ICRP Consultation - Protection of the Environment under Different Exposure Situations
While it is accepted that man should consider the impact of his operations on the environment, it is difficult to see how these recommendations are to be applied within the current scheme.
The UK already carries out environmental impact assessments for their environmental permitting regime, considering pathways and accumulation within the environment, and assessing impact on potential foodstuffs and crops. These are carried out under EU directives such as the Habitat Directive. Is it really necessary to go beyond the current arrangements, for what is perceived as no particular gain?
The document refers to sources and then goes on to refer to medical equipment as well as radioactive sources. This implies that we should be considering radiation doses from radiation generators as well as radioactive materials, i.e. linear accelerators, gamma radiography sources, waste tanks, pipelines. This is not currently considered and cost benefit would be difficult to justify.
If the chemical industry uses “severe effect levels”, why are we not doing the same? The suggested Derived Consideration Reference Levels are significantly below the SELs.
In line 569, the document states that Commission does not recommend any generally applied form of dose limitation for biota, but here DCRLs are being introduced and these are effectively a dose limitation, albeit in bands.
The recommendations appear to be based on limited scientific evidence. It is felt that ICRP should identify where further research is required on the effect of radiation exposure to the ecosystem before recommending environmental protection measures.
The document also needs to consider the situations where it might apply. It is difficult to envisage where doses of the magnitude suggested would be likely during a planned exposure, unless by deliberate irradiation, via a radiation generator or in an area such as reactor cooling ponds.
It is recommended that the Environmental Reference Levels (ERLs) be given a different abbreviation. The abbreviation ERLs is normally used for Emergency Reference Levels in the UK.
Appendix 4 references basic population characteristics of plants and animals, but omits to indicate over what volume or area.
SRP Legislation and Standards Topic Group
10th October 2012