|Nuclear Information and Resource Service
3rd comment submission on Draft ICRP 2005
RE: Exemption and Exclusion
ICRP 2005 in both charts and text recommends an exemption and an exclusion level of 10 microSieverts (1 millirem)/ year as a dose that is acceptable to the public from exempted and excluded sources and practices. Essentially, ICRP is choosing an unverifiable, unenforceable level that will allow the radiation establishment to wash its hands of responsibility for nuclear wastes produced by practices it promotes and facilitates internationally and in each nation. Both the concept and the level are unacceptable and will be used by nations to justify relaxing waste requirements on nuclear industries. This could be the straw that breaks the remaining credibility the ICRP has in the world.
Since 1986 the public (especially in the United States where there was more awareness of this assumption being made by the radiation establishment, but increasingly internationally) has indicated that the 1 millirem (10 microSievert)/year level is not an acceptable level of exposure, dose, or risk. In fact, conceptually, there is no level below which radiation is safe or safe “enough.” The responsible radiation principle is to minimize unnecessary exposures. Thus for those anthropogenic radioactive materials (generated as a result of human nuclear industries especially nuclear power and weapons) the goal should be to capture and isolate all of the wastes, not deliberately disperse them into the public space.
Thus, despite the claims by members of in the inner circle of the nuclear establishment promoting nuclear technologies that a 10 microSievert or 1 millrem annual dose is considered “trivial” or acceptable…the truth is that it is only trivial or acceptable to those who are creating the wastes and responsible for the cost of its isolation. The human beings that will be exposed and are aware of the whole exemption/exclusion/release/
clearance/below regulatory concern/ or other name for the concept out rightly oppose it. They/we do not consider it trivial or acceptable, physically or ethically. The uncertainties about doses to be received, numbers of sources, effects at those levels, synergistic effects, and more make it a totally irresponsible and untenable practice. Yet ICRP knows its recommendation will provide support for across the board deregulation of radioactive materials. ICRP is aware that its recommendations are used to create policies, regulations and laws in the nuclear nations of the world. We recommend that ICRP cease the development of this concept and remove it completely from the 2005 ICRP recommendations. It is a major step backward from ICRP's 1990 conclusion that the amount of natural radiation we receive "provides no justification for reducing the attention paid to smaller, but more readily controlled, exposures to artificial sources." Instead of deregulation, the many technologically produced radiation sources now in the environment need to be brought under control.
The research provided on ionizing radiation health effects indicates a need for greater limitation of low level exposures, which in fact turn out to be high level exposures to some cells in the body where the radioactive materials concentrate. ICRP provides no technical basis for its promotion of exemption--letting go of already-controlled and regulated nuclear materials and expansion of the previous concept of exclusion (which applied to unregulated radioactive materials). All that is provided are misinformed, unacceptable rationalizations based on nuclear industry concerns about costs and efforts required to long-term manage the wastes from its facilities.
ICRP 2005 provides no realistic estimate or limit on the number of exclusions and exemptions. There is no verification or enforcement.
ICRP 2005 ignores studies on radiation damage such as the Bystander Effect (cells in the area but not directly hit by radiation show injury) and Genomic Instability, claiming a lack of enough knowledge to reflect risk estimates.
We call on ICRP to incorporate increased risks identified by other scientists and panels in its radiation risk estimates and to adopt the precautionary principle of preventing potentially harmful exposures.
By "excluding" and "exempting" low-level radioactive materials and wastes from control, ICRP is supporting deregulation of radioactive wastes generated by nuclear power, weapons, and other atomic activities.
The ICRP support for exemptions and exclusions violates repeated public opposition to deregulating nuclear materials and wastes despite ICRP’s claims of intending to involve “stakeholders.” ICRP perpetuates the incorrect assumption that we will accept “trivial” risks from release of previously regulated manmade nuclear material. We call on ICRP to require that all man-made (“artificial”) radioactivity be regulated at all levels…not “excluded” or “exempted” from controls.