Protection of theenvironment// IRSN orientation
Edition 2005-04-07

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Protection of theenvironment// IRSN orientation
First edition 11/03/2005
IRSN report n°2005-48© IRSN/2005 --- All rights reserveddoc reference
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o IRSN 2005-48// IRSN short view
The Institute for Radiological Protection and Nuclear Safety (IRSN), createdby the law n°2002-254 of May 09, 2001, then by the decree n°2002-254 ofFebruary 22, 2002, is a public establishment of an industrial and commercial
nature (EPIC), under the joint authority of the Ministers of Defense, theEnvironment, Industry, Research and Health."
IRSN employs more than 1,500 specialists, including engineers, researchers,
doctors, agronomists, veterinarians and technicians, experts in nuclear safety
and radiological protection and in the control of nuclear and sensitive
materials
The Institute exercises specialist and research assignments in the following
fields:• nuclear safety ;• safety in transporting radioactive and fissile materials ;• protection of man and the environment against ionising radiation ;• protection and control of nuclear materials ;Doctrine & synthèse• physical protection of facilities and transport of radioactive and fissile

Editions property of IRSN
77-83, avenue du Général de Gaulle
92140 Clamart - France
Tél : +33 1-58-35-88-88

materials.

Web site : www.irsn.org

This document may not betranslated, adapted or reproduced
by any means or for any purpose
whatsoever without written
authorization. For further
information, please contact :IRSN
Frederic Goldschmidt
BP 1792265 Fontenay aux Roses cedex
FranceFax : +33 1-58-35-79-71

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Forward
The Institute for Radiological Protection and Nuclear Safety conducts
research programmes and studies on nuclear and radiological risks ; itis responsible for public service activities in the prevention of theserisks and provides technical support to the competent publicauthorities in nuclear and radiological protection safety and security.
In this respect, the Institute is called on to develop a position on acertain number of scientific and technical issues.
Under its policy of transparency and its desire to make high-quality
information available to all partners and stakeholders for use indeveloping their own views, IRSN publishes doctrine and summary
documents that present the Institute's position on a specific subject.
IRSN specialists prepare these documents, if appropriate inconjunction with outside experts, which are then submitted to aquality assurance validation process.
They reflect the IRSN position on the day of their publication on its
internet site. This position may reviewed in the light of progress inscientific knowledge, changes in regulations or a need for more indepth discussion of the subject to respond to an internal requirement
or external requests.

www.irsn.fr

This document may be used and quoted freely on condition that thesource and publication date are mentioned.
Comments are welcome. They may be sent to the address indicatedalongside, quoting the related document.

Jacques Repussard
Director General

Doctrine & synthèse
IRSN
BP 17
92265 Fontenay aux Roses
cedex
FranceFax : +33 (0) 1 58 35 79 71

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o IRSN 2005-48//Members of theworking group
Annie SugierJean Claude Barescut
François Bréchignac
Jean Brenot
Didier Champion
Jean Christophe Gariel
Jacqueline Garnier-Laplace
Nathalie Lemaitre
Joseph Lewi
Daniel Quéniart
Annie Sugier

Chairwomen

DSDRE/DPSDESTQ/DEAS
DRPH/Dir
DEI/Dir
DEI/SECRE
DEI/SECRE/LRE
DEI/SESURE
DESTQ/Dir
IRSN/Dir
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Summary
Forward

4

1/
Changes in radiological practice//and current challenges

7

2/
Present limits of understanding// and resulting constraints

93/
The general strategy proposed by the IRSN// for a system of radiological protection of
the environment and associated objectives

10

4/
The main principles// of the proposed method forenvironmental risk assessment and the new scientificunderstanding that will be needed

125/Consequences// in terms of environmental monitoring

14

6/
The relationship// of IRSN programs to chose of its partners

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1/

Changes in radiologicalpractice//and current challenges
Environmental protection within a radiological protection context has
for some time been conditioned by the ICRP paradigm which statesthat if man is protected others species are not put at risk. During thelast decade, the absence of any scientific demonstration of thisaffirmation, and the increasing importance given to environmental
issues at a number of international conferences, have led to areexamination of this paradigm.

ICRP, 1991. Recommendations of theInternational Commission on
Radiological Protection, Publication
60, Pergamon Press, Oxford and NewYork.

The most widely voiced objections to the ICRP paradigm are as
follows:• This paradigm does not apply to those parts of the environment
where there is no human presence (in the deep oceans, for example)
and it may not be valid over all scales of time and space.
• The lack of harmonization between the methods of managing
environmental radiological protection and the international
recommendations for environmental protection in general isdifficult to justify in the face of European legislation targeting:−−−

The conservation and protection of habitats.
The conservation of biodiversity and the protection ofendangered species.
Resource management, the prevention of pollution andpollution control at source.

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o IRSN 2005-48• The absence of proven methods and specific criteria forenvironmental protection with regard to radionuclides is difficult tojustify given those existing for chemical substances. Moreover, thissituation makes it difficult for the public to understand the impact
of radionuclides released into the environment.

These considerations explain the evolution of radioecology. Thisdiscipline, historically bound to support human radiologicalprotection, initially targeted the study of transfer of radionuclides
towards humans. The field of radioecology has now expanded tobetter include an evaluation of the exposure and effects of theseradionuclides on fauna and flora, together with the ecosystems ofwhich they form part. In addition, while the distribution ofradionuclides in the environment was supposed to be homogeneousand in equilibrium between the various compartments, study now
takes account of their spatial and temporal variations in theenvironment.

Radiological protection of the environment is important from anumber of points of view: It is the subject of vigourous and recurrent
questioning associated with the various uses of radioactivity and dueto the resulting increase in the stock of long lived radioactive
products ; there are many domestic and international legislative andconstitutional changes (French environmental charter) in progress orplanned for the future ; the domestic situation in France is unique(highly nuclearized country with all the corresponding economic,
industrial and social implications).
However, there is as yet no scientific proof of any effect on
ecosystems from exposure to radionuclides during the normal
operation of facilities making use of radioactive substances. This may
be due to a too much limited distance view and/or the fact that theecological monitoring carried out in situ, using current environmental
monitoring strategies specified for the waste authorizations granted
to nuclear facilities, do not allow to detect effects at the ecosystemscale and to identify their cause.

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Present limits ofunderstanding//and resulting constraints
An analysis of the current level of understanding, based on work by anumber of international organizations and European research
programs, has identified the following areas where knowledge isprimarily lacking:• The process of accumulation of radionuclides in abiotic (air, water,soil, sediments) and biotic compartments (fauna and flora) and theresulting potential effects.
• The effects of chronic low level internal exposure to α
and β emitters on all types of species.
• The propagation of these effects from the individual to the
population, communities and ecosystems.

The implementation of an environmental radiological protection
system will inevitably come up against these knowledge limitations. A
number of extrapolations will be necessary in order to overcome
them, including those from the individual to the population andhigher organizational levels, from a high dose regime to a low dose
regime, from acute exposure to chronic exposure, and from external
exposure to internal exposure.

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The general strategy
proposed by the IRSN//for a system of radiological protection of
the environment and associated objectives
The IRSN believes that an environmental radiological protection
system must aim to preserve the structure and function of
ecosystems. This will require consideration of 1) the biotic and abiotic
compartments which form both the sources of exposure and thehabitats of the living organisms, and 2) the interactions within andbetween these components.

It is necessary to be in a position to carry out an assessment of therisk to the environment from radionuclides, both now and in the
future, based on scientific standards. The IRSN believes that thisshould lead to the development, approval and implementation of anassessment methodology applicable to activities in which radioactive
substances are used. This also implies a need for solid scientificunderstanding, minimizing the requirement for excessive safetymargins resulting from lack of detailed scientific understanding, andfor a corresponding development program aimed at theimplementation of suitable protective measures.

The IRSN follows the approach adopted by the ICRP which aims toprovide a degree of consistency between protection systems targetingthe environment and that designed for humans. This consistency
already emerges from the notion of reference animals and plants thatis used in the same way as the reference man to provide a common© IRSN/2005 --- All rights reserveddoc reference
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basis for simplified dose calculations. In this way, the environmental
transfer pathways used in the analysis of human exposure areconsidered using concepts, methods and tools that are common toboth areas of risk assessment.

The IRSN believes that it is essential that the method used to assess
the risk to the environment from radionuclides should be consistent
with that used for chemical substances. This consistency is all themore necessary as it is sometimes difficult to separate radiotoxicity
and chemotoxicity in some particular cases of internal exposure.
Moreover, current environmental monitoring strategies are notsufficient to provide an accurate determination of the causes ofenvironmental changes that may be observed both temporally andspatially. This strengthens the case for consistency between thevarious assessment methods.

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The main principles//of the proposed method for environmental risk
assessment and the new scientific understanding thatwill be needed
Environmental risk assessment as developed for chemical substancesis traditionally carried out in the following four stages:• Identification of hazards.
• Analysis of exposure.
• Analysis of effects.
• Characterization of the risk. In its simplest form, this consists of acomparison of the actual exposure with predefined limits (quality
criteria, limits derived from specific studies, etc.).
The most important, detailed aspects to be considered when applying
this process to radioactive substances are:
• The reference to doses or dose rates received.
• The need to consider both external and internal exposure pathways.
• The absence of normalized tests for determining the ecotoxicity ofradionuclides.

Present knowledge of the effects of ionizing radiation on fauna andflora is mainly concerned with gamma emitters. Additional research
work is therefore needed to provide a robust determination of thebiological effectiveness of the various types of radiation.

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The development and implementation of laboratory assessment test
protocols is particularly necessary in the case of radionuclides for thereasons stated above. Current ecological monitoring methods are, inthe main, not sensitive enough to enable the effects to be detected.
The IRSN believes that priority must be given to the design anddevelopment of chronic ecotoxicity tests extending over one orseveral generations.

In order to characterize the risk to fauna and flora, it is necessary toquantify the relationships between exposure and effects for eachgiven species (dose-effect relationships). This is the foundation of theknowledge needed in order to develop radiological protection criteria.
These may take the form of absolute or guidance limits corresponding
to conditions under which the risk is negligible. It follows thatparticular emphasis should be given to work aimed at determining
these criteria for radionuclides using clearly described methods.

The ideal situation would be to characterize disturbances at theecosystem level. This is only partly possible, either through studying
the effects on certain species in laboratory microcosms, through theuse of more demanding approaches such as mesocosms, or in situ. Aspart of its ENVIRHOM project, the IRSN is carrying out a program ofexperimental research work on biological effects at both the subcellular level and at that of the individual. Today a modeling approachis being used to study the effects on populations. This approach will
be further enriched as new knowledge concerning the higherorganisation levels of ecosystems will become available.

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5/Consequences//in terms of environmental monitoring
While an assessment is an essential prerequisite for the quantificationof the risk to an ecosystem driven by a given substance, it is also
necessary to carry out follow-up verification that the assessment iscorrect. Environmental monitoring (for example, by comparing theobserved concentrations in the media concerned with the quality
criteria) will be indispensable given the uncertainties associated withmultiple pollutants and the complexity of the various biological andecological levels at which any effects are likely to be expressed. The
IRSN intends to study the suitability of, environmental monitoring
strategies, techniques and associated metrology.

Given the complexity of the situations under consideration, the initialevidence of any correlation between ecological disturbance (forexample, an increase or reduction in biodiversity within a community)
and the concentration of a substance in the area concerned, will
normally be supported by a program of in-depth studies before
concluding on a causal relationship.

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The relationship// of IRSN programs to chose of its
partners
In addition to the work already carried out under the European ERICA
program (6th FP), the IRSN will develop research partnerships and will
also take an active part in the international programs to be managed
by the ICRP (Committee 5 and specific working groups), the IAEA
(who have established a specific action plan), and by the UNSCEAR.
An important aspect of the IRSN participation in these programs willbe the delivery to these organizations of the most recent results
obtained by the Institute from work on the behavior of radionuclides
and their biological effects on living organisms in ecosystems
subjected to chronic exposure, in particular those results arising fromthe ENVIRHOM program. It is also possible that the conclusions
reached by these working groups will result in the reorientation ofsome of the current programs being carried out by the Institute.

The IRSN notes that the work of the European Commission is now
directed more towards the development of a regulatory framework
than towards the discovery of new knowledge. The IRSN recommends
that a more equal balance be struck between this regulatory work andresearch work aimed at improving our knowledge in the fields
described above.

In France, the IRSN recommends testing on pilot sites, incollaboration with the operators and national authorities concerned,in order to validate the operational feasibility of the method
developed by the Institute.

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