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Submitted by PEDRO CARBONERAS, COMMITTEE 4
   Commenting as an individual
Document Emergencies
 
COMMENTS TO THE DRAFT REPORT (42/194/08) ON THE “APPLICATION OF THE COMMISSION’S RECOMMENDATIONS FOR THE PROTECTION OF PEOPLE IN EMERGENCY EXPOSURE SITUATIONS” (P. Carboneras; June/08)



GENERAL COMMENTS

• There are very many good ideas in the document which should be maintained, although there has to be a clear distinction as to whether they relate to the implementation of the RP system as described in ICRP-103, and/or they provide other potentially useful information for those responsible for emergency preparedness and response. The document should probably keep both of them, but it does not, at this point, present sufficiently clear these two types of guiding material.
• The information presented is not always sufficiently clear as related to the general scheme described. From my understanding of the text:
a) There are three phases in an emergency: early, intermediate and late (this last one moving into an “existing situation”).
b) The Commission will provide advise for the early phases (emergency situation) in this document and for the later ones (existing situations) in other ICRP document.
c) For the “emergency situations” (in this document), the Commission makes a clear distinction in between two steps: “planning” for the response and “implementing” such response.
The text in the document does not always reflect properly this scheme. In fact many of the paragraphs in chapter 2 (planning) are also valid for chapter 3 (implementation). Conversely, many times the document use the word “planned” or “planning” in a very ambiguous manner, as related to the scheme above. For instance in many paragraphs of Chapter 1, what is said should be valid for both “planning” and “implementation”, although the texts refer only to “planning” (see paragraphs 19;20; 23; 25; 26; 28; 30).
• I fully agree with the need to involve relevant stakeholders in both steps (planning and implementation) of the emergency response although in a different manner (as recognised in the text); however the document unduly goes much further on the identification of such groups (see among other the paragraphs 53, 111, 125, etc.), which in my opinion is not the role of ICRP.
• The RP system described in ICRP-103 is basically an “evolution” of the previous one. But in the case of “emergency” and “existing” exposure situations, it is a little bit more than just and “evolution” and introduces a significant change to the previous advice, which (no doubts) will be difficult to implement in practice. In this context I find the document unsufficiently clear in two basic issues:
a) How to optimize the “whole response” considering the application of individual protective measures.
b) How to decide the termination of protective measures considering (one again) the optimization of the whole response.
I would like the TG to devote additional efforts to clarify these points, even with the use of specific examples in an Annex.
• The three Annexes should probably be retained, but they should be properly presented. In my opinion:
- Annex A is just one example to illustrate the use of one single (but very relevant) factor during the planning step: the assessed dose (see also paragraphs 78 and 79).
- Annexes B and C contain useful descriptive information for emergency preparedness, but very little guidance for the application of the RP system as recommended in ICRP-103. On the other hand, Annex C contains many repetitions.
• I share the view of the NEA-EGIR, that the document should be made more practical for the users (more “active” and less “descriptive”). At least the “active” and the “descriptive” parts should be clearly presented separately.
• I also share the view of the NEA-EGIR in two other aspects:
a) The need to be very precise when talking about “workers” involved in the emergency response, considering the existing ICRP doctrine in this field.
b) The difficulties to properly comment on Section 4 without having available the other ICRP document being prepared.
• Much of the material given in Chapter 1 is applicable for both steps (planning and implementations). Similarly much of the advice offered in Chapter 2 for the “planning” step could also be valid for Chapter 3.

SPECIFIC COMMENTS (Not comprehensive and considering those already provided by the NEA- EGIR).
• Preface.
The NEA should be mentioned when talking about other developments taken into account by the TG.
• Executive summary.
It should be extensively review once the full document has been revised taking into consideration the comments received in this consultation period.

• Introduction.
- Para. 1 – Sixth line
“… new recommendations contain significant variations with important implications…”
- Para 1. – One but the last line
When talking about the “medical field”, it should had been said “medical exposures”, because there may be emergency situations in the medical field well within the scope of this document.
- Para 3 – Delete the first sentence because it’s not needed and may introduce confusion.
- Para. 6 – I wonder whether this paragraph is useful at all for this document. If maintained it should be properly balanced.
- Para. 7 – Eight line
“… in order to facilitate their use by the different responsible agents involved as well as their acceptance by the public…”
- Para. 8 – Second line
“… both stable and acceptable although it could be improved. They may be…”
- Para. 11 – The pre-emergency phase is not a phase of the emergency. See my second general comment to clarify this subchapter 1.3.2.
- Para. 16 – Fourth line
- Delete the reference to the NORM industries. They are not equally regulated around the world so far (not even sufficiently international guidance exist for that). On the other hand they can hardly produce significant radiological emergencies.
- Para. 16 – Ninth line
- The key issues to plan for emergencies are twofold: 1)the likelihood of the accident; and 2)the magnitude of the potential radiological impact
- Subchapter 1.3.5
- Besides the definition of the different “dose concepts” to be used, there is also information related to their use, which introduces confusion.
- The text talks about “residual dose” and “total residual dose”. Are these two concepts different? I hope not.
- Para. 30 – Last line (reference to 2.1.5.)
And what about the use of ILs in the “implementation” step?
- Para 31 – Last two lines (reference to 2.1.2.)
And what about the protection against severe deterministic injuries in the “implementation” step?
- Para 36 – Last line (reference to 2.4.4)
And what about the protection of workers in the “implementation” step?
- Para 37 and 38
The use of figure 3a in two different senses introduces complexity.
- Para 49 – Last three lines
There are many “planning” activities which can be taken even for potential malicious acts!
- Subchapter 2.1.5.
The applicable range (20 – 100 mSv/y) is not mentioned!
- Fig. 4 - Unless presented coulored, this figure is very difficult to be used.
- Para 82 – Last two sentences
Perhaps better placed in subchapter 2.3.3.
- Subchapter 2.4.
There are many parts of the text really applicable only in the “implementation” step, while Chapter 2 is related to the “planning” step. See my second general comment.
- Para. 128
- Partially repeated in para. 122.
- What is really important here is to mention the need to have prepared (in the “planning” step), with the participation of relevant stakeholders, methods and tools to help in the decision taken process during the implementation besides the early phases.
- Para. 129 – One but last sentence
- Delete the sentence related to the financial support for stakeholder participation. This is not for ICRP.

- Para. 130 – Last line
“… later phases of the emergency plans, as well as to review existing planning provisions”.
- Para. 133.
- It could be deleted here.
- Para. 138 – Last line
- Add the idea of potentially continue to improve the radiological situation if feasible.
- Final note
- I don’t quite share the specific views and comments provided by the NEA-EGIR related to the following paragraphs:
 7.- For the early phase the need for “triggers” is basic. However, for the later phases, what is really needed in the planning step is to have reached (with all the other agents involved, including stakeholders) sufficient agreements on methods and procedures to take further decisions.
 12 to 15 – The whole subchapter 1.3.2 needs to be revisited as indicated in my previous comments.
 31; 34; and 44 – The use of a “risk-based approach” for planning the response in case of emergency situations is questionable in my opinion and if introduced, will need a lot of debate to find the appropriate wording. I would rather prefer a more loose text, as it is now.
 71 and 72 – These two paragraphs could be of value as general guidance for emergency preparedness, although not necessarily within the ICRP scope.