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Submitted by Dr. Florentin Lange, AG 507 of German SSK-Committee
   Commenting on behalf of the organisation
Document Rehabilitation
Working Group AG 507 of German SSK-Committee “Emergency Planning”, 10.10.2008

Comments on draft of ICRP: „Application of the Commission’s Recommendations to the Protection of Individuals Living in Long Term Contaminated Territories after a Nuclear Accident or a Radiation Emergency”

General Comments:

We agree with the conceptual contents of the document and judge it as valuable guidance in implementing specific aspects of the ICRP recommendations 103. However, the document lacks specific and detailed information and guidance which is needed for a better practical application of the ICRP recommendations. It should be made clearer what authorities should do as preparatory actions in the phase, before an event occurred. This concerns general planning actions, educational aspects, provision of various theoretical and practical tools and methods, organisation of stakeholder involvement, etc.
Also more applicable guidance is needed for the phases following a radiological event. These deficiencies become evident when looking at the rather few specific examples given in the document and the current state of some of the figures provided.

Specific comments:

(4) Last sentence: “The Commission recommends that this transition should be undertaken in a co-ordinated and fully transparent manner and agreed and understood by all the affected parties”: This recommendation seems to be very optimistic with regard to a general agreement and understanding because there will be a political debate with a background of different interests of the affected parties. Therefore we have doubts concerning its practical implementation!

(10), (11) The external exposure pathway is hardly discussed. We would appreciate at least one paragraph with information on this exposure pathway

Figure 1: It is questionable whether the figure in is current state and with little additional explanation is really serving the purpose: the range of displayed doses is very low, predominantly around < 30 µSv/a up to 100 µSv/y. This raises the question of the usefulness for exposure situations with much more significant annual doses. Further more, one can only guess that the ordinate describes cases.

Figure 2: The figure is hardly readable

Figure 3: Due to the linear scale of the ordinate the figure has limited information. A logarithmic scale may be better. It is also not clear which age group is displayed.

(17) Some past events are mentioned. It would be useful to have at least a little bit of background information on each of these events in Annex A

(21) Annex 1 is referenced but not part of the document. Is the correct reference Annex A chapter 3?

(32) Further guidance would be needed how national plans are proposed to be implemented by national authorities. It has to be distinguished between a general prospective planning before an event happens and the planning for the later rehabilitation phase following an emergency situation. Annex B which addresses engagement of stakeholders in the course of existing exposure situations is found to be too little specific for practical guidance.

(38) Last sentence: “The Commission recommends giving particular attention to the equity in the distribution of exposure among the concerned group of individuals”. Question: should it read “groups”?

Figure 4: In this figure the applied reference levels are not indicated
(57) The contents of this paragraph raise questions about a proper relationship between the costs of implemented strategies and the costs per Person-Sv of avoided exposure. It is suggested to include a reference to the European handbook for inhabited areas.

(60) In paragraph 60, the third pillar is characterised as "The transmission of practical knowledge about the control of the radiological situation to future generations through the education system". In view of the following sentence "In this perspective, authorities will have to set up infrastructures to support the dissemination of a "practical radiological protection culture" within all segments of the population,...", this characterisation of the educational objective seems to be very limited. Pillar three might be extended with a sentence focusing on a broader education of the general aspects of the basics of radiation protection and its implication in the daily life.

(66) Concerning protective actions that would avoid re-concentration of radioactivity in local areas one example is given: “a particular attention will have to be paid to the management of radioactive house waste as for example ashes from fireplaces in rural areas” – The quality of this example is doubtful. Are there findings that long living radionuclides of the elements Cs and Sr remain in the ashes? It is suggested to choose more convincing examples.

Chapter 5. Radiation Monitoring and Health Surveillance

In chapter 5, monitoring and health surveillance are presented as the key elements for controlling and in this respect also reducing the dose burden to the population. However, with monitoring alone the time development of the contamination cannot be predicted. It is therefore necessary to apply in addition computational models to estimate the future contamination and dose burden to allow for proper optimisation decisions. This aspect of modelling in the frame of optimisation might be also discussed in chapter 6.

(74) “Following a radiological event, the exposed population should have an initial medical evaluation”: Further guidance is needed regarding the definition of “exposed population” otherwise practical problems are anticipated. Practical problems are also expected from past experience with respect to the requirement to supply “appropriate information regarding their level and potential type of risk”

Chapter 6. Management of Contaminated Foodstuffs and other Commodities

Chapter 6 focuses solely on food aspects. The external dose - not as important as food - still may be a non negligible contribution and this should be discussed at least in one additional paragraph. In particular the external dose cannot be fully controlled by the population (decontamination to 0 levels is not possible and as we assume that the existing exposure situation is resulting from an emergency, the external doses might be far above 1 mSv/yr in some areas) whereas food can be controlled and if necessary actions initiated.

(81) Last sentence: it is suggested that “people with poor health condition” are not included in the examples of most sensitive groups needing least contaminated food.

Annex A: It is suggested to include some information on all events which are mentioned in para 17.