TL: THE TECHNICAL CASE AGAINST RADIOACTIVE WASTE DUMPING AT SEA A Review of Technical and Scientific Issues Relevant to the Work of the Inter-Governmental Panel of Experts on Radioactive Waste Disposal at Sea (IGPRAD) SO: Greenpeace International (GP) DT: July 20, 1992 Keywords: nuclear waste radioactive ocean dumping disposal greenpeace gp technical reference / [long] [20 pages] Submitted by Greenpeace International to the Fifth Session of Inter-Governmental Panel of Experts on Radioactive Waste Disposal at Sea (IGPRAD) of the London Dumping Convention (LDC) London, at the IMO, 2-6 November, 1992 CONTENTS EXECUTIVE SUMMARY INTRODUCTION 1. COMPARATIVE LAND-BASED OPTIONS TO SEA DISPOSAL 1.1 Comparative Assessments 1.1.1 Costs 1.1.2 Risks 1.2 Regulatory Approaches 1.2.1 Waste Management Options 1.2.2 The GESAMP Approach 1.2.2.1 Rational Development 1.2.2.2 A Precautionary Approach to Marine Pollution Control 2. PROOF OF HARM 2.1 Operational Definitions 2.2 Comparison of Risks 2.3 Consideration of Potential Damage 2.3.1 Damage to Human Beings 2.3.2 Damage to Other Organisms REFERENCES * * * EXECUTIVE SUMMARY In this submission Greenpeace provides its assessment of technical and scientific issues which IGPRAD has been asked to address by the Contracting Parties to the LDC. The first part of the submission considers (a) comparative land- based options and the costs and risks associated with these options, and (b) regulatory approaches to the dumping at sea of both radioactive and non-radioactive wastes. (a) Both the IAEA and IGPRAD concluded that it would be premature to reach consensus about the relative hazards of disposing of low-level radioactive wastes on the land or in the ocean. Greenpeace feels that this lack of consensus need not prevent a decision being taken on whether the dumping of radioactive wastes at sea should be banned or not. Greenpeace concludes that there is sufficient basis for excluding sea dumping as a disposal option. We propose two key criteria which we consider should be applied in choosing between management options for radioactive wastes. These are: 1. the ability to monitor developments after "disposal"; 2. the ability to intervene if necessary. Accordingly, dumping of radioactive wastes at sea can be ruled out as a valid option, in Greenpeace's view, on the basis that ocean dumping is essentially irreversible and the dumped material is unrecoverable. (b) We review GESAMP's report to the LDC which considers various regulatory approaches applied to the disposal of wastes in the marine environment. GESAMP proposed what they considered to be a common, comprehensive and holistic framework for the regulation of dumping at sea. Greenpeace considers that the GESAMP approach does not provide an appropriate approach to controlling marine pollution. Instead we recommend that IGPRAD adopt the approach taken in UNCED, which recognises the scientific context of the precautionary approach. The UNCED approach could serve as the basis for global action in controlling contaminant inputs, and therefore Greenpeace recommends that IGPRAD would do better to adopt this goal instead of the "subordinate global goal" recommended by GESAMP. The UNCED document states the goal as being: "... to manage human activities and human development in a manner that will prohibit or limit contamination of the marine environment, especially where there is reason to believe that damage or harmful effects are likely to be caused, even where there is inadequate or inconclusive scientific evidence to prove a causal link between emissions and effects, and thereby to ensure that the viability of marine ecosystems and the legitimate uses of the sea are sustained for the benefit of present and future generations.". The second part of the Greenpeace submission considers issues related to whether it can be proven that any dumping of radioactive wastes and other radioactive matter at sea will not harm human life and/or cause significant damage to the marine environment. It is acknowledged that dumping of radioactive wastes at sea will eventually lead to the release of radioactive material into the marine environment. Marine flora and fauna will receive enhanced radiation doses both from the intact waste packages and also after release of radionuclides into the marine environment. Numerous pathways exist which could result in radiation exposures of human beings. The IAEA analysis on risk comparison, reviewed in section 2.2, does make it clear that dumping of radioactive material at sea at levels several orders of magnitude less than those outlined in the IAEA Definition and Recommendations, can reasonably be expected to give rise to a health detriment. Based on current scientific knowledge and understanding, Greenpeace recommends that IGPRAD should adopt the following conclusions: 1. That, based on current scientific understanding, dumping carried out according to the IAEA Definition and Recommendations can be expected to lead to effects on human health proportional to the extent of the dumping; 2. That it is not possible to define radiation doses below which no deleterious effects can be demonstrated in humans; 3. That it is not possible to define radiation doses below which no deleterious effects can be demonstrated in organisms other than humans; 4. That it cannot be proven that dumping of radioactive wastes and other matter at sea will not cause damage to the marine environment. Taking the foregoing concerns and conclusions into account, we conclude that the option of sea dumping for radioactive waste cannot be supported from a technical or scientific perspective. * * * Introduction ============ (1) In order to help facilitate the work the Inter-Governmental Panel of Experts on Radioactive Waste Disposal at Sea (IGPRAD) this submission addresses the technical and scientific issues which IGPRAD has been asked to address by the Contracting Parties to the London Dumping Convention (LDC). (2) At the first meeting of IGPRAD (LDC/IGPRAD 1/6) two working groups were established. This paper reviews the issues entrusted to Working Group 2, namely the scientific and technical issues related to: - comparative land-based options and the costs and risks associated with these options, and parallels between the various regulatory approaches to the control of dumping at sea of both radioactive and non-radioactive wastes; - the question of whether it can be proven that dumping of radioactive wastes and other radioactive matter at sea will not harm human life and/or cause significant damage to the marine environment. 1. Comparative Land-Based Options to Sea Disposal ================================================= (3) IGPRAD has been asked to consider two issues within this category of work: (a) the evaluation of comparative assessments, submitted by Contracting Parties, of the disposal on land and dumping at sea options for the management of low-level radioactive wastes; and (b) to review parallels between the regulatory approaches to, and environmental assessments of, the dumping at sea of both radioactive and non-radioactive wastes. 1.1 Comparative Assessments --------------------------- (4) In 1987 IGPRAD recommended that the International Atomic Energy Agency (IAEA) should evaluate the comparative assessments, submitted by Contracting Parties, of the disposal on land and dumping at sea options for the management of low level radioactive wastes. In response, the IAEA issued IAEA-TECDOC-562 [1]. In 1991, Greenpeace presented a critique of the IAEA document to the 4th meeting of IGPRAD [2]. (5) IAEA-TECDOC-562 consists of a review of five comparative studies which were transmitted to the IAEA by Contracting Parties. IAEA Safety Series No. 65 [3], which constitutes the IAEA's principal guidance to the LDC on the nature and content of environment assessment of the sea dumping of radioactive wastes, was used as the primary basis for the review of the five studies. IAEA Safety Series No. 65 was used to generate a list of evaluation factors divided into six categories: financial, technical, social and political, general environmental, radiological, and methodological. The IAEA evaluation presented in IAEA-TECDOC-562 compared the content of each report to the list of evaluation factors and identified a number of similarities and differences in the approaches used in the five studies. 1.1.1 Costs (6) IAEA Safety Series No. 65 identifies economic cost as an important consideration in comparative evaluations, and it is one of the specific considerations which IGPRAD was asked to address. (7) A concern expressed by some Panel members at the 3rd Meeting of IGPRAD, was that the procedure suggested by the IAEA presents difficulties in that while direct costs can be estimated with some precision, other costs - particularly the costs of future environmental, health and social impacts - may be difficult to estimate precisely, or may be difficult to incorporate adequately within the comparative analysis. Moreover, future legitimate uses of the oceans may change substantially with the development of new technologies. It is extremely difficult to estimate the costs associated with potential interference in these future uses. The approach taken by the IAEA is problematic in that the analysis tends to over-emphasize costs which can be easily quantified and de-emphasise those which are difficult to quantify precisely. Moreover overly simplistic cost-benefit analysis, for example, may give the illusion of precision when combining these costs. Where the boundaries of analysis and the scale of uncertainties are not explicitly acknowledged, the "precision" with which results are expressed may give a misleading impression of the accuracy of any analysis [4]. (8) Greenpeace concluded that these considerations suggest that if cost is to be factored into comparative evaluations then this should be done in a cautious manner [2]. In particular it is essential to emphasise the uncertainties associated with the less easily quantifiable impacts and be explicit about the assumptions which have been made in incorporating the costs of future social, health and environmental impacts into the decision-making process. 1.1.2 Risks (9) The Panel concluded from the analysis presented in IAEA- TECDOC-562 that there was agreement that the choice of disposal option should be based on many types of factors, and not just on radiological impact (LDC/IGPRAD 3/9). Despite this, however, the dominant consideration in IAEA Safety Series No. 65 is the radiological impact on human beings. This is also the case for the reports submitted by Contracting Parties. (10) In IAEA Safety Series No. 65 all feasible systems are screened on the basis of regulatory constraints and other general considerations (e.g. the availability of disposal sites). The remaining systems are analysed purely on the basis of radiological protection criteria. The final stages of the analysis are essentially directed at optimisation again, with the emphasis on radiological protection criteria. It is clear that this approach is far from comprehensive but deals almost exclusively with the control of radiation doses. (11) Although the IAEA argues that, by following the methodology outlined in IAEA Safety Series No. 65, the various evaluation factors can be placed in a hierarchical scheme which can be used as a framework for comparison between various disposal options. As noted in the Greenpeace critique [2], examination of this scheme reveals it to be only a partial framework. In fact it constitutes little more than a check list of various evaluation factors which could be taken into account. (12) Combining the various evaluation factors on a common basis requires the application of weighting factors. The approach put forward in IAEA Safety Series No. 65 is of little use in assigning relative weightings for evaluation factors in different categories. In fact the selection of weighting factors is left aside to be dealt with by national competent authorities. Therefore the IAEA approach fails to provide a structured way of incorporating the necessary considerations into the decision- making procedure in an objective manner. (13) The selection and application of weighting factors is also problematic. On the one hand it may lead to subjective application of arbitrarily selected weighting factors by a competent authority which may not be considered to address the legitimate concerns of another potentially affected State - as could certainly be the case where dumping occurs in the deep ocean. On the other hand, reaching international agreement on the appropriate weighting factors to be applied would be an extremely complex exercise. Regardless of how the weighting factors are derived, there is clearly considerable scope for a high degree of subjectivity to enter into a process presented as empirical by the IAEA. (14) On the basis of the reports considered, both IAEA and IGPRAD concluded that it would be premature to reach consensus about the relative hazards of disposing of low-level radioactive wastes on the land or in the ocean. This is a truism - due to lack of supporting data the case for final disposal into any media is unproven. Nevertheless, Greenpeace feels that this lack of consensus need not prevent a decision being taken on whether the dumping of radioactive wastes at sea should be banned or not. In its critique Greenpeace argued that there exists sufficient basis for excluding sea dumping as a disposal option [2]. (15) Greenpeace considers that there are two key criteria which should be applied in choosing between management options for radioactive wastes. These are: 1. the ability to monitor developments after "disposal"; 2. the ability to intervene if necessary. (16) As can be seen from the experience with chemical weapons disposed of at sea following World War II, ocean dumping is essentially irreversible and the dumped material unrecoverable. Accordingly, on these grounds alone, dumping of radioactive wastes at sea can be ruled out as a valid option. 1.2 Regulatory Approaches ------------------------- (17) The Joint Group of Experts on the Scientific Aspects of Marine Pollution (GESAMP) was requested by the LDC to undertake an examination of the parallels between the regulatory approaches to, and environmental assessments of, the disposal of wastes in the marine environment. As part of the task GESAMP were asked to identify opportunities for developing a common, comprehensive and holistic framework for the regulation of dumping at sea. (18) In 1991 GESAMP published their review of regulatory approaches to, and environmental assessments of, the disposal of wastes in the marine environment [5]. In order to fulfil the specific request from IGPRAD, GESAMP have adopted a report entitled "Can There Be a Common Framework for Managing Radioactive and non-Radioactive Substances to Protect the Marine Environment ?" [6]. 1.2.1 Waste Management Options (19) In their report GESAMP state that permanent isolation of wastes from the environment is not possible. Two approaches are identified as basic options for waste management: dispersion and containment. GESAMP conclude that the two approaches only differ with respect to the time-frames over which the release to the wider environment occurs. Implicit in their conclusions is the underlying assumption that these are "once and for always" solutions. (20) These conclusions by GESAMP are justified for any "walk- away" disposal concept (e.g. land-fills, deep geological disposal, sub-seabed disposal, etc). They do not apply, however, to systems designed so that their performance is monitored and where intervention can be made if found to be necessary after wastes have been emplaced in them. Such reversible and monitorable systems do allow the possibility permanently to isolate wastes from the environment. Greenpeace therefore advocates such systems in the context of certain wastes - such as long-lived radioactive wastes - which have already been produced. 1.2.2 The GESAMP Approach (21) In their report to IGPRAD [6], GESAMP present a summary of their Reports and Studies No. 45. In particular GESAMP stress that, in their earlier paper, it was concluded that the adoption of an overall framework for marine environmental protection based upon so-called "sound principles" and a "logical" hierarchy of goals and activities, would enhance the effectiveness of management activities. 1.2.2.1 Rational Development (22) In particular GESAMP identify four principles drawn from the Stockholm 1972 Conference on the Human Environment, the Law of the Sea Convention (1982), and the Brundtland report. These are: - sustainable development; - prevention of harm; - avoidance of inter-sectoral transfer of damage; - international co-operation. (23) During the 3rd session of IGPRAD concern was expressed that the task which GESAMP had agreed to undertake was formulated prior to recent expressions of the "precautionary principle" and the "principle of anticipatory environmental protection" within the LDC consultative process (LDC/IGPRAD 3/9). It now seems that such concern was justified. Not only is the "precautionary principle" not incorporated into GESAMP's set of fundamental principles, but there is a suggestion by GESAMP that the precautionary principle is fundamentally flawed because they do not see how it acknowledges the legitimacy of human interactions with ecosystems. The questioning of the precautionary principle by GESAMP is evidence that they have failed to evolve their collective thinking in line with scientific developments and that GESAMP have also failed to take note of the political imperatives arising from these developments. (24) Despite an acknowledgement that the continued viability, productivity and diversity of ecosystems is "possibly" the most important objective of environmental protection, GESAMP see a tension between this and continued human development and its "associated propensity for waste production". Accordingly, GESAMP suggest that the overall goal of the protection of the marine environment should be: "To protect the marine environment against the adverse effects of human activities so as to conserve marine ecosystems and to safeguard human health while providing for rational use of living and non-living resources." (25) This is a political judgement rather than a scientific one. There is a fundamental policy question here, namely is it possible to value the environment in absolute terms or merely in relation to "rational" exploitation by humans ? GESAMP clearly advocates the policy that the marine environment can be given a notional economic value to allow the use of the oceans for waste disposal purposes. As evidenced by the recent decision to declare Antarctica a "World Park", and also because GESAMP ignore benefits arising from preventive measures such as substitution and alternative technologies, it can be seen that GESAMP's approach is too narrow and out of touch with contemporary policy developments. Moreover, it is far from evident that GESAMP have the appropriate structure, composition or mandate to resolve such broad policy issues. (26) The idea of the environment simply as a resource for exploitation is developed by GESAMP further in their formulation of "a subordinate global goal" for marine pollution control. This states: "To manage human activities and social and economic development in a manner that limits contamination of the marine environment by substances and wastes, thereby ensuring that the viability of marine ecosystems and the legitimate uses of the sea are sustained for the benefit of present and future generations.". (27) Implicit in this working definition is the concept that not only do marine resources have a direct economic value in a tangible sense, but that these economic resources can be exploited legitimately for the dumping of wastes within the oceans' capacity to "assimilate" them. Such an approach implies that all variables within the receiving environment are known and impacts can be controlled and monitored. While GESAMP describe their approach as being "for managing the use of the marine environment...", any approach based upon these precepts is highly questionable. (28) As noted by Greenpeace in its critique of GESAMP Reports and Studies No. 45 to the 14th Consultative Meeting of the LDC [7], we consider that science has had great difficulty in defining and modelling the dynamics of major ecosystems, marine or otherwise, natural or human-made. It is this difficulty which accounts for the great failings of predictive science in the past years: acidification of soils, the death or decline of forests, the loss of stratospheric ozone, eutrophication of coastal waters, etc. GESAMP fail to take account of these failures when they promote their version of "rational" development. From past experience, it appears that resource-limited observation cannot provide a sufficient understanding of marine ecosystems so as to guarantee the continued maintenance and functioning of ecosystems under the pressures arising from uses deemed "rational" by GESAMP. (29) The GESAMP report [6] outlines the structure of the approach to radiological protection taken by the International Commission on Radiological Protection (ICRP): justification, compliance with the dose limits, and optimisation. GESAMP praise the holistic nature of this system and considers that it has potential for wider application to environmental management and protection. (30) While the ICRP system can be applied in any "controlled" radiation field - and as such could be claimed to be "holistic" in a narrow sense - it is far from evident that it has adequately "protected" people. Karl Morgan considers that while ICRP guidance has been useful in reducing some unnecessary radiation exposures, ICRP has also "delayed action to reduce excessive exposures, has underestimated radiation risks and recommended radiation exposure levels which are much too high." [8]. These are serious failures which cannot be simply ascribed to a failure to observe the ICRP system of dose limitation. Contrary to the assertion by GESAMP [6], they are attributable to weaknesses in the system, and in particular a weakness in the system with respect to the "justification principle". (31) Similar to the notion of "assimilation" for which no definitive or absolute values can be set, "justification" is also a highly subjective term. It is not capable of being rigorously defined and therefore has been of little or no practical use in the decison-making process. Not suprisingly, GESAMP do no more than state its definition without explaining how justification could be used in practice. Greenpeace considers that justification has no role to play as a scientific or working principle, and therefore the ICRP system is severely compromised. (32) Other serious failings of the ICRP approach to date include the difficulty in applying it during accidents or other uncontrolled exposures and that due to inherent limitations it has not been systematically applied in protection of the environment from radiation and radioactivity [9]. (33) GESAMP do not provide the comprehensive analysis IGPRAD requested, because their report does not address the protection of ecosystems in anything other than relative terms expressly tied to economic considerations. This approach leads GESAMP to conclude that prevention of pollution by restricting disposal options is most unlikely to be appropriate or effective at global level. The unsupportable corollary of this GESAMP claim is that NOT restricting disposal options will somehow lead to a more rational use of resources and control of pollution. 1.2.2.2 A Precautionary Approach to Marine Pollution Control (34) In their conclusions, GESAMP go so far as to claim that the prohibition of any disposal option could lead to immediate social and/or economic impacts that are unnecessary and undesirable. Unsurprisingly, no empirical evidence is put forward to support these claims, nor is consideration given to potential social and/or economic impacts of continued dumping. (35) It can be seen that, despite the advances of the Precautionary Principle in many fora, GESAMP are still trying to justify the dumping of radioactive wastes into the ocean by means of reference to what are claimed to be objective, quantitative and verifiable measures of "acceptable" harm. Closer examination reveals that the definition of harm used is severely limited by the methodologies applied, and that moreover application of these methodologies will never provide absolute assurance that damage to the environment or to people will not result. This is a consequence of GESAMP operating outside of their scientific mandate, to embrace antiquated political considerations in their support of continued dumping. (36) By way of contrast to GESAMP's approach, Resolution LDC.44(14) on "The Application of a Precautionary Approach in Environmental Protection Within the Framework of the London Dumping Convention", acknowledges that: "... existing pollution control approaches under the LDC have been strengthened by shifting the emphasis from a system of controlled dumping based on assumptions of the assimilative capacity of the oceans, to approaches based on precaution and prevention.". (37) More recently, the United Nations Conference on Environment and Development (UNCED) has considered this shift in emphasis in the protection of the oceans and seas and the protection, rational use and development of their resources. A report of the Secretary-General of UNCED notes that: "...this shift has been away from the principles of assimilative capacity which have required both scientific evidence of significant environmental degradation or harm, as well as the demonstration of a causal link to a substance or activity, toward the principle of anticipatory action, which ... does not preclude acting even before the onset of damage is thought likely." [10]. (38) Unlike GESAMP, the UNCED document recognises the scientific context of the precautionary approach. It states: "Appropriately, the principle of precautionary action: (1) appreciates the limits of scientific prediction, monitoring and control; (2) accepts that anticipatory action can and should be taken where sufficient grounds exist for concern, even in the absence of firm scientific proof of cause and effect; and (3) recognises that resources must be put into clean production technology in order to ensure that harmful wastes are minimised." [10]. (39) The UNCED document concludes that this basis of a precautionary approach could be directed at all substances and wastes, although certain substances might be given priority in the initial phases of its implementation [10]. (40) The UNCED document also concluded that a specific goal was warranted in the context of the prevention of marine pollution by substances and wastes. It concluded that this could serve as the basis for global action in controlling contaminant inputs, and Greenpeace recommends that IGPRAD would do better to adopt this goal instead of the "subordinate global goal" recommended by GESAMP. The UNCED document stated the goal as being: "... to manage human activities and human development in a manner that will prohibit or limit contamination of the marine environment, especially where there is reason to believe that damage or harmful effects are likely to be caused, even where there is inadequate or inconclusive scientific evidence to prove a causal link between emissions and effects, and thereby to ensure that the viability of marine ecosystems and the legitimate uses of the sea are sustained for the benefit of present and future generations." [10] 2. Proof of Harm ================ (41) As noted earlier, GESAMP have concluded that permanent isolation from the environment of dumped wastes is not possible, and therefore dumping of radioactive wastes at sea will lead to the release of radioactive material into the marine environment [6]. This will cause contamination of both water and sediments by radionuclides and radioactive materials, and thus creates the possibility of uptake of radioactivity from the waste materials and the radiation exposure of marine organisms and humans. (42) The principal mechanisms for transport of released radionuclides from the deep oceans are physical mechanisms (e.g. advection, mixing) and biological mechanisms (e.g. uptake by organisms via the food web). Contaminants may be transported over considerable distances by both mechanisms and by combinations of them. While it is considered unlikely that contaminants from the deep oceans will be transported over long distances to surface waters without substantial dilution and dispersion, processes which short-circuit long-term dispersion processes are known. The IAEA have given consideration to the possibility of advective plumes reaching a fishing zone in deep water (e.g. a long-line fishery), and deep convective mixing reaching down to depths of 2000 metres has been observed [11]. Moreover, it is known that there are mechanisms for relatively fast horizontal sediment transport in the deep oceans over large distances, creating the possibility that components of deep-sea sediments may be transported onto the continental shelf [11]. (43) While it is claimed that models used to assess the rates of transport of radioactive materials from the deep ocean are conservative, it is also the case that there remain substantial uncertainties about deep-ocean circulation relevant to particular dumping sites [11]. Hence the IAEA have noted: "Not enough is known about deep-ocean circulation to be able to distinguish the rates of transport likely from specific dump- site locations. We have simply made pessimistic assumptions, and have not yet therefore made separate estimates for different locations. Specific assessments for individual disposal sites are however called for within the terms of the London Convention." [12]. (44) Disposal of packaged radioactive waste on the sea-bed will result in enhanced radiation exposure of marine biota both from intact waste packages and also after release of radionuclides into the marine environment. In addition to the potential consequences for marine organisms (see section 2.3.2), this creates the possibility for human exposure to dumped radionuclides through the consumption of marine foodstuffs. (45) Following release of radionuclides into the marine environment, numerous pathways of varying importance exist that could lead to radiation exposures of human beings. These include radiation exposures due to external radiation and ingestion of radionuclides. Estimates by the Nuclear Energy Agency (NEA) [13] show that the consumption of seafood contaminated by radionuclides from past ocean dumping, is likely to give rise to considerably larger exposures than external exposures. (46) In order to assess the significance of the potential impacts of releases of radionuclides into the marine environment through the dumping of radioactive wastes in the deep ocean, IGPRAD was asked to address the question of whether it can be proven that any dumping of radioactive wastes and other radioactive matter at sea will not harm human life and/or cause significant damage to the marine environment. This work was divided into several sections: - the development of a number of operational definitions of various terms; - a review and summary of available scientific information on estimates of risks, both voluntary and involuntary, to human well-being that result from various human activities; - develop an explanation of the basis of the linear dose / effect relationship and an opinion as to whether it is possible to define radiation doses below which no deleterious effects can be demonstrated in man or other organisms. 2.1 Operational Definitions --------------------------- (47) IGPRAD was asked to develop operational definitions of such terms as "harm", "safety", "proof", "significance" and other terms which might be required to address operative paragraph 2.3 of Resolution LDC.28.10. (48) At the first meeting of IGPRAD it was decided to refer this matter to GESAMP. GESAMP declined to deal with this work on the grounds that definitions of the terms involved non-scientific as well as scientific considerations. During the 4th Meeting of IGPRAD the question of the definitions was re-examined and again it was decided to postpone any final decision on the definitions. (49) Greenpeace does not consider the failure to develop formal definitions of these terms to be a barrier to the completion of the IGPRAD work, insofar as discussions under the topic "Proof of Harm" have been able to proceed without these definitions. 2.2 Comparison of Risks ----------------------- (50) IGPRAD requested the IAEA to review and summarize available scientific information on estimates of risks, both voluntary and involuntary, to human well-being that result from various human activities in order to provide a basis for comparison with risks arising from the dumping of radioactive wastes at sea. (51) The IAEA submitted its draft study to the 4th Meeting of IGPRAD [14]. The document contains comparative assessments of risks to individuals and populations posed by the ingestion of natural radionuclides and certain organic chemicals in seafood and risks associated with the sea dumping of radioactive waste. (52) Several criticisms of the IAEA study were voiced during the 4th meeting of IGPRAD. Those of particular significance were the fact that the risk estimates for sea dumping of radioactive wastes were for past dumping activities conducted at levels several orders of magnitude below the limits suggested in the IAEA Definition and Recommendations [15] and that the IAEA analysis did not consider all exposure pathways, because it restricted itself only to ingestion. (53) Despite the request by IGPRAD to provide a broad base for risk comparison, the IAEA analysis largely limits itself to the risks of fatal cancer induction as a basis for comparison. IGPRAD concluded from the IAEA document that the risks of fatal cancer induction through ingestion of sea-food "provides one basis for an equitable comparison of risks" (LDC/IGPRAD 4/9 para 4.12.1). It should be noted that this basis for comparison means that some of the risks associated with exposure are excluded, such as non- fatal cancers and genetic effects, and that carcinogenisis may not be the most sensitive end-point of the effects of exposure. (54) In the conclusions it drew from the IAEA paper, IGPRAD took note of the IAEA's finding which emphasises that the greatest harm to the global population from the various sources compared, arises from ingestion of naturally occurring radionuclides (LDC/IGPRAD 4/9 paras 4.12.2 and 4.12.3). It should be noted that while comparing the estimated incremental dose rate with that expected to arise from natural background may have utility in providing a perspective on likely impact, "this has no validity from the viewpoint of protection." [16]. Overall, the IAEA fails to present an analysis which readily allows a distinction to be made between voluntary and involuntary risks, occupational and public exposures, and morbidity and mortality, despite the importance of disaggregating these risks being recognised elsewhere by the IAEA [17]. (55) The IAEA report notes that the concentrations of certain organic compounds may present higher risks of cancer induction than do the presence of radionuclides from dumping operations (although the proportions would change if the calculations were based on dumping at the limits set in the IAEA Definition and Recommendations [15]). However it fails to point out that some of the organic substances used as a basis of comparison are either banned or severely restricted in use, even where the exposure of the population to these substances is below the allowable levels of intake set. It must be questioned whether the IAEA's simplistic comparison is valid, as on the one hand we are dealing with harmful organic materials whose further input into the marine environment is restricted, while on the other hand we are considering the deliberate introduction of radioactive materials into the oceans in the future. (56) Moreover, the IAEA report asserts: "On this basis any cause for concern about the harm resulting from sea dumping of radioactive waste would seem to be misdirected because chemical contaminants give rise to much greater harm to both global and European populations." [14]. (57) This would seem to contradict the claim made in the 4th meeting of IGPRAD where it was stressed that "nothing in the IAEA report, nor in the conclusions drawn from the document presented by the IAEA... should be construed as dealing with, or judging, the acceptability of risks..." (LDC/IGPRAD 4/9 para. 4.11). In order to be consistent with its claim that it does not favour any disposal option in particular, the IAEA should not express any such judgement. (58) Significantly this also highlights an inadequacy in the IAEA approach and, as noted above, in the GESAMP Reports and Studies No. 45 Addendum 1 [6], where continuation with what can be shown to be a potentially detrimental practice is not assessed in terms of possibilities of less detrimental alternatives, but in terms of other, unconnected, sources of risk. The fact that other sources of pollution - such as that which may arise from chemicals - may generate greater risk is not relevant to the prevention of risk caused by the dumping of radioactive waste. In essence, IAEA and GESAMP appear to be claiming that a priority source of harm renders other sources insignificant, a conclusion that cannot be justified on the basis of science. 2.3 Consideration of Potential Damage ------------------------------------- (59) IGPRAD was asked to develop an explanation of the basis of the linear dose/effect relationship and an opinion as to whether it is possible to define radiation doses below which no deleterious effects can be demonstrated in man or other organisms. 2.3.1 Damage to Human Beings (60) The IAEA analysis on risk comparison [14] reviewed in section 2.2 above, does make it clear that dumping of radioactive material at sea at a level several orders of magnitude less than those outlined in the IAEA Definition and Recommendations can reasonably be expected to give rise to a health detriment. (61) IGPRAD requested the IAEA to address the question of radiation risks at low doses in consultation with the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and the ICRP. In response to this request, IAEA- TECDOC-557 [18] was presented to the third meeting of IGPRAD. (62) Greenpeace welcomes the unambiguous language of the IAEA report, which makes it clear that for low dose rates it may be assumed that the likelihood of effects is directly proportional to the exposure to radiation. Moreover the IAEA report concludes that there is no evidence to indicate a threshold dose below which effects of exposure radiation might be expected not to occur. (63) Greenpeace recommends that IGPRAD should draw the following conclusions from the IAEA paper: 1. That, although any increase in health effects may be statistically impossible to distinguish from the ambient levels of these effects in a population, based on current scientific understanding, dumping carried out according to the IAEA Definition and Recommendations can be expected to lead to effects on human health proportional to the extent of the dumping. 2. That it is not possible to define radiation doses below which no deleterious effects can be demonstrated in human beings. 2.3.2 Damage to Other Organisms (64) The IAEA has provided guidance on the disposal of radioactive wastes into the marine environment. Following a request from Contracting Parties to the LDC, the IAEA undertook to develop a formal Definition and Recommendations of radioactive wastes unsuitable for disposal at sea. The first such Definition was published in 1974 [20] and the latest revision was made in 1986 [15]. The IAEA's approach has been based on the radiological protection principles embodied in the system of dose limitation of the ICRP [19]. (65) In its latest 1990 Recommendations [21] the ICRP has reaffirmed its 1977 claim that "the standard of environmental control needed to protect man to the degree currently thought desirable will ensure that other species are not put at risk." [22]. It should be noted, however, that the ICRP has developed and recommended a system of dose limitation which has as its central objective "the achievement and maintenance of appropriately safe conditions for activities involving human exposure" [22], and therefore it does not address environmental protection as a central concern. (66) It is possible that the ICRP assumption may carry some validity in those situations in which sources of radioactivity are released into environments occupied by humans or from which they derive a significant part of their nutritional requirements. However there are no agreed criteria for verifying this approach [16]. (67) In some situations it is possible to conceive of relatively high radiation doses to the fauna even though the exposure of human beings is kept within regulatory requirements [see, for example, 23, 24, 25]. Because of this concern, it was realised that a more detailed examination of exposures of marine organisms was clearly necessary in order to determine whether they would be adequately protected from dumping operations carried out in compliance with the IAEA Definition and Recommendations. (68) An examination of the available means for assessing the environmental impact of the disposal of low-level waste into the deep sea was conducted by the IAEA [26]. The IAEA report confirmed an earlier prediction that dumping of such wastes into the deep ocean has the potential to deliver damaging radiation exposures to aquatic organisms even when the dumping rate is restricted to the IAEA Definition and Recommendations [23]. For certain radionuclides the potential incremental exposures would be sufficiently high and widespread such that effects at the population level would be expected [26]. IAEA Technical Reports Series No. 288 concluded that future revisions of the Definition and Recommendations must take into account potential environmental effects [26], and Calmet and Bewers have indicated that, as a result of the IAEA report, it can no longer be assumed that "environmental organisms" are likely to be protected if doses to humans are kept within the regulatory limits [19]. (69) From the above it is clear that the existing IAEA Definition and Recommendations [15] do not provide an adequate level of environmental protection to marine organisms. Therefore it has to be questioned whether, as requested to IGPRAD, it can be proven that dumping of radioactive wastes and other radioactive matter into the marine environment, according to any future revision, will guarantee that there will be no damage to the marine environment. (70) In a paper for the Commission of the European Communities Woodhead and Pentreath [16] have identified what they consider to be the three essential requirements for a system of protection for marine organisms. These are: - an estimate of the radiation dose rate to the tissue or organ of interest (this requires a knowledge of the distribution of the radionuclides both within the organism and its external environment); - the determination of dose-response relationship for the various organisms; - an assessment of the effect which the death or reduced reproductive capacity of an individual or groups of individuals, would have at a population level. (71) None of the above requirements can be met in full at present. With regard to the tissue/organ dose rates and dose rate/response relationships, Woodhead and Pentreath conclude that "it is unrealistic to believe that information of this nature will be available for all species of wild organisms in anything like the detail in which it has been developed for man." [16]. (72) Therefore, while Woodhead and Pentreath felt that increasing the sophistication of models used was not an insurmountable problem, they considered that the provision "of the essential supporting data, particularly on radionuclide distributions in a wide variety of species, is a problem." [16]. Moreover they acknowledge that there is a limit to the extent to which account may be taken of the wide diversity of marine organisms in an assessment, and that therefore such an assessment must be based on certain generalisations. While the generalised approach might give robust results for the more highly fecund species in marine environments [27], it is considered a much less robust conclusion for marine species which exhibit low fecundity [16]. Disturbingly, it is for the less fecund species that the least empirical data is available [28]. (73) For non-human species it is stated that the protection of populations, rather than of individual organisms, is the primary objective [26]. Yet it is considered that the development of guidelines for assessing the impact of radiation on deep sea marine organisms at the population level is not easily achieved [16]. In this respect it should be noted that even for humans there are no limits of exposure for populations [26]. While methods for translating the radiation responses of individuals into a prediction of effects at the population level have been suggested [29, 30], they have not been rigorously examined and applied to real waste disposal situations [16]. Moreover, McKee et al have concluded that given "our poor understanding of response mechanisms at higher levels (particularly at the ecosystem level), it is clear that knowledge of radiation effects at the organism level does not provide an adequate basis for prediction of effects at higher levels of organisation." [25]. It should also be noted that impact on the ecosystem as a whole cannot be determined solely by reference to the impacts on individual populations, as it fails to ensure that species interactions are taken into account [31]. (74) As noted above, the IAEA has concluded that dumping conducted according to the existing IAEA Definition and Recommendations could lead to significant damage to marine organisms at the population level [26]. While it has been stated that the IAEA Definition and Recommendations should be revised to take into account environmental protection requirements [19, 26), there is a significant lack of data at all three levels of information suggested as necessary to ensure protection of marine organisms [16]. (75) Moreover there can be no guarantee that such data will become available in the detail required to guarantee protection of the most vulnerable populations. Accordingly, Greenpeace recommends that IGPRAD adopt the following conclusions: 1. It is not possible to define radiation doses below which no deleterious effects can be demonstrated in organisms other than human beings. 2. Based on current understanding it cannot be proven that dumping of radioactive wastes and other radioactive matter at sea will not cause damage to the marine environment. ----------------------------------------------------------- References ========== 1. IAEA, Low Level Radioactive Waste Disposal: An Evaluation of Reports Comparing Ocean and Land Based Disposal Options, IAEA TECDOC-562, IAEA, Vienna, 1990 2. Greenpeace International, A Review of the IAEA Approach to Comparative Assessments of the Impact of the Dumping at Sea and Land-Based Disposal of Low-Level Radioactive Wastes, LDC/IGPRAD 4/INF.4 3. IAEA, Environmental Assessment Methodologies for Sea Dumping of Radioactive Wastes, IAEA Safety Series No. 65, IAEA, Vienna, 1984 4. See, for example, Funtowicz, S.O. and Ravetz, J.R., Uncertainty and Quality in Science for Policy, Kluwer Academic Publishers, Dordrecht, The Netherlands, 1990 5. GESAMP, Global Strategies for Environmental Protection, Reports and Studies No. 45, GESAMP, 1991 6. GESAMP, "Can There Be a Common Framework for Managing Radioactive and non-Radioactive Substances to Protect the Marine Environment ?", GESAMP, Reports and Studies No. 45, Addendum 1, 1992 7. Greenpeace International, Critical Review of GESAMP Report No. 45 on "Global Strategies for Marine Environmental Protection", 1991 8. Morgan, K.Z., ICRP risk estimates - an alternative view, IN: Radiation and Health: the Biological Effects of Low-level Exposure to Ionising Radiation, Jones, R.R. and Southwood, R. (eds), John Wiley and Sons, Chichester, 1987 9. Davy, D.R. and Jeffree, R.A., Ocean Dumping of Low Level Radioactive Waste, Australian Nuclear Science and Technology Organisation, IAEA-CN-51-48, no date 10. 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Wallis, I.G., Modelling techniques for predicting the long- term consequences of radiation on natural aquatic populations.", Methodology for Assessing Impacts of Radioactivity on Aquatic Ecosystems, Technical Reports Series No. 190, pp.97-118, IAEA, Vienna, 1979 30. Van Winkle, W., Modelling techniques for predicting long-term consequences of the effects of radiation on natural populations and ecosystems.", Methodology for Assessing Impacts of Radioactivity on Aquatic Ecosystems, Technical Reports Series No. 190, pp.97-118, IAEA, Vienna, 1979 31. GESAMP, Long-term consequences of low-level marine contamination., Reports and Studies No. 40, 1989 =end=