional reactors are built and operated and more wastes are deregulated and recycled into consumer products or construction materials), additional doses may be added to those received from an accident or attack. 2.1.2 (47) Rather than the euphemistic term “severe deterministic injury” it would be more honest to admit that it’s radioactive contamination that may prove prematurely lethal. 2.1.3 (53) (whom to involve) and 2.1.4 (56) (whom to protect) 2.1.4: Unless mentioned elsewhere, provision should be made to address the issue of children and schools. A complaint made frequently by mothers in the vicinity of TMI after the accident was that their children went off to school in different directions, and there were no provisions considered adequate for the parents to be able to retrieve their children in the event of another accident. A radioactive explosion near one of those schools could set off a dangerous situation if parents tried to pick them up, especially if they were at different schools. Equally inadequate is ordering parents not to retrieve them and await an announcement. These situations need more consideration in the plans. 2.1.4 (62): Nations with high requirements may not be willing (or politically able) to utilize ICRP’s standards for effective dose or reference levels. The proposed solution ( setting levels only slightly different) is unlikely to be met with enthusiasm. Note the caution in 2.1.6(4-65). 2.2.2, 22.214.171.124 , and 2.3 seem to present emergency response plans appropriately. They contain reason and common sense to apply to the planning. Thank you for the opportunity to comment on this draft document.