NRC Comments on ICRP Draft Document Entitled: “Application of the Commission’s Recommendations for Protection of People in Emergency Exposure Situations.” 1. General Comments: Consistency and Harmony with the BSS: The IAEA has recently issued a new revision of safety requirements entitled: “International Basic Safety Standards for Protection against Radiation and for the Safety of Radiation Sources.” (IAEA DS-379, Revision 1.0, July 2, 2008). DS-379 has been developed essentially to be in harmony with ICRP 103 recommendations. Because of the ongoing discussions, some of the thinking in DS379 is now more advanced than the ICRP draft Task Group report. For example, DS379 recommended having a well established emergency system for implementation of emergency plans and radiation protection strategies. In addition, DS379 included safety requirements for establishing measures to protect emergency workers. Therefore, we recommend adding to the emergency basic principles a requirement for “ensuring that an emergency management system is established and maintained to protect human life, health, and the environment in the event of a nuclear or radiological emergency.” In addition, the ICRP document should provide safety recommendations for establishing measures to protect emergency workers (see detailed comment below). 2. General Comments: Integration of Safety and Security: Although the draft document provides recommendations for safety aspects under emergency exposure situations, it does not provide clarification for events that may be security-related. Many aspects of the emergency response will involve law enforcement activities to maintain and preserve evidence during such situations. The document addressed recommendations for safety aspects under emergency exposure situations. However, the document lacked recommendations on safety and security integration and harmonization aspects. It should be noted that under emergency situations, security integration and coordination are of paramount importance to enable achieving overall public and environmental safety. We recommend that the document address this issue in a more detailed fashion under a specific Section or Chapter. 3. General Comments: Repetition and Duplication: The document seems to have a considerable degree of repetition and duplication in discussion and presentation. While the treatment in each section seems to be consistent, the reviewer is left wondering what specific new advances are to be taken from this report, somehow gleaned from the many words and presentation. 4. General Comments: Use of the term “potential exposure”: The document consistently uses the term “potential exposure” to refer to exposures that do occur at different points in time following an event. This use is different from the ICRP uses of the term in other reports, where potential exposure refers to exposures that have not occurred, and only have some probability of occurring. ICRP is encouraged to find a different term for use in this report, to avoid confusion. 5. General Comments: Concerns regarding previous events and applicability for the future. This document is branded by lingering memories of Chernobyl and Goiâna as if the way these events played out will be the way any similar type event will play out in the future. These events were 20+ years ago and much has been learned regarding communications with the public and responders, media as well as the operation of the RMBK reactors. The guidelines also suggest that a reactor accident will always be accompanied by a release of radioactive materials. The language needs to be specific and state "a reactor accident accompanied by a large release of radioactive materials." 6. Executive Summary and Paragraphs #1 through #5: Measures for Protection of Emergency Workers: The document lacked recommendations for measures to protect emergency workers. For example, the document may recommend for an emergency exposure situation to establish: (a) planned level of exposure protection requirement that should be applied when feasible; and/or (b) if such a level of worker protection is not feasible, no emergency exposure worker should be exposed in excess of the single year occupational dose limit except for the purpose of saving life, preventing development of catastrophic conditions, or averting a large collective dose to the public. 7. Executive Summary (d) and Paragraph 55: The document repeatedly used the term “contaminated waste.” We recommend using the term “radioactive waste,” or “waste containing radioactive materials.” The document should rather refer to radioactive waste categories or classes when addressing potential risks for handling and disposal of radioactive waste. 8. Executive Summary (l): It is not clear how "detailed planning to protect against exposures resulting in stochastic risk…" will be accomplished given the very nature of stochastic risk. How can one determine if a cancer is from low-level exposure or from background? 9. Executive Summary (o): If planners have to get agreement from representatives of "all potential stakeholders," then clear guidance is needed on how to identify representatives from this group in a way that won''t cause problems with "all potential stakeholders." 10. Paragraph 4: #5, "to prevent, to the extent practicable, the occurrence of stochastic health effects in the population": Detailed guidance needs to be developed to: 1) identify how to distinguish which of these are radiogenic and 2) characterize the "extent practicable,” or delete this item. 11. Paragraph 6. first bullet: Delete “non-experts” and replace with, “local, regional, or government decision makers and the public.” 12. Paragraph 6, third bullet: Rewrite to read: “Criteria consistent with established radiation principles must be in place before an emergency, because, if they are developed only during or after an emergency, it is likely that such criteria could be perceived as simply a political expediency.” 13. Paragraphs #8 and #42: Dealing with large Uncertainties: The document stated in paragraph #8: “Emergency exposure situations may be characterized by one or more of the following features: significant uncertainty concerning current and future exposures, rapidly changing rates of potential exposure, potentially very high exposures (i.e.; those with the potential to cause severe deterministic health effects), loss of control of the source of the exposure or release.” In addition the document showed in paragraph #42, Figures 3a and 3b, large uncertainty brackets in estimating doses for application of reference levels. The document lacks detailed information on how address these uncertainties to have appropriate decision-making in response to emergency situations. For example, the document may benefit from addressing in more details zoning of contaminated areas relative to risk where different action levels may apply, and consideration of other factors such as category and number of the exposed population, costs, and availability of facilities and supplies to establish alternative scenarios and actions. In addition, approaches for addressing uncertainties such as: expert solicitations, use of field monitoring data, use of realistic and reliable environmental modeling and simulation approaches; may be of benefit to discuss in this document to minimize uncertainties. 14. Paragraphs #21, #56 and #57: Reference Person/Representative Persons: The draft document stated in paragraph #21: “When calculating the effective dose it should be remembered that its value is not related to an individual but to a reference person, averaged over both sexes and all ages.” However, in paragraph #56, the document stated: “In order to ensure that the optimum response strategy is developed, it is important to consider the range of doses and other consequences for individuals that may occur, both in the absence of protective measures, and following implementation of the protection strategy.” Further, the document stated in paragraph #57: “The Commission advises that this is achieved by identifying a set of different population groups who, by their locations, characteristics and behaviors, appropriately represent the full distribution of doses and risks. These population groups should be characterized by representative persons, as described in the Commission''s advice on representative persons [ICRP 2006]. It would be expected that, where children are likely to be present in an affected area, the consequences and protective strategy for this age group would be explicitly considered. In accordance with the Commission''s advice on the representative person, it is important that the dose estimates made reflect the those likely to be received by the groups most at risk (e.g., pregnant women and children), but that they are not grossly pessimistic.” The statement in paragraph #21 appears to be contradictory to those made in paragraphs 57 and 58. There appear to have ambiguities regarding averaging the dose among different populations and selection of a “representative” or a “reference person.” We recommend that the document clarifies these ambiguities and resolve inconsistencies. 15. Paragraph 34: Justification of “significant” resources for response planning to reduce potential exposures that may result in severe deterministic injuries must take into account the probability of such exposures. Since “significant” in this case is indefinite, accounting for the probability in judging justified expenditures for planning provides additional guidance. 16. Paragraphs # 37, 38, 42: References to Figures 3a and 3b: The document refers to Figure 3a in two completely different contexts. This is quite confusing, as it is not possible to understand how the figure is to be used to visualize the concepts. ICRP should take the space needed to give a clear figure for each figure and concept, providing appropriate labeling of the axes, etc. 17. Paragraph # 53: Engagement of Stakeholders: This paragraph, and many others, refers to the engagement of stakeholders. In paragraph 53, it is stated that “It is essential that all aspects of the plan are agreed by all relevant stakeholders.” Agreement is a very strong term, and unlikely to be achieved. Stakeholders can be actively involved, and some type of agreement, or lack of disagreement, is a worthy goal during the planning, but it is hardly reasonable to state this as an absolute. 18. Paragraph # 54. 55: International Stakeholders: This paragraph makes no distinction between the kinds of interactions held at a local level, and the discussions that might take place internationally. It is inappropriate to assume that national organizations will be involved in the many possible local stakeholders in another country. This paragraph should be revised to clarify the intended discussion that interactions are appropriate across national borders, and should be engaged at the appropriate national level. Also note that paragraph 55 seems to return to a discussion of local stakeholder engagement. If true, it would be better placed as paragraph 54, so that the discussion of local stakeholders is in one place. 19. Paragraph 55: Management of Radioactive Waste for Emergency Situation: The document stated: “in emergency exposure situations…, it is likely that very large volumes of contaminated waste will be generated.” Managing and disposing of this waste will pose significant problems both socially and practically, and may even require changes to legislation. Where agriculture is affected the problem of large volumes is compounded with the waste rapidly becoming a health hazard and the production of some food wastes (e.g. milk) not being easily terminated. Engagement with representatives of local communities, producers and regulators in advance of an emergency can provide an opportunity for solutions to be developed in outline, and any legislative changes required to be identified in advance.” Long-term management of radioactive waste may be a safety issue which needs to be addressed beyond an emergency situation phase. The document may address containment of radioactive waste to minimize public exposure and environmental contamination. However long-term management, disposing of waste and engagement of the public and communities during emergencies may lead to improper actions for long-term safety of waste disposal. Nevertheless, emphasis should be placed on containment of waste under emergency situation and applying safety measures to minimize public exposure and minimize impacts to water and agricultural resources. 20. Paragraphs 63-66; Section 2.1.6: Role of Intervention Levels: This section should be a critical linkage between the discussions of optimization of reference levels, and the role played by the earlier concept of intervention levels for particular types of protective measures. Unfortunately, the section is difficult to read, confusing, and does not provide the expected relationship to optimization. 21. Paragraphs 68 and 69; Section 2.2.1: Strategies and Individual Protective Measures: This section, as the earlier section on intervention levels, was expected to provide a clear linkage and relationship between the concepts of reference levels, intervention levels, and then to the individual protective measures. Unfortunately, the section does not address in a clear manner the relationship between the terms, leading the reviewer to no better understanding of how to from a coherent system of protection. 22. Paragraph 131: Termination of Protective Measures: The paragraph states: “Therefore, in general, it would not be expected that the total residual dose will change significantly as a result of the termination of protective measures.” This is not likely to be true, at least in situations where evacuation is no longer necessary, etc. Recent modeling efforts in the United States have shown that a majority of the dose to a population is actually the result of allowing individuals to return after the evacuation. 23. References: References List Update and Consistency with the Text: The document cited references that were listed in incomplete fashion, superseded, or inappropriate. For example, IAEA references on: GS.G-2.1, DS44, One Decade after Chernobyl are incomplete with no dates. IAEA Safety Series 115 is being superseded by DS379 reference to ICRP 103 is missing. In this regard, we recommend that the document be revised to ensure appropriate and complete references and consistency with the text. 24. Editorial Comment: Section Numbering: There are several places, particularly within chapter 2, where the same section number is used multiple times.