Submitted by Steven M Baker, Ph.D., Umtanum Enterprise Commenting as an individual
Executive Summary (g) lines 97 through 101 defines the term “optimization” without using the acronym “ALARA”, avoiding the negative connotation that the acronym carries in the nuclear community. This is an improvement, but it still defines optimization in terms of the phrase “as low as reasonably achievable” from which ALARA was derived. It would be preferable to explicitly define optimization in terms of “justification” which, I think, is the ICRP intent. Replacing the subject lines with the paragraph below should help avoid having regulators implicitly answer the questions: “what is reasonable?” and “what is achievable?”. Regulators have ignored dealing with "reasonable" (which should be determined in terms of justification) and have essentially specified “achievable” as radiation detection limits. The principal of optimization of protective actions applied with reference levels aims to minimize the detrimental impact of a radiation release as required by the principle of justification.
In order to minimize the total detrimental impact, optimization must consider:
Preventing severe tissue/organ damage,
minimizing the probability of cancer and heritable diseases,
preserving to the extent possible the health and wellbeing of all affected individuals,
providing to the extent possible decent working conditions for responders on-site,
maximizing to the extent possible quality of life of affected communities off-site,
preventing or reducing deleterious radiation effects on biota including biological diversity, and
minimizing cost of response to the radiation release.
This is essential to mitigate consequences during the emergency response, and to improve living conditions in affected areas during the recovery process. Of course, this change would require many other changes throughout the document. For example, 2.3. Principles for protection of people and the environment (42): lines 470 through 481 should be replaced with:(42)The aim of the Commission's recommendations concerning large nuclear accidents is to advise on actions to be taken to ensure an appropriate level of radiological protection for people and the environment. This means ensuring that all corrective action is conducted in accordance with the principle of optimization.