Greenpeace Radiation Protection Advisors comments on ICRP draft publication:
“Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident”
General comments
Specific comments
ABSTRACT
Line 18-20: The need to base action on the precautionary principle should be emphasised. Radiation situations are not different from chemical situations in this respect.
Line 27-28: Key stakeholders should not only be involved in emergency and recovery management, but also in the preparation for emergencies.
MAIN POINTS
Line 41-43: Not only to mitigate the consequences during the emergency response but also during the recovery process.
Line 52–56: We urge the ICRP to establish time limits for the reduction of exposure levels (including intermediate levels) to accelerate reduction to 1 mSv/yr. In the current text, a reference level could be set at 10 mSv/yr without timeline for reduction, resulting in increased levels of exposure of a large population for a prolonged period of time.
The text “[…] progressive reduction in exposure to levels on the order of 1 mSv per year” should be changed to “[…] progressive reduction in exposure to levels of 1 mSv per year” to remove ambiguity.
EXECUTIVE SUMMARY
Line 91: The term reasonable should be further defined – it should, for instance, not include liability factors: liability needs to be factored in decisions that create the basis for emergencies – the operation of nuclear installations.
"Reasonable" infers what is reasonable from the point of view of the impacted population, not from the point of view of the source of the emergency.
Line 93: Measures should be implemented based on the precautionary principle, unless their implementation would cause in an evidenced way more societal, environmental and/or economic harm than when the measures are not taken.
Line 99: For the sake of priority perception: societal, environmental and economic
Line 107-111: The reference level for the general population should be set lower than 100 mSv , to prevent large population groups to be exposed to significant exposure levels. Setting such a high level for a large group of people can mean protective actions might not be applied on the basis of economic considerations, which is not acceptable.
Also the emergency situation should be defined as shorter terms (days or weeks and not up to one year).
Line 114-121: A time indication needs to be set for all reference levels, e.g. the exposure to levels between 1 and 20 mSv/yr should be not longer than X. This should rather be shorter term than longer (up to 1 year).
2.3. PRINCIPLES FOR PROTECTION OF THE PUBLIC AND THE ENVIRONMENT
Line 732: As stated in general comment 3, there is little uncertainty with respect to the stochastic risks at low doses. Therefore we recommend to reformulate this line to say “As radiological protection is based on scientific evidence indicating that the probability of stochastic effects is proportional to exposure”
3.4. PROTECTION OF THE PUBLIC AND THE ENVIRONMENT
Line 1283: ... before there is any significant release of or exposure to radioactive material.
Argumentation: This principle may not be abused as an argument not to evacuate when a release has taken place, but certain populations have not been exposed yet due to weather circumstances. In those cases, evacuation before exposure is preferential.
Line 1303: ... or permanently relocated.
Argumentation: permanent relocation of a part of the population (from the so-called closed zones) is a reality after Chernobyl and Fukushima. It is good to be prepared for the possible occurrence of permanent relocation for some victims.
Line 1329: Ad “The staff that remain”: Measures should be taken in advance to assure sufficient critical staff availability for those that cannot evacuate.
Line 1347: ... For longer emissions in time, administration may be necessary more than one time and with a slightly higher frequency than once every 24 hr.
Line 1350: But it is also beneficial for other population groups.
Argumentation: There are countries in which administration of iodine tablets is restricted to pregnant women or children, or where accessibility to iodine tablets for other groups remains difficult on the basis of the argument given now. Although pregnant women and children should have priority, also other potential risk groups should get extra attention for provision of iodine (think of people with problematic access to pharmacies, people in professional positions that do not allow them to leave their place, etc.), and availability for all others should be secured as well.
Given the increasing life expectancies, it cannot be upheld any longer that people of higher ages (above 40, 50 or 60) would not benefit from iodine provision.
Line 1360: Why is there no recommendation about decontamination of material during evacuation (think of cars and other vehicles, clothes and items taken)? These can carry hot particles outside of the evacuation zone and especially threaten their users (also after individual decontamination) with re-contamination, including internal exposure.
Decontamination recommendations should be given to all who are evacuated.
Line 1381: Because of the fact that milk is also an important pathway of ingestion of Cs-134, Cs-137 and Sr-90, long term observation of the radiological quality of milk is necessary.
Line 1392: temporary or even permanent relocation
Line 1396: ... Permanent relocation is planned removal of people for good from areas that are unrecoverable within a generation (more than 10 years).
Line 1411: ... In such cases, support for permanent relocation may become inevitably necessary.
Line 1430: ... at national level, and - especially in transboundary contamination situations - international levels…
Line 1442: ... International coordination of dose criteria is necessary to avoid confusion among the population of other countries (especially in near-border situations) and potential unsustainable exposure to contaminated foodstuffs due to differences in dietary patterns.
Example: The European Commission set initially higher dose rates for several foodstuffs from the Fukushima area as were valid for the same foodstuffs from the Chernobyl area, and which were higher than the dose rates valid in Japan and in the Codex Alimentarius. In the end the European Commission chose for similar dose rates as in Japan (the most stringent of the whole set). This lead in the mean time to large confusion within the EU.
Line 1456: ... Local monitoring initiatives should be supported, among other with professional independent expertise.
Line 1460: may not be in general a significant exposure pathway,
Line 1460: because it may be in specific circumstances, it will…
Line 1465: Decontamination of surfaces and soils is an important tool, but it has to be acknowledged that a comprehensive decontamination of complete ecosystems in larger areas is not possible and even in extensively decontaminated areas, there remain chances on extensive exposure from parts that could not be fully cleaned. Also recontamination from earlier decontaminated areas may take place (for example by run-off from not decontaminated mountain forest areas).
Line 1476: ... environmental, societal and economic…
Argumentation: even when not meant that way, the word order may imply priority. Economic impacts may never have priority over environmental and societal impacts. In the case of decontamination – because of the potential long-term effects, environmental arguments should have priority over societal, and these two over economic when determining whether and to what extent certain areas need to be decontaminated.
Line 1497: Apart from particular cases ... (which have to be determined with the utmost caution and with a restrictive interpretation and justification), ...
ANNEX A. CHERNOBYL
Line 2324-2336: (UNSCEAR, 2000) is used as a reference, which is almost 20 years old. We recommend to use more recent reports, such as the IAEA report in 2006 on Environment consequences of the Chernobyl accident and the UNSCEAR 2008 report on the Chernobyl accident. There are different views on the dynamics of radioactive releases.
Line 2380: Also residents outside of the 30km zone, in other highly contaminated areas that were evacuated in the subsequent period, were not officially notified of the occurrence of the Chernobyl accident.
Line 2497: These numbers are presented wrongly (the km2 numbers are total area over the three countries per range in Bq/km2 Cs-deposit) and outdated. The correct numbers as established in 1998 [Atlas of Caesium 137 deposition on Europe after the Chernobyl accident, M. De Cort 1998] are:
18,900 km2 with contamination of 185-555 kBq/m2
7,330 km2 with contamination of 555-1480 kBq/m2
3,620 km2 with contamination >1480 kBq/m2
Line 2524: Doses were also received by exposure to Sr-90 in regions around the exclusion zone in Belarus and Ukraine.
Line 2563: What is the reference to this statement?
Line 2666: Rather: the information only became gradually available over the course of several years.
Line 2695: Why only Belarus information is included here? In Ukraine in 1991-2000, the obligatory evacuation of population was conducted at a density of contamination by Cs134+137 higher than 555 kBq/m2 and voluntarily evacuation at a levels higher than 185 kBq/m2.
Line 2698: This is an error: voluntarily relocation was at the density of contamination higher than 185 kBq/m2 and dose higher than 1 mSv/year. There was no relocation at densities of contamination between 37-185 kBq/m2.
Line 2720: This only applies to Russia. In Ukraine this was from the levels >555 kBq/m2.
Line 2770 (A42): It is not clear why only the scientific centre in Gomel is mentioned here. A similar branch was also created in Kiev (Ukrainian Institute of Agricultural Radiology, http://uiar.org.ua/Eng/index.htm), as well as the National Research Centre for Radiation Medicine of National Academy of Medical Sciences of Ukraine (http://nrcrm.gov.ua/en/) and many others.
Line 2782, A.4.4: Why only the Russian federation is mentioned in this paragraph?
ANNEX B. FUKUSHIMA
Line 2913: Add the fact that the full reasons for the accident have yet to be concluded. (National Diet Japan commissioned report http://dl.ndl.go.jp/view/download/digidepo_3514606_po_NAIIC_report_hi_res4.pdf?contentNo=1&alternativeNo=)
Line 2973: The Act on Support for Victims of the Nuclear Accident was legislated in June 2012. It aimed to protect residents’ rights to stay or evacuate and return, and, for any case, appropriate support should be provided. However, in reality, the right to evacuate has been violated as for evacuees outside of the designated evacuation area there has been no support other than a small compensation for some residents in small areas for very short period of time. (MEXT http://www.mext.go.jp/component/a_menu/science/detail/__icsFiles/afieldfile/2013/12/16/1329116_006.pdf). Also housing support has ended in March 2019. (Fukushima prefecture https://www.pref.fukushima.lg.jp/uploaded/attachment/291575.pdf).
Line 3100-3117: Decontamination was not effective in many areas and given that more than 70 percent of Fukushima contaminated areas are mountainous forests, they cannot be decontaminated. (see Greenpeace report: Reflections in Fukushima: The Fukushima Daiichi Accident Seven Years On
https://storage.googleapis.com/planet4-canada-stateless/2018/06/RefFksm_EN.pdf)
Line 3119-3128: Decontamination workers are not protected. (see Greenpeace report: On the Frontline of the Fukushima Nuclear Accident: Workers and Children Radiation risks and human rights violations
https://storage.googleapis.com/planet4-japan-stateless/2019/03/b12d8f83-frontfksm_en.pdf)
Line 3129-3160: Residents were not provided necessary information such as lifetime exposure in case they return. (see Greenpeace report: No return to normal. House Case Studies of the Current Situation and Potential Lifetime Radiation Exposure in Iitate, Fukushima Prefecture
https://www.greenpeace.de/sites/www.greenpeace.de/files/publications/20170215_greenpeace_report_fukushima_noreturntonormal.pdf)
Line 3244-3263: Some children and women were exposed to high radiation and not protected by the measures by the Japanese government. (see Greenpeace report: Unequal Impact. Women’s & Children’s Human Rights Violations and the Fukushima Daiichi Nuclear Disaster
https://storage.googleapis.com/planet4-japan-stateless/2018/12/0df7c0c5-0df7c0c5-uequal-impact-en.pdf