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Submitted by Judith Johnsrud, Ph.D., NEW ENGLAND COALITION ON NUCLEAR POLLUTION,et al.
   Commenting on behalf of the organisation
Document Emergencies

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, , 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.