Comments on the Draft “2005 Recommendations of the International Commission on Radiological Protection.” From: Kay Drey, 515 West Point Avenue, St. Louis MO 63130. Member of the Board of Directors, Nuclear Information & Resource Service. Submitted on December 31, 2004, by e-mail to Jack.Valentin@ssi.se Secretariat, ICRP These comments are being submitted to the International Commission on Radiological Protection with the hope that any changes you ultimately make to your radiation standards will make the standards more protective of nuclear workers, members of the public, other living creatures, and the environment. Not less. Every exposure to ionizing radiation increases a person’s risk of damage to tissues, cells, DNA and other vital molecules, potentially causing programmed cell death (apoptosis), genetic mutations, cancers, leukemias, birth defects, reduced reproductive success, and immune, cardiovascular, and endocrine system disorders. Or, as summarized in the Draft ICRP Recommendations, the potential harmful effects of radiation can impact “at the molecular, cellular, tissue and organ, and whole organism level.” (Paragraph B28) For this reason, the fundamental aim of the ICRP should be to reduce, not condone, the generation, transfer and dispersal of manmade radioactive materials into the biosphere, and thus should reduce the potential radiation exposure of the human species and other living organisms currently and into the future. Having read documents by and about the ICRP for thirty years, I feel especially pleased to have the opportunity to submit comments to you about proposed changes to your radiation standards. I made my first public speech about nuclear power --- against nuclear power --- in November 1974, and have been studying about its known and unknown hazards ever since. The primary reason I oppose nuclear power is because I believe workers at nuclear power plants are allowed to be exposed to levels of radiation that I feel are dangerous. The second reason is that nuclear power plant operators are allowed to discharge radioactive liquid, gaseous and particulate wastes into the environment as a part of the routine operation of the plant, not just as the result of an accident. The routine releases --- both those that are detected and measured, and those that are not --- increase the risks to living creatures on our finite planet. I also fear that no safe, permanent location may ever be found for radioactive wastes; some will remain hazardous virtually forever. I worry about human error in the design, construction and operation of nuclear power plants and of facilities used throughout the uranium fuel cycle. I believe nuclear power plants should be shut down until --- if ever --- a solution is found for the wastes already generated. For many years I have read about the ALARA principle, about protecting workers to the extent that is “as low as reasonably achievable, social and economical considerations being taken into account.” While I have understood the economics of limiting the amount of protection provided to workers, I have felt that, at the least, every worker should be informed that his permissible dose is determined not just by concerns for his health and survival, but by concerns for his employer’s economic health and survival, as well. While reading the Draft 2005 Recommendations, I was reminded of the first time I read about the ICRP’s rationale for justifying why its numerical dose values for a nuclear worker were allowed to be so much greater than for a member of the public. In his article entitled, “The Nuclear Energy Game: Genetic Roulette,” in The Progressive, January 1976, H.W. Ibser, Ph.D., now Emeritus Professor of Physics, California State University – Sacramento, had included the following quote from a 1959 ICRP report: “Genetic effects manifest themselves in the descendants of exposed individuals. The injury, when it appears, may be of any degree of severity from inconspicuous to lethal. A slight injury will tend to occur in the descendants for many generations, whereas a severe injury will be eliminated rapidly through the early death of the individual carrying the defective gene. Thus the sum total of the effect caused by a defective gene until it is eliminated may be considered to be roughly the same. The main consideration in the control of genetic damage (apart from aspects of individual misfortune) is the burden to society in future generations imposed by an increase in the proportion of individuals with deleterious mutations. From this point of view it is immaterial in the long run whether the defective genes are introduced into the general pool by a few individuals who have received large doses of radiation, or by many individuals in whom smaller doses have produced correspondingly fewer mutations.” (“Recommendations of the ICRP -- Report of Committee II on Permissible Dose for Internal Radiation,” Para.8.) After tracking down the original report, I had found the following concluding sentence to that paragraph 8: “However, even in this case it is desirable to limit the dose received by an individual.” I found the report and its recommendations to be surprising and disturbing. I appreciate the ICRP’s acknowledgment throughout the Draft 2005 Recommendations that many uncertainties and limitations of current knowledge remain --- for example, the lack of sufficiently precise epidemiological data needed for certain decisions, or the fact that “many parameters can only be considered as rough estimates” of radiation risk. (Paragraphs 63, 64) “There are very few investigations on animals that give information on the RBE [Relative Biological Effectiveness] for high energy protons.” (Para.75) “There are a number of epidemiological studies that provide information on the risk for inhaled or intravenously injected alpha emitters. The distribution of radionuclides and the dosimetry in the body and also the estimation of dose distributions in tissues and organs are very complex and are strongly based on the models used. The estimated doses are, therefore, associated with large uncertainties. For this reason most epidemiological studies cannot be used as the sole basis for an assessment of the RBE for alpha emitters.” (Para.76) How, then, has the ICRP decided to continue recommending a radiation weighting factor of twenty for alpha emitters, or twenty times greater than photons and electrons? The US Nuclear Regulatory Commission uses the same relative effectiveness of alpha as compared to gamma and beta radiation in 10 CFR 20, Table 1004(b). Is twenty an arbitrary quality factor? Was it chosen merely for practical reasons? Should the radiation weighting factor be lower or, more likely, higher? To quote from the abstract of a Health Physics paper by Russell J. DuFrain, et al.: “The maximum theoretical value for the RBE for cytogenetic damage from alpha irradiation was determined to be 278 at 0.1 rad or less which is in marked contrast to previously reported RBE values of approx. 20.” (Vol. 378, Sept. 1979.). And what have recent studies indicated about the induction of chromosome aberrations in human lymphocytes by alpha radiation, as reported by A. A. Edwards, et al., in the Intl. Journal of Radiation Biology (Vol. 38, 1980)? Because of acknowledged gaps in knowledge about the relative radiotoxicity and biological effectiveness of a range of manmade and natural radioactive materials, would it not be beneficial if the ICRP were to commission epidemiological studies of nuclear power plant workers and their children --- for example, of Shippingport and Dresden workers where the reactors began operating more than forty years ago? Without such data, how are your proposals for radiological protection to be considered reliable --- and safe? If it is found that the operation of nuclear power plants and other human actions and lifestyles result in inhumane doses for workers, the generation of permanently hazardous wastes and their planned and accidental discharges into the environment, and the risk of catastrophic accidents, then I believe the ICRP should no longer seek to justify those actions by crafting “appropriate” radiation standards. I believe the industrial workers of the world, as well as governmental officials and members of the international public would welcome the accumulation and assessment of hard data on the radiotoxicity of the current acute and chronic, permissible exposure and release standards . As I read recently: no risk is acceptable if it is avoidable. I believe that nuclear power can and must be replaced by energy sources that are safe now and will not leave a lethal legacy. I believe the leadership of the International Commission on Radiological Protection is essential if this goal is to be achieved. Sincerely, Kay Drey tritium3@sbcglobal.net