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Submitted by Chris Murray, UK Nirex Limited
   Commenting on behalf of the organisation
Document Reference animals and plants
7 July 2005

(Internet consultation)

Our Reference - 480136

Dear Sir

Nirex's response to the ICRP consultation on the draft for discussion ‘The concept and use of reference animals and plants for the purposes of environmental protection’

Thank you for the opportunity to comment on the ICRP consultation document ‘The concept and use of reference animals and plants for the purposes of environmental protection’.

Nirex is the government-owned body in the UK responsible for the long-term management of radioactive waste. Our mission is:

"In support of Government policy, develop and advise on safe, environmentally sound and publicly acceptable options for the long-term management of radioactive materials in the UK."

Our current role is to:

· carry out scientific, engineering and social science research to help develop safe and environmentally sound options for dealing with radioactive waste in the long term;

· set specifications and standards based on a phased deep geological disposal concept and advise the industry on how to treat and package radioactive waste through the application of the Nirex Letter of Compliance Process;

· maintain an inventory of radioactive waste in the UK in conjunction with the Department for Environment, Food and Rural Affairs (Defra);

· communicate with all stakeholders, including the public, to build understanding and develop ways of addressing the wide range of concerns and views surrounding the management of radioactive waste, so that these influence our work.

This work will be carried out adhering to Government policy at all times, ensuring no conflict or overlap with the work of Committee on Radioactive Waste Management (CoRWM) or the Nuclear Decommissioning Authority (NDA).

Our comments:

In our view, the document does not address how flora and fauna should be considered with regard to very long-term radioactive waste management. In particular, it is not explained how an approach using reference animals and plants could be utilised given ecosystem and species changes that could occur over the relevant timescales of tens of thousands of years.

The suggestion of comparing dose from released radionuclides with dose from naturally-occurring radionuclides requires further consideration. People may have very different perceptions of the risk, or the acceptability of risk, from naturally-derived and man-made sources respectively. Therefore, stakeholder acceptance of such an approach would be very important and should be recognised explicitly.

Section 3 of the document tabulates data availability. We recommend that a comment on the nature of such data should be included in the document to clarify the extent to which spatial and temporal variability applying to the data collection studies will influence their applicability to real ecosystems and the flora and fauna within them.

The document could usefully be updated to take account of recently published work that is specific to this topic, for example the EC FASSET Project, in particular, where such work evaluates the utility of an approach based on reference animals and plants.

We would welcome the opportunity to discuss these issues with you in more detail. If you require clarification about any of the points raised please contact my office.

We would be grateful if you could send us a copy of the outcome of the consultation and add us to any list of interested consultees that you hold.

Yours faithfully

Chris Murray
Managing Director

Direct Line: +44 (0) 1235 825264
Fax Number: +44 (0) 1235 821627