„The present publication is intended to address some of the issues ICRP identified as essential lessons learned from the (Chernobyl and the Fukushima) accident, together with the lessons learned during the decade following these accidents. “The draft report is intended to update the publications 109 and 111 but there could be some more essence and concrete guidance to implement the lessons learned in the aftermath of the Chernobyl and Fukushima accidents into practical guidance for decision-making. The main findings of the radiological protection system remain unchanged.
A new aspect is the ICRP recommendation to clarify the use of the 1 mSv to 20 mSv band of reference levels for the protection of people living in long-term contaminated areas following the emergency by stating that the used reference level would not generally need to exceed 10 mSv per year. The argument used by ICRP is that “annual exposures of the order of 10 mSv during the first years of the recovery process, added to exposure received during the emergency response, could lead to total exposures greater than 100 mSv in a relatively short period of time for some affected people”. While such a situation cannot be excluded, the requirement of the strict application of reference levels/ as a mean of constraint optimization during the first year and the longer term after an emergency, which could be based on the existing reference level of 100 mSv for the public would be preferable to the introduction of another numerical value to the protection system.
During the last decade several international safety standards and safety guides have been published as international consensus documents, which address the issues discussed in the draft report in great detail. Some of them are listed as references in the draft report but key aspects of the safety requirements are missing in the draft document.
Examples are:
- “The objectives of radiological protection are achieved using the fundamental principles of justification of decisions and optimisation of protective actions. Implementation should take careful account of all hazards and implications, both radiological and non-radiological, in order to provide reasonable and sustainable living conditions for all those affected, including decent lifestyles and livelihoods.” Justification goes far beyond the objective of radiological protection. The Commission recommends involving key stakeholders in public consultation processes for the justification of decisions (whenever possible), including “necessary expertise in various areas such as evacuation logistics, transportation, medical care, community infrastructure, provision of necessary services, support for business interests, etc.”. The remaining question is how to balance between the numerical radiological protection criteria (reference level) and the variety of the wide spectrum of additional aspects and criteria, many of which cannot be quantified with sufficient accuracy. The preferable way to deal with this question is to develop a conceptual framework, which is based on the societal values and includes the input of the radiation protection system.
- The most important and manifest health effects of the nuclear accident in the short term appear to be on mental and social well-being. Generally, psychological consequences of the Chernobyl and especially Fukushima accidents are similar (despite the fact that doses were very different) and they may have overweighed the effects of the radioactive exposures. Requirement 16 of IAEA GSR Part 7 states: Non-radiological consequences … shall be taken into consideration in deciding on the protective actions … to be taken”. There is no discussion or guidance how to deal with this important lesson at the operational level. The statement “While difficult to balance radiological and non-radiological health effects against the benefits of protective actions, planning should attempt to do so to assist decision makers in selecting optimised protection strategies“ is true but there is little specific guidance how to deal with this situation. The available existing international guidance documents on dealing with mental and social well-being is not mentioned in detail. The repeated mentioning of stakeholder involvement seems not sufficient to be helpful to implement the requirement at operational level.
- The management of radioactive waste resulting from decontamination, clean-up activities has been and continues to be a complex issue, which may overwhelm existing arrangements and capabilities. Req. 15 of IAEA GSR Part 7 together with information provided by additional IAEA publications (GSR Part 5, SSR-5, GSG-1, WS-G-2.5, WS-G-2.6, WS-G-6.1) strongly recommends to assess the adequacy of existing waste management strategies to deal with waste following an emergency early on during planning as part of the protection strategy and to use the results of the analysis as planning basis to include waste management considerations as part of overall emergency arrangements. The recommendation of IAEA is to seriously consider waste generation when justifying and optimizing the protection strategy both that the preparedness stage and during later phases of emergency response. In some contrast to these recommendations the draft ICRP report only mentions the management of radioactive waste as one among several actions of planning and implementation of longer-term actions (section B.3. Intermediate phase)..
Transition to the “new normality”, e. g. from an emergency exposure situation to an existing or a planned exposure situation. Requirement 46 of IAEA GSR Part 3 addresses the arrangements to be in place, as part of overall emergency preparedness, and to be implemented as appropriate for the transition from an emergency exposure situation to an existing exposure situation. IAEA Safety Standards Series GSG-11 states: “At the preparedness stage, the time frames in which it is anticipated that an emergency will be terminated should be assessed for a range of postulated nuclear or radiological emergencies on the basis of a hazard assessment .... Experience suggests that a time frame in the range of several weeks to one year can be proposed for terminating a large scale emergency (e. g. an emergency at a nuclear installation resulting in significant off-site contamination)”. Overall, the statements made in the ICRP draft document remain somewhat unspecific, which could result in negligence of this important issue in planning during the preparedness stage with major consequences for the affected population and the society at large (experience from Fukushima).