Submitted by Christopher Mogg, OECD-NEA Commenting on behalf of the organisation
The report has been reviewed by a sub-group of the CRPPH-EGIR. The sub-group welcomes the report and acknowledges the efforts of ICRP. The report is well structured, takes account of both present and future risks related to the near-surface disposal of radioactive waste, and there is clear evidence of a strong ethical basis to the recommendations in the report. A particularly positive aspect of the report is that it contains a number of examples to illustrate the principles and concepts. This helps to clarify matters but also to avoid problems of interpretation.
During this round of consultation, members of the EGIR sub-group were invited to feed in comments on the final report through the NEA - comments put forward by the NEA in pre-consultation have been well considered and on this final version, comments were received from one member as follows:
Para 124 begins, “(124) It is necessary to distinguish between deliberate and inadvertent human intrusion into the facility. The former is not discussed further in this report as it is considered to be out of the scope of the responsibility of the current generation to protect a deliberate intruder (i.e. a person who is aware of the nature of the facility) because by its nature a deliberate intruder has bypassed any relevant controls that are in place.” ... One can readily agree that one cannot, or need not aim to protect the deliberate intruder. The issue is protection of third parties (other people) who are not deliberate intruders being harmed by the activities of the deliberate intruder. For example, some aspects of design might mitigate third party impacts due to deliberate intruders. What is the ICRP ethical basis for ignoring the possible impacts on third parties?
There are several references to the strategy to contain and isolate the waste to avoid significant exposures. The text around those references is very useful but I don’t see any explanation of what counts as significant. I would not ask for a quantitative definition, such as “doses below 100 mSv are not significant”, although some might expect that since they are defined as low doses by ICRP. But something could be usefully said to the effect that Significance can be determined based on consideration of the exposure circumstances, the scope for control of doses and other risks that may be present; see discussion of setting of/application of constraints and reference levels. Just a suggestion.
There are quite a few references to short-lived radionuclides. The second reference helpfully adds that for purposes of waste disposal they are generally considered to be radionuclides with less than a 30-year half-life. Firstly, this would be even more helpful after the first reference, but also be clear that this is how ICRP have used the term in this report. It is interesting that ICRP’s value for Sr-90 is 28.79 years (< 30) and for Cs-137 it is 30.1671 years. This makes ICRP’s 30 year division problematic. A lot of LLW is activity dominated by these two nuclides and would be best managed, but then is it short-lived or long-lived? It might be helpful to say short-lived means of half-life shorter than that of Cs-137, approximately 30 years."