Comments (1-5):
Also found in the title is the term, “Large Nuclear Accident”. A “large nuclear accident” is not in the glossary, so it is unclear what this refers to. Within the glossary, “emergency exposure situation” is defined and includes “intentional misuse of a source”. Intentional misuse is not an accident. Is the meaning of “source” confined to nuclear power plants? Is the document addressing large radiological emergencies that are not nuclear (i.e., involving nuclear fission) accidents? Does it apply to radiological explosive devices?
The Executive Summary, paragraph (b), acknowledges that the recommendations may be applicable to other events, yet still vague.
The subtitle states that the document updates ICRP 109 & 111. The titles to those documents are broader using terms such as “emergency exposure situations” and “….after a Nuclear Accident or a Radiation Emergency”.
Please consider adding a recommendation that long term planning incorporate the impacts and vulnerabilities associated with climate change. These impacts can include stronger storm surges, higher sea levels, heating of cooling water, agricultural and demographic shifts, etc. (See International Panel on Climate Change AR-5 2014 Report, “Impacts, Adaptation and Vulnerabilities”, https://www.ipcc.ch/report/ar5/wg2/).
Planners should identify trends in their locations and incorporate into long term planning.
Section 5 includes this statement, “Although it is difficult to ask the population to be prepared in advance for the occurrence of a nuclear accident, the Commission recommends that key representative stakeholders should participate in emergency and recovery preparedness. “
Please consider adding a statement(s), which suggests that the consequences described in 2.2.3-2.2.6, may be reduced with increased efforts to educate and mentally prepare the general population. Planners should weigh the value of these efforts. (Assuming 2.2.4-2.2.6 remains in the text, see my previous comment)
The reasons given for replacing existing Draft text with the commenters’ suggested graph/text (Baker et al.) are not justified. No evidence is provided that regulatory bodies “often misinterpret” reference levels as dose limits. Some regulatory bodies may correctly understand that reference levels are recommendations and choose to apply them as dose limits.
The Draft contains an abundance of direction that reference levels are recommendations and should be employed based on the totality of the circumstances. A few Draft examples here (underlining by this commenter, not in Draft):
Line 44 “For protection of responders and the population during the emergency response, the reference level should not generally exceed 100 mSv, while recognizing that higher values may be necessary to save lives and for the prevention of catastrophic conditions.
Line 51 “Levels should be within or below the Commission’s recommended 1–20-mSv band taking into account the actual distribution of doses in the population and the tolerability of risk for the long-lasting existing exposure situation and would not generally need to exceed 10 mSv per year.
Line 107 “For protection of responders and the population during the emergency response, the reference level should not generally exceed 100 mSv, while recognizing that higher levels may be necessary in exceptional circumstances to save lives and prevent further degradation of the facility leading to catastrophic conditions. The initial reference levels may be applicable for a short period and should not generally exceed 1 year. Lower reference levels may be selected based on the situation in accordance with the gravity of the accident.
The text that is suggested by the commenters is in conflict with this Draft and other ICRP documents (as well as recommendations made by many other expert bodies). The commenters would like the ICRP to utilize a graph which shows a Linear Dose Relationship which flattens at about 0.1 Gray and text which states, in part, “…a plethora of scientific data suggest that exposures below the red area can have both beneficial and negative health effects, the ratio of which determines the net-outcome of detriment. These data should be available to affected people to help them make their own decisions with respect to radiation protection and should be considered when responding to specific radiological release situations in which numerical guidance may be exceeded.”
This seems to be an attempt to guilefully contradict Draft paragraph 2.2.1.2 (the implied theory of LNT in particular).
Fellman is more blunt, “It's time to base evacuation procedures on science rather than on Linear Non-Threshold extrapolated nonsense.”
Fellman and some of the co-authors of the Baker et al. comment are listed as members of a group with the stated Mission (from their website, I will not publicize it here):
"To help prevent unnecessary, radiation-phobia-related deaths, morbidity, and injuries associated with distrust of radio-medical diagnostics/therapies and from nuclear/radiological emergencies through countering phobia-promoting misinformation (such as the LNT) spread by alarmists via the news and other media including journal publications. (2/12/2016)"
4. Yamada and Nadesan Comments
Both commenters take issue with the numerical values of some of the recommendations. However, they provide no sound basis to support their claims. For example, Yamada states that, “As the scientific fact that humans cannot coexist with radiation exposure.” Yet, humans have done so over our evolutionary history.
The Draft recommendations are not “limits” and there is significant language to inform the reader that dose reduction is always a goal (ie, Table 6.1 for long term public exposure, “The long-term goal is to reduce exposures to the order of 1mSv per year”, or the use of “less than or equal to” signs before the recommendation limit). So the commenter’s concern is essentially addressed.
Nadesan objects to the emergency recommendation upper limit of 100 mSv for pregnant women and children. Again, the recommendation is proceeded by “less than or equal to” signs. The recommendation only applies in emergencies exposure situations, which the Draft defines as “….requires urgent and timely actions in order to avoid or mitigate exposure. “
The commenter claims that this upper level would be “catastrophic”.
However, the Draft recognizes the radio-sensitivity of pregnant women and children in several places, (see Lines 675 and 1050, for example.). The commenter provides no evidence that the risks are “catastrophic” and the Draft’s risk estimate of 0.5% to 25% increase in fatal cancer risk from 100 mSv is sound.
5. Beyond Nuclear and Related Comments
Comments which seem to imply that radioactivity is more lethal than demonstrated by the known evidence. No new evidence is offered in support of the comments.
From their website, Beyond Nuclear advocates for the abandonment of nuclear weapons as well as nuclear power. Some of their supporters seem to have commented as well. The fallacy of Argumentum ad Populum.