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Submitted by Diana P Sidebotham, New England Coalition on Nuclear Pollution
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Comments of the New England Coalition on ICRP-2005 Draft Recommendations

The New England Coalition (NEC; the Coalition) is a non-profit public-interest organization in the United States, founded in 1971 as the New England Coalition on Nuclear Pollution, with primary interest in nuclear reactors and other uses of nuclear energy; radiation impacts on health, safety and quality of the environment; and development of alternative sources of energy. Throughout its 33 years, the Coalition has participated as a formal party in the licensing and regulation of power reactors in our region and in national proceedings on radioactive waste management.

For numerous reasons, including those cited below, the Coalition respectfully requests that the ICRP withdraw and revise its current proposals, which, otherwise, if adopted, will weaken radiation protection standards. Instead, NEC urges the ICRP to develop recommendations that will be substantially more protective of human health, safety, and genetic integrity.

NEC supports the ICRP plans to investigate the impacts of ionizing radiation on the world’s non-human biota, and to offer recommendations for regulatory measures to protect the well-being and survival of plants and animals, both for their importance to human beings and, perhaps more importantly, for their own sakes. The position taken in ICRP 27 and ICRP 60 that protection of man is sufficient to assure also adequate protection of other species is not tenable.

However, we are concerned that the ICRP’s proposal only to use “reference sets of dosimetric models and environmental geometrics” applied to “reference plants and animals” will result in a level of anthropocentric generalization that predetermines failure to set standards applicable to the need for protection of the vast array of fauna and flora that comprise what ecologists describe as “the web of life.”

New England Coalition’s Principal Concerns and Comments on Draft ICRP-2005

The comments and suggestions below are not exhaustive but represent some of the many concerns of the Coalition with these ICRP recommendations, and the concerns of NEC members who live near operating nuclear facilities or waste sites.

** Whenever there is uncertainty about the adequacy of protection of public health and safety and of the world’s biota, or emerging evidence that existing standards are inadequate, the ICRP and all comparable advisory and regulatory entities should adopt and abide by the Precautionary Principle, in order to assure the highest attainable level of protection for all. Regulatory prudence requires that an advisory body exercise an excessive amount of caution. If, ultimately, this caution is found to be very conservative, no biological harm will have been done. Workers and the public will have been well served.

** However, the NEC cautions that so much radiation has already entered the biosphere -- from the routine emissions and effluent that have been released from the world’s c.440 nuclear power reactors, plus releases from accidents, plus releases from the many other sources of exposures -- that ICRP should not recommend any increases in permissible doses to either members of the public or to nuclear industry workers or military personnel (or those civilian populations, for instance, who are currently being exposed to residual depleted uranium in war zones).

** Many of the presently unregulated technologically-enhanced naturally-occurring radioactive (TENORM) sources should, to the extent possible, be identified and brought under regulatory control.

** The ICRP’s exercise of its charge (remit) should recognize the primacy of protection of people and other biological organisms over providing protection for nuclear industry licensees and those who conduct nuclear energy activities at the expense and survival of people and organisms.

** Although threats of sabotage of nuclear facilities – military, commercial, medical, research, or industrial – have long been of concern to critics of nuclear technologies, the climate of terrorist attack and “dirty bomb” fears that now pervades much of the world must not be used to justify the large increases in permissible dose limits that ICRP proposes. The ICRP has proposed 10 rem (100 milliSievert) maximum effective dose per year. Such limits during and after such an event appear to be designed for, or to have the effect of, allowing or encouraging delays in evacuation, or permitting just minimal decontamination of a radioactive site. This in turn could allow members of the public to return to and continue to live in contaminated environs for decades afterward. It is noted that, in the United States, the Department of Homeland Security is reportedly already planning to promulgate this 10 rem per annum level of allowable dose. After 30 years (roughly the first half-life of cesium-137 or strontium-90, an individual could accumulate upward of a 300 rem exposure, approaching the LD-50 range. NEC strongly urges ICRP to withdraw this proposal.

** ICRP should adopt, and clearly state, the principle that an individual recipient of added radiation exposures (or doses from other contaminants that are being introduced into the biosphere), that are in addition to naturally-occurring background levels, should receive a positive benefit greater than or commensurate with the additional risk incurred. The right of individuals to refuse additive exposures that are not beneficial to the recipient should be respected in ICRP decision-making.

** Cost/benefit decisions and risk assessments should favor those who receive the risks, not those who inflict them. The ICRP should not make health and safety cost/benefit decisions on the basis of nuclear industry allegations of “benefits for society,” at the price of adverse impacts on the lifespan or the well-being of the individuals, or groups of individuals, who will experience the physical damage or bear the financial burdens of ill health.

** The use of organ dose weighting factors that incorporate unacknowledged or unmeasured averages and high levels of uncertainty should be abandoned. This matter is closely related to the issue of internal dose assessment.

** The ICRP must take into account the much greater significance -- the hazards -- of internal emitters than has been the case in the past. In particular, a conservative protective approach to
standards-setting requires that the greater relative biological effectiveness of internal alpha particle emitters be fully recognized. Even research which questions the exact magnitude of the RBE but that has not yet been fully resolved, justifies the conservative approach.

** ICRP must now fully incorporate into its analyses the findings of recent microbiology research on low-level radiation effects at the cellular, sub-cellular and DNA levels. These research results include the occurrence of delayed mutational response, genomic instability, and bystander effect.

** Under no circumstances should the ICRP return to the notion of a “safe threshold” of dose – which it does in these recommendations. Nor should ICRP otherwise ignore or reject the linear hypothesis of dose and response. To the contrary, we urge ICRP to incorporate in the precautionary approach the likelihood that low doses may, at least in some circumstances, cause substantially greater biologic damage than higher doses. ICRP should not recommend a one mrem per year “exclusionary dose limit” that disregards the presence of low levels of radiation.

** The ICRP should not condone the deregulation of radioactive materials and wastes. Quite to the contrary, we urge that ICRP will recommend strongly against both exclusions and exemptions of “low-level” or “low-activity” or “mixed” wastes from regulatory control.

** The use of the healthy, young “Reference Man” as the “most exposed” individual to be protected is not tenable. To the contrary, it is the “most sensitive” members of the population who are the ones in greatest need of rigorous protection: ovum, embryo, fetus, rapidly growing young child, pregnant woman, the elderly, and those with weakened immune system and impaired health. It should be recognized that a nuclear industry worker tends to be well-paid to assume additional risk and has the option to seek other employment. Occupational exposure should, nontheless, also be required to be kept to the minimum. A member of the public has no control over nuclear facility accidents, or intentional or inadvertent radiation releases, or small but cumulative doses received from exposures to unlabeled recycled radioactive materials.

** The ICRP can no longer limit its consideration of adverse radiation impacts to only lifetime risk of fatal cancer and gross genetic defects in the first subsequent generations. Many other resultant non-fatal disorders have been identified with irradiation, at both high- and low-doses.

** The ICRP should utilize the findings of both epidemiological research, which provides identification of potential radiation-related health problems, and microbiological research, the techniques of which can identify the mechanisms of a radiation impact and its outcome.

** Especially in order to provide appropriate radiation protection for members of the public, it is essential to take into account all exposures, high or low, internal and external, that the single individual is receiving from all sources of exposure. These include, inter alia, naturally-occurring, technologically augmented, medical, unregulated, deregulated, recycled, non-nuclear workplace, atmospheric fallout, and any other sources.

** Associated with NEC’s concern that ICRP fails to recommend calculation of the total doses received by an individual from all sources, the Coalition is not comfortable with the basic “Principles and Optimization of Protection” regulatory approach as defined in the ICRP’s Draft for Consultation. The distinction is between a dose constraint to provide a protection level “in all situations that are within the scope” of the recommendations from a “single source” and the way in which “optimization” appears to be applied.

The “dose constraint” is defined as a source-related restriction on individual dose – but just for the “most exposed” individual who is in a “class of exposure” for “all situations within the scope of recommendations from a single source.” The constraints are then identified as “normal situations” [e.g., facility operations?], accidents and emergencies, and the “case of controllable existing exposure” [not clearly defined here]. Dose limits, if they are correctly and conservatively developed, are indeed needed. However, all the implied qualifications in what otherwise ought to be a straight-forward reference to “dose limits” result in the reader’s uncertainty about what other situations may be encountered that are not included in the definition(s).

However, from our perspective, the “effective dose” discussion then further reduces the certainty that the resultant calculated tissue or organ dose equivalent is accurate for any individual by declaring that the recommended terminology [radiation weighted dose] seems to mean more than one thing. Especially with the increased focus on the role of internal emitters, and with the use of unverifiable estimates of organ and tissue doses, NEC concludes that these sections need clarity.

Moreover, “optimization of protection” appears to offer an opportunity to introduce factors extraneous to health protection, such as economics of operations, or acceptable risk. While some aspects of these two basic approaches to the “system of protection” (constraint and optimization) may seem to provide improved results, we suggest that (a) seldom is there a true balance of opinions among the selected stakeholders in decision-making; and (b) an additional set of actors and actions may operate to defeat the intent: namely, failures of regulatory practice to assure that both workers and the public do in fact receive lowest doses and highest achievable radiation protection.

** Dose recipients are subject to little understood interactions of exposures to ionizing radiation and exposures to the many thousands of other toxic materials in the environment, including chemicals, heavy metals, and others that are known to cause biologic injury to the recipient. The research is unquestionably difficult, but the consequences may be highly significant in initiating and intensifying damage. What matters in such calculations are the mixture and synergistic relationships between and among all of these hazardous exposures as they affect the individual.

** The NEC suggests that it is because mutational impacts of irradiation will be irreversible – but have been allowed to be subjected to neglect – that we especially strongly recommend that the ICRP incorporate all of the above concerns and comments in a revised version of its ICRP-2005 standards recommendations to national regulatory agencies that we have suggested and that we support.

The New England Coalition thanks the Commission for taking our comments into consideration.

Diana P. Sidebotham, President
New England Coalition