Radiological Protection of the Environment/Non-Human Species
An Industry Perspective
R. Coatesa, S. Saint-Pierrea‡, RPWGb
aWorld Nuclear Association (WNA), London, United Kingdom
bWNA, Radiological Protection Working Group‡, London, United Kingdom
Abstract - Following last October's IAEA-sponsored international conference in Stockholm on the protection of non-human species, WNA developed some key messages with regard to international developments on this challenging topic. Because we intend that these key messages be consistent with the overall perception of leading individuals and institutions in this process, we would appreciate their review of these key messages and any comments that may result from that review. This paper presents these key messages. We see great merit in the IAEA/ICRP initiatives seeking to incorporate regular stakeholder input in the development of the future system of radiological protection for non-human species. Similarly, we see clear benefits from the development of a joint IAEA/UNSCEAR/ICRP "road map" that would provide clear direction and co-ordination of activities as the process moves forward. As this occurs, WNA will continue to participate actively in the international debate in general and specifically in discussion within the technical community. Our aim is to ensure that nuclear industry expertise and data contribute constructively to future developments. Finally, for reference, this paper also presents (in Appendix A) the WNA comments that were provided to the ICRP at the end of 2002 on ICRP's first consultation document relative to the protection of non-human species.
WNA Key Messages on Radiological Protection of the Environment/Non-Human Species
1. There is wide agreement that the current system of radiological protection has in practice provided appropriate standards of environmental protection, but also wide acknowledgement that the system needs to be further developed for completeness in order to fill a conceptual gap (i.e., exposure of non-human species where human exposure is not the predominant concern) and to address some specific outstanding situations.
An effective practical solution that fills the conceptual gap and that can be scaled to address specific outstanding situations should:
- Realistically characterize the environmental risk posed by a specific set of practices;
- Be sufficiently flexible to fit a wide range of situations and be commensurate with any potential risk so as to ensure that resource expenditures are in reasonable balance with benefits; and
- Improve clarity and transparency regarding how and to what extent the environment is being protected.
2. The IAEA, ICRP and UNSCEAR have an important leadership role in ensuring a clear direction for future work and the co-ordination of activities to develop and implement a sound international framework for environmental radiological protection. In exercising this leadership, the three organisations should collaborate on a joint "road map" that:
- Describes a shared vision, clear objectives and a path forward for developing and implementing a framework;
- Specifies how stakeholders can participate in development and implementation of the framework; and
- Delineates a sequence of activities, milestones, timeframes and responsibilities for achieving the objectives – with progress reported regularly and transparently to the stakeholders.
The WNA will continue to contribute actively to the international debate and to a discussion by the scientific community, with aim of ensuring that nuclear industry expertise and data contribute constructively to future developments.
3. The system of environmental protection must be shaped in an overall context in which the producers of nuclear power as a clean, beneficial source of energy act as stewards of environmental protection in conformity with stringent environmental standards. As a practical reality, this stewardship is currently working well:
- The radiological impact of many nuclear sites, and power plants in particular, is often difficult to distinguish from background levels of radiation;
- There is no evidence that radioactive discharges from nuclear sites, controlled to levels consistent with ICRP criteria for the protection of humans, have had any discernible effect on potentially affected ecosystems; and
- Even for sites with the most significant historical discharges, currently available biota dose assessment methodologies indicate that dose rates are significantly below levels at which any effects would be expected.
4. Several additional points concerning current practice by the global nuclear industry bear emphasis:
- The nuclear industry uses:
- Extensive pollution controls based on the ALARA ("as low as reasonably achievable") principle;
- Sophisticated monitoring systems to ensure that radioactive discharges are kept well below authorized limits and that nuclear facilities are functioning normally; and
- Industry-standard environmental monitoring programmes to detect and analyse any potential anomalies or trends in radiological levels in surrounding air, land and water,
- The incremental environmental concentrations of radionuclides already accounted for in the controlled release of radioactive discharges from nuclear facilities are well below the concentration levels at which any effect would be expected on non-human species.
- There are no indications from the recent IAEA Stockholm international conference or earlier international events that IAEA and UNSCEAR current international guidance values for the protection of non-human species (i.e., 1 and 10 mGy/day) would not be appropriate. Experience to date shows that situations with exposure to non-human species that would approach these guidance values are extremely rare, and evidence of observable harm in these rare cases has not been demonstrated.
- There is no evidence to undercut the long-standing premise that protecting the environment as a whole can best be achieved through a system of radiological protection centred on humans. Therefore, new complementary provisions directed at protecting non-human species should not focus on routine discharges into the general environment but rather on specific outstanding situations involving significant discharges into the environment in particular local settings that tend to favour the accumulation of radionuclides. In such situations, it is quite likely that a screening demonstration of a "finer" level of protection would be sufficient, without need for extra monitoring or for extra provisions explicitly aimed at protecting non-human species by controlling radioactive discharges.
5. Any future system of protection that fills the "conceptual gap" should:
- Be based on a scientific framework that assesses natural and man-made radioactivity on a common basis;
- Be capable of simple and practical application;
- Not impose a disproportionate burden on the beneficial uses of nuclear technology, including the availability of nuclear energy, and not require blanket application across sites with evident negligible environmental impact; and
- Be focused instead on specific outstanding situations with the aim of protecting species, populations and ecosystems.
APPENDIX A - WNA comments that were provided to the ICRP at the end of 2002
on ICRP's first consultation document relative to the protection of non-human species
Introduction
The WNA believes that ICRP are to be congratulated for recognising the importance at this time of further developing the radiological protection framework towards the inclusion of non-human species, and indeed for producing an authoritative and broad review of this topic. We believe that it is of the highest importance for ICRP to be leading the international debate in this field, and that this should serve to focus the debate around a comprehensive and coherent framework within which both the underpinning science and, if necessary, any subsequent regulatory approaches can be developed.
In particular we acknowledge the need to address what ICRP calls a "gap" in the ICRP 60 philosophy and to ensure that the developing radiological protection approach to the environment is broadly aligned with environmental protection philosophy as it has developed in relation to other potential detriments such as chemicals.
Our comments on the Consultation Document fall into five key areas as discussed below.
Is there currently environmental harm?
On reading the Consultation Document we were struck by the lack of discussion on the current state of the environment, and in particular on the substantial evidence of lack of environmental harm arising from practices which are subject to the current control framework advocated by ICRP. In effect this links to the assertion in ICRP 60 that protecting man will ensure that other species will not be put at risk. We therefore think that it is important for the document to state more clearly that the current emphasis and work is driven primarily by the need to ensure a fully comprehensive framework, philosophy and underpinning science - i.e. it is not driven by any need to address any current real harm to non-human species in the environment.
On this basis it is essential to ensure that any developing philosophical and scientific framework, and as a possible consequence any regulatory framework which might follow, is based on a proportionate response to the level of expected harm.
Balancing benefits and detriments
The Consultation Document as currently structured discusses at considerable length the concepts of harm and detriment, and how these can be addressed. The document is surprisingly light on recognising the need to ensure that the benefits to society, which accrue from the use of radiation and radioactive materials are a vital ingredient in the development of any framework. In essence, we consider that the fundamental ICRP principle of justification, together with optimisation, has not been given the necessary prominence. All alternative sources of energy production give rise to environmental detriments of different kinds, and indeed the lack of energy would give the greatest dis-benefit to society. The fundamental issue is not therefore how to avoid environmental harm, but how to balance and optimise the totality of benefits and detriments.
Focus on non-human species
The WNA fully supports the report's conclusion that the protection framework should be focused on non-human species as a complement to the existing framework centred on humans. Ethical issues relating to the 'protection' of the abiotic environment are essentially matters beyond science, which need to be addressed at a political level by authorities and stakeholders. ICRP must focus on the development of a structured, scientific framework for considering the impact of ionising radiation on living organisms.
Emphasis on effects at population and ecosystem level
We believe that the proposed approach of minimising radiation effects such that there is negligible impact at the population and ecosystem level is the correct focus for the developing framework. This would align with wider environmental approaches at the level of a general framework.
In this context we note that scientific data on effects is available mainly at the level of individuals, although some work is available to extrapolate from such effects to potential impacts at the population and ecosystem level. However, there is a clear need to focus our science and understanding so that effects at an individual level can be better interpreted in the context of the primary objective of protecting non-human species at the population and ecosystem level. The development of the ICRP philosophy can be a great assistance in helping to focus future scientific work in this field.
Beyond the protection of populations and ecosystems, we recognise that approaches to conservation do in practice in many cases address issues at the level of individual organisms. However, these are special cases, which need to be addressed on a case-by-case basis, and are entirely inappropriate for the basis of a general framework.
As an example of the difficulties which would arise if a general approach were to be based on the protection of individual organisms, it would indeed be invidious if the construction of a facility or hospital, which inevitably would lead to considerable local non-human impact at the level of individual organisms, could proceed whilst the subsequent operation of the facility would be restricted on the basis of radiological effects at the individual organism level.
The Reference Organism approach
The 'Reference Organism' approach proposed in the report appears to have merit. It would seem to be scientifically viable, although as stated above the linkage to effects at population level needs to be better understood and defined. Whilst the practical definition of 'reference organism' may be more complex than 'reference man', it appears relatively simple in concept. It will, however, be important to avoid over-complication if the concept is to gain wide understanding and acceptance. In particular the need for any subsidiary reference levels must be minimised, and only involved where there may be strong evidence of potential harm.
We agree that more scientific data is needed in this field, but we believe that the developing ICRP framework will greatly assist in ordering the great weight of scientific data, which already exists as well as in prioritising areas for future research.
Conclusion
The WNA believe it is important that ICRP should lead the future development of the scientific framework for the protection of non-human species, and that the approach advocated in the Consultation Document has great merit as a starting point. We believe that the report itself, together with future work under the guidance of ICRP, should be set in the context of recognising the need to balance the overall societal benefits and detriments accruing from the use of radiation and radioactive materials.
Given the importance of this topic it is vital to ensure a full and effective international engagement with the debate in order to avoid domination by any particular regional perspective or sectoral approach. The rate of progress towards establishing the philosophical and scientific framework needs to balance the need to achieve full international consensus, the availability of the under-pinning scientific information and the need and desire to provide leadership in order to focus multiple approaches (which may be developing) on these issues.
The WNA welcomes ICRP work in this field, and seeks to work constructively both at the level of international debate and with the scientific community to ensure that our own expertise and data can best contribute to future developments.
APPENDIX B : List of Radiological Protection Working Group (RPWG) Members of the World Nuclear Association (WNA)