For a successful integration of nuclear energy in the energy transition, efficient cooperation between industry, universities and knowledge institutes, the government and society is an absolute precondition. If certain developments are wanted by government and society, this stimulates industrial activity, innovation and development. On the other hand, inspiring education at universities and colleges in that field stimulates the formation of a new batch of engineers and scientists, who will find their place in industry, the government and elsewhere in society, and who will act as ambassadors for even more support. If that cooperation goes well, it turns like a flywheel: almost frictionless.

As for nuclear power and the applications of radiation and radioactivity, there are a number of brake pads fitted to that flywheel that currently prevent it from turning properly. In this article, we'll discuss some of those brake pads and how to remove them from the flywheel.
 

1.1 The Dutch authorization framework
is compatible with efficient commissioning of innovative reactor systems

Internationally and within the Netherlands, concern has often been expressed as to whether the "authorization framework", ie the regulations and the supervisory authorities, are ready to allow innovative reactor systems. Our research shows that, certainly in the Netherlands, it is not the regulations that hinder innovation. Research by one of the authors of this article, nuclear safety specialist at the Ministry of Defense, shows that the regulations even seem to meet the basic requirements of flexibility and efficiency.¹

There are, however, some risk factors in the admission process itself. This mainly concerns the shortage of capacity and practical experience at both the government departments concerned and the supervisory authority, the Authority for Nuclear Safety and Radiation (ANVS). These shortages can lead to delays and / or substantial cost increases, while neither of these serve the security of the systems involved. Needlessly slow processes are not conducive to public support for such important developments.

Below we make some recommendations. The follow-up can strongly contribute to an authorization process that meets the international safety requirements set for nuclear power generation installations, while while making sure that the process itself runs efficiently and smoothly.

1.2 Rest in licensing

Taking over reactor designs from other countries.

A reactor system will usually first be authorized in the country of origin. In all relevant cases, this concerns countries that are members of the IAEA, the organization that oversees nuclear safety internationally. If a reactor system in the country of origin has successfully passed all internationally coordinated stages of approval, this offers other countries a safe basis for the approval of the system in question. In real life, it works well if the supervisor of the receiving country is involved from day one with the admission procedure, and is informed by the supervisor of the country of origin.

An undesirable situation arises if the recipient country sets additional or otherwise deviating requirements to the already strict international requirements for reactor systems. Not only does this lead to unnecessary significant cost increases. Such changes are also often used in legal proceedings through which opponents want to suggest that a system does not meet the security requirements.

No significant changes to the approved reactor design, unless demonstrably necessary.
 The above consideration leads to the conclusion that significant changes to the design should be avoided as much as possible. With the exception, of course, of situations in which these are necessary, for example if they are related to the available cooling water or if there is, for example, 'retrofitting' to a specific location.

No interim changes between final reactor design and facility start-up.
 In the past, there have been situations where the government of the recipient country required interim changes to the design of the reactor systems under construction. This is of course disastrous for the costs of the project. It is also destructive to the trust that the builder of the power plant has in a government that acts in this way.

1.3 Licensing based on Module Design Certification

Module Design Certification (MDC) is the certification of the detailed design of the SMR reactor module, including the primary safety systems, whereby this certification is preferably transferable to other countries. With a coordinated and equal admission framework that operates in different countries, international certification can be a huge facilitator for the international acceptance of Small Modular Reactors (SMRs). Separating the reactor certification process from that of site approval is a cost-effective approach.

The Netherlands can put this into practice by offering the expertise of the ANVS internationally to the IAEA. The IAEA can facilitate this and the ANVS can participate in reactor validation processes. In this way, the knowledge of validation processes of specific reactor designs can be taken to the Netherlands – both sides enter a learning curve. Knowledge of the licensing process can then be incorporated into national legislation. With the aim of implementing the acceptance of foreign or internationally agreed (IAEA) codes and standards of reactor designs and the associated reactor design certification system in the Nuclear Energy Act.² The Dutch Nuclear Energy Act (VOBK³) can be prepared by politics for acceptance of Module Design Certificates.

1.4 Risk Informed & Graded Approach

The Dutch Nuclear Energy Act (VOBK, page. 15) states: “The inclusion of the boundary conditions for power reactors is therefore a logical step that goes together with the drawing up of boundary conditions for research reactors. However, the preconditions for research reactors may be applied gradually if it can be demonstrated that they have a smaller potential risk for the environment. A graded approach ("grading") implies the proportional application of certain preconditions depending on the potential risk for the environment. For large research reactors (a few dozen megawatts thermal), the gradual approach may reveal that the preconditions set for power reactors apply accordingly. In addition, it is also possible that a number of preconditions do not apply to a particular research reactor because the research reactor, for example, does not have a pressurized cooling system. Annex 6 of the DSR explains how the graded approach should be applied to research reactors.”

The above quote shows that the Dutch Nuclear Energy Act already provides for what is called a "graded approach" in the international discussion about the authorization framework for innovative reactor systems. In short, this approach means that preconditions for the admission are applied gradually based on the potential risk to the environment. This is an important fact for SMRs, because in the design of SMRs there is a strong focus on reducing that potential risk. Although the passage mainly mentions research reactors, the logic of the approach applies equally well to SMRs.

A recommendation is that it would make sense to add an annex to the Nuclear Energy Act describing how the graded approach should be applied to all aspects of SMRs, other low-power reactors, nuclear barges, and the like. Another possibility is to include a more general annex independent of the reactor design. The permit applicant can probably also come up with a good proposal on how the graded approach can be implemented. But a revision that makes the Nuclear Energy Act less specific would be a more structural improvement.

One of the issues involved in the gradual approach is setting frameworks based on the so-called "Design Based Threats", or the threats associated with the design in question.⁴ The broad and grave scenarios associated with very large power reactors may not all apply to SMRs. Therefore, some threat scenarios can probably be disregarded. A recommendation could be to apply the graded approach here as some scenarios are overkill for certain SMR reactor designs.

As early as 2010, the Cordell Group proposed an approach aimed at limiting the scope of the certification process. This involves separating site-specific approvals from operational requirements. This results in a feasible reduction of the existing differences between the licensing practices of countries.⁵ Similar are Söderholm's recommendations.⁶ Implementation of these proposals could make the permit application process more efficient, reducing the time required and reducing political risk during the later stages of a project. Feedback from stakeholders from various groups can also be considered in revisions to the nuclear regulatory framework. Implementing the said recommendations can lead to a gradual approach to nuclear safety and security, acceptance of the certificates issued for modules (MDCs) and a political decision on nuclear policy laid down in a government decision. In this way, broad public involvement can be assured, as well as the provision of broad support prior to the admission process (Decision in Principle).

The mandatory international consultation for an Environmental Impact Assessment (EIA) of an SMR might not be necessary, under the AARHUS and ESPOO Conventions, as the transboundary effects of an accident involving an SMR are absent. It remains to be investigated whether the graded approach can therefore also apply to the EIA.

1.5 The level of ‘nuclear knowledge’ in the government
must urgently be raised

Over the past ten years, the radiation education institutes, the Dutch Association for Radiation Protection (NVS), the Reactor Institute in Delft (RID), the Health Council, the ANVS and the RIVM have sounded the alarm about the state of radiation education and research. Recently, the Advisory Council for Science, Technology and Innovation (AWTI) wrote an urgent letter.⁷ The question is whether this message gets through to policymakers sufficiently.

In 2020, a report was issued on behalf of the ANVS, drawn up by a committee in that included André van der Zande (former DG RIVM), Carolien Leijen (chair of the NVS, the professional association of radiation protection experts) and Bert Wolterbeek (director of the Delft Reactor Institute). This committee finds that knowledge in the Netherlands in the field of nuclear technology and safety, and that of radiation protection, has eroded to a critical point. The causes are shrinking budgets, disbanded professional groups and the retirement or departure of highly skilled people.

An impulse of many million euros is needed to maintain the current level alone.

1.6 Sufficient research in nuclear engineering and radiation protection?

Many people think that if the Netherlands did not have nuclear energy, expertise in nuclear technology and radiation protection would no longer be needed. Nothing is less true. Numerous sectors are affected by radiation and radioactivity. Consider the application of radioactive substances in hospitals (for diagnosis and therapy) and industry (assessing welding work, measuring asphalt thickness in road construction). In addition, the presence of such materials plays a role in homes (natural radioactivity in building materials and in the soil), the safe operation of mining, geothermal energy, the gypsum / cement / phosphate industry and other applications.

Thanks to the unique properties of neutrons, research reactors contribute to all kinds of scientific fields. In addition to the production of radioactive medicines, they make an important contribution to research into the (crystal) structure of materials, as well as to art-historical research into old paintings and antiquities.⁸

As a modern society, you therefore always need a good knowledge infrastructure and associated facilities with regard to nuclear technology and radiation protection. Moreover, it means that as a country you keep the option of nuclear energy open because a core of specialists in that field continues to exist.

1.7 Sufficient expertise with the government?

Almost every ministry or inspection agency has something to do with the field of radiation protection / nuclear safety and technology. Still, the government does not seem overly concerned that knowledge and research on these topics is eroding. This has two main causes:

1. The fact that in most ministries this is a “small” topic, with no more than two policy officials working on it part-time. They often also have to cover a wide range of other subjects.
2. The fact that knowledge is eroding in the professional departments, often to the level that they have difficulty formulating the right questions for the knowledge institutes.⁹

The following departments and inspections play a relatively modest role for radiation protection, nuclear safety and technology:

• State Supervision of Mines (SodM/SSM): Inspecting mining in which radioactive materials play a role, such as oil and gas extraction and (deeper forms of) geothermal energy.
• Ministry of Education, Culture and Science (OC&W): stimulating research and shaping the National Science Agenda (NWA). Neither nuclear technology and safety nor radiation protection have ever been a theme in this department.
• V & J / NCTV / AIVD / MIVD: National security, including radiological and nuclear terrorism.
• Ministry of the Interior (BZK): The Building Decree, including regulations on the radiation levels that building materials may emit.
• Ministry of Foreign Affairs (BuZa): Keeping track of the international obligations of the Netherlands, including the Euratom and OSPAR treaties, and treaties in the context of nuclear weapons tests (CTBTO), weapons of mass destruction (UN Security Council resolution 1540), and GICNT (Global Initiative to Combat Nuclear Terrorism).

The following departments are particularly important for nuclear energy, research reactors and related research:

• Ministry of Economic Affairs and Climate (EZK): stimulating a good economic climate for the energy sector, stimulating research and innovation.
• Ministry of Infrastructure and Water Management (I&W): policy in the field of the environment (waste policy) and the risks for the public, maintaining the Nuclear Energy Act and associated regulations and by-laws.
• Ministry of Health, Welfare and Sport (VWS): research into radioactive medicines and the reactors that produce them.
• Ministry of Social Affairs and Employment (SZW): setting rules for employees.
• Ministry of Defense: driving development within nuclear energy based on their own main tasks and needs.
• Authority for Nuclear Safety and Radiation Protection (ANVS): issuing permits and enforcing laws and regulations.

2 Rest in policy

Two things play a major role in the nuclear sector: radiation protection and continuous improvement. Below these is a third principle: LNT, which stands for Linear No Threshold. Below we briefly explain how these issues are interrelated and how they affect the nuclear industry.

2.1 Radiation protection

Radiation protection is based on the following principles: Justification, Optimization and Dose Limits.¹⁰

Justification is about whether you can apply radiation (ethically) in society at all. Our regulations are clear about this: generating energy through nuclear fission is justified.

Then it is important to optimize the exposure to radiation. The word ALARA (As Low As Resonably Achievable) is often used in this context. Socio-economic factors must be taken into account. Many people confuse ALARA with “as low as possible”, but it is precisely by taking socio-economic factors into account that an optimal exposure level is created, below which lowering the exposure even further is no longer useful, nor desirable.

The dose limits are there to protect the population (1 mSv per year) and employees (20 mSv per year) against a high radiation dose caused by licensed activities. These values ​​have been established internationally. Exceeding those limits is equivalent to a violation of the law.

2.2 ALARA and Linear No Threshold: recipe for continuous improvement?

In the nuclear industry, the principle of continuous improvement is also of paramount importance. The concept in its current form (Plan-Do-Check-Act or PDCA) was developed by Deming in the 1950s and contributed to the success of Japan's post-war industry.¹¹ This thinking has also been adopted by the nuclear industry, but in terms of reliability and safety.

While ALARA is mistakenly seen by many people as a “race to the zero millisievert”, continuous improvement is mistakenly seen as a “race to the top”. The PDCA cycle applied to non-nuclear business operations (efficiency in production) has a natural “brake”: the costs for the efficiency improvement must outweigh the additional returns. But security can always be improved and is “priceless” in the eyes of many people, which means that people lose sight of the fact that what is “safe” is also linked to socio-economic factors. Safety should also be based on an optimization principle, sometimes referred to as SAHARA (Safety As High As Reasonably Achievable).

2.3 The Linear No Threshold hypothesis

The Linear-No-Threshold hypothesis states that radiation gives a risk of cancer, and that the chance increases linearly with the dose: twice the dose, twice the chance. In particular, according to LNT, there is no threshold value below which the probability becomes zero. In principle, even the smallest amount of radiation could lead to death, which is statistically virtually impossible.

According to ICRP¹² LNT is a conservative model that can be used for comparisons of two different approaches to a particular activity with ionizing radiation. The way in which (according to LNT) the smallest amount of dose is received is then preferred.

Evidence for the linear behavior can be found in the high dose range (100-1000 millisieverts). But science is inconclusive about what happens below 100 millisieverts. Note that the dose limit for the population (1 millisievert per year) is a factor of 100 below the limit, about which science can make statements. Note also that the radiation level of 1 millisievert is comparable to the natural radiation level that every person on earth receives.

2.4 Consequences for standards

In practice, the principle of proportionality has been lost in the nuclear safety requirements. There is often no optimization, but only the aim to achieve the highest degree of safety and lowest radiation dose (after all, LNT). While socio-economic factors play too small a role in the whole.

In addition, there is a broader trend in our society: that of increasingly rejecting any risk (see e.g. current affairs such as the discussion around PFAS and the discussion around Tata Steel), instead of seeking a compromise between benefits for the economy and society, and possible disadvantages for local residents.

In the case of nuclear energy, the danger perceived by the public is much greater than the danger assessed by experts, as a result of which politicians will be inclined to impose requirements on the level corresponding to the emotion of the population rather than the level corresponding to the ratio of the experts.

Finally: deriving norms involves a number of thinking steps, in which models are also used. The uncertainties in those models and in those other thinking steps are all estimated conservatively. Viewed across all thinking steps, this leads to an “accumulation of conservatisms”, making the final answer (the norm), “for security reasons”, very much stricter than necessary to achieve the desired level of protection.

The desired level of protection itself can also be questioned. Do the (safety) requirements imposed on applications of radiation and nuclear energy provide the same level of protection to the population as is required from other branches of industry?

In other words: are the standards set for nuclear energy in proportion to the actual risks?

2.5 A non-testable hypothesis as a basis for regulation

The Linear No Threshold hypothesis has sparked heated debates among radiation experts in recent decades. Internationally, the use of the hypothesis is firmly anchored in the role of the International Committee on Radiation Protection (ICRP). Opponents of the rule, such as the British Wade Allison, argue that the ICRP ignores the numerous indications that LNT does not agree with scientific insights from the past decades in, for example, molecular biology.¹³ There is continuous discussion about LNT. Geraldine Thomas, researcher of UNSCEAR (The United Nations’ scientific committee that investigates the health effects of nuclear accidents, most notable those in Chernobyl and Fukushima), sighed in response to a question about LNT: "Please avoid theories that cannot be tested".¹⁴

Currently, the application of LNT and ALARA within the nuclear sector, and within the field of radiation protection, is generally not seen as problematic.¹⁵ People are used to working under this very strict standard, and many see it as 'conservative', in other words: it is nice that this standardization builds in a considerable safety margin.

But the undesirable effects of these standards do not occur within these communities. The effects of over strict regulations emerge in exceptional situations, such as in the accident in Fukushima. In an article on "Medical and biological consequences of nuclear disasters" in the Dutch Journal of Medicine, Stalpers, Franken and Van Dullemen describe the consequences of this event.¹⁶ After an extensive and detailed explanation of the (minor) effects of exposure to low doses of radiation, and a consideration of the much lesser effects on the public and nature as a result of radiation that the Chernobyl disaster had, the authors describe the much larger damage caused by the social and psychological effects of the accident. After the accident "… many workers and local residents were shunned like lepers. None of the workers recovered from acute radiation sickness ever found work again. Depression, anxiety syndromes, abortus provocatus, divorce, physical neglect, alcoholism and cirrhosis of the liver, smoking addiction and cardiovascular disease deaths were increased without direct correlation with the level of radiation exposure."

After the accident at Fukushima, the consequences were similar. In its reports on the consequences of the accident, the UN scientific committee (UNSCEAR) that investigates the accident at Fukushima states that the accident did not lead to radiation deaths among the population. Neither does the UNSCEAR expect radiation related impact health impact from the accident, because personal doses received were simply too low for such impacts. ¹⁷ However, according to official figures from the Japanese government, the number of deaths resulting from the large-scale evacuation was already in the hundreds after a few weeks. A few years later, as a result of effects similar to those described above for Chernobyl, there were several thousand.

Of course, the ICRP is not responsible for these unwanted side effects. However, the LNT rule does make a strong suggestion of danger from low doses of radiation. Several anti-nuclear organizations misuse the rule as a "death calculator." The authors of the article quoted above show how this works. If 100 people are exposed to a (high) dose of 1000 millisieverts, it has been statistically determined that 5 more people will die from cancer than the average 30 that you would expect in any group of 100 - over their entire life. The LNT rule states that if 100,000 people are exposed to a (low) dose of 1 millisievert, an additional 5 will also die, but now compared to the average of 30,000 that you would expect in a random group of 100,000. Of course these would be 5 too many, but the problem is that such an effect can no longer be determined. Anti-nuclear organizations apply the LNT rule to very large groups of people, resulting in large numbers of supposed victims of, for example, "Fukushima". Incidentally, the ICRP explicitly states that such calculations are an improper application of the LNT hypothesis.

We already knew that radiation in low doses cannot simply be converted into a higher mortality probability, because there is a large variation in the natural background radiation in the world, without this leading to a proportional variation in the incidence of cancer. The article by Stalpers and his colleagues cites the examples of the Denver area (Colorado) and the Massif Central in France where the radiation amounts to 3.5 millisieverts per year - more than three times what the Dutch citizen receives on average per year. On the beach near Rio de Janeiro (Brazil) this rises to 6 millisieverts, and in the province of Minas Gerais (Brazil) to 20 millisieverts and locally even 120. In none of these areas is the risk of cancer demonstrably increased.

Many radiation experts therefore argue that LNT could better be replaced by another starting point for radiation protection. In their article, the aforementioned authors argue in favor of starting from the so-called LQ, or the linear quadratic model. This model is not based on (inconclusive) health statistics, but on the (medical-biological) observation that DNA damage can be repaired by the cell after a low dose of radiation, and also on the observation that error-less DNA repair decreases whith higher radiation doses.

In other areas too, LNT leads to consequences that have an impact on other aspects of social life. For example, mining for certain raw materials is complicated by the very strict guidelines resulting from LNT. For example, mining for certain rare earths (a group of substances that plays an important role in modern electronics and renewable energy production) is known to produce mining waste that exceeds the standard for radioactive waste, requiring it to be stored as radioactive waste. This poses a costly risk to mining companies. The Eurare study carried out by the European Union suggests that this plays an important role in the lack of mining for these materials in the Western World.¹⁸ In the development of geothermal energy, too strict radiation standards may also play an obstructing role.¹⁹ In geothermal energy, the natural warmth of the earth is utilized by drilling deep holes, where cold water is injected, heated and the hot water is pumped up. The dissolved radionuclides²⁰ from the deeper crust of the earth are then carried along in the pumped warm water and create radioactive deposits (scaling and sludge) in pumps, filters and pipes.

The discussion has so far not produced a better, more workable model that all parties can work with. In the short term, questioning LNT will probably not yield such an advantage that a lot of energy will now have to be invested in this. However, it is important to ask this question, especially now that it seems that nuclear energy will play an increasingly important role in the future - and society will have to come to a new relationship to a subject that has often led to unrest with at least a part of the population.

3 Peace in society -

4 take a proactive approach to the discussion about disposal

A final recommendation is, as soon as the social discussion about nuclear energy becomes serious, to also enter into a discussion about the usefulness and necessity of realizing a disposal facility for long-term radioactive waste. Such a conversation is already being prepared by the Rathenau Institute, which is preparing a report on which one of the authors of this memorandum has provided feedback.

The COVRA (Central Storage for Radioactive Waste) has a permit that allows it to store the long-lived waste produced above ground in the reinforced facility it has built in Borssele (Netherlands), until the end of this century. There is nothing technically wrong with that: the waste is there safely and an important technical advantage of aboveground storage is that the heat production of the waste can decrease sufficiently to make it suitable for disposal. But there is also a socio-cultural aspect to this choice: such a term can give the impression that things are being postponed in the long term.

One of the authors, in a commentary on the Rathenau draft report, expressed support for starting the decision-making process on disposal. After all, the waste is already there and experiences from other countries make it clear that this decision-making is complex and takes a lot of time.

Broadly speaking, we see here two possible routes that could be put forward in the discussion.

1. The Netherlands will stop with nuclear energy. In that case, participation in a Belgian disposal facility would be the logical choice. It might even be possible to do this without adjusting treaties by choosing a border location and connecting a Dutch corridor to a Belgian disposal facility.

2. The Netherlands will continue with nuclear energy, possibly in the form of generation 4 reactors. If the Netherlands makes this choice, it makes sense to enter into a discussion about the advantages and disadvantages of the Netherlands having a nuclear disposal facility of its own. Such a conversation, in which internationally shared scientific insights have a place in addition to the sociocultural aspects that also deserve attention, can form a prelude to the revitalized ecology of knowledge referred to in previous paragraphs.

1 Tjerk P. Kuipers, Developing nuclear security related legislative guarantees in licensing mobile Small Modular Reactors (Master thesis, University of Applied Sciences Brandenburg, augustus 2020) https://opus4.kobv.de/opus4-fhbrb/frontdoor/deliver/index/docId/2662/file/MiNS_Master_Thesis_KUIPERS_pub.pdf
2 Or in the or in the Bbs (Besluit basisveiligheidsnormen stralingsbescherming/ Decree on basic safety standards for radiation protection). In Dutch Legislation the Bbs is a General Administrative Order (AMvB-Algemene Maatregel van Bestuur), which gives further substance to the Nuclear Energy Act (2018), zie https://wetten.overheid.nl/BWBR0040179/2018-07-01.
3 VOBK (Veilig Ontwerp en het veilig Bedrijven van Kernreactoren/ Safe Design and Safe Operation of Nuclear Reactors) is the name of the Dutch Nuclear Energy Act. See eg.: Ambtshalve wijzigingsvergunning ogv de Kernenergiewet verleend aan NV Elektriciteits-Produktiemaatschappij Zuid-Nederland t.
4 DBT: Design Basis Threat, zie bv. Design Basis Threat (DBT) | IAEA.
5 CORDEL Group. (2010). International Standardization of Nuclear Reactor Designs. London, UK: World Nuclear Association.
6 Söderholm, K. (2013). Licensing Model Development for Small Modular Reactors (SMRs) - Focusing on the Finnish Regulatory Framework. PhD Dissertation.
7 Advies: Rijk aan kennis - Naar een herwaardering van kennis en expertise in beleid en politiek
8 Straling bij kunsthistorisch onderzoek
9 Kennis en beleid verbinden - praktijkboek voor beleidsmakers, Wim Derksen, Boom Lemma uitgevers, 2014, EAN 9789462360235. Zie voor een boekbspreking hiervan bv. http://www.beleidsonderzoekonline.nl/tijdschrift/bso/2012/09/BELEIDSONDERZOEK-D-12-00015.pdf.
10 The 2007 Recommendations of the International Commission on Radiological Protecten, ICRP publicatie 103 (2007), zie ICRP Publication 103.
11 Zie PDCA.
12 The 2007 Recommendations of the International Commission on Radiological Protecten, ICRP publicatie 103 (2007), zie ICRP Publication 103.
13 Wade Allison, professor emeritus of radiation physics at the University of Oxford, has written several books about this, including ‘Radiation and Reason’ en ‘Nuclear is for Life’.
14 https://www.unscear.org/unscear/en/index.html
15 A thought experiment: suppose we are going to adapt LNT and apply a personal dose limit of a maximum of 100 mSv per year for population and personnel, the T (hreshold) theory. What would be the profit that we achieve with that? The VOBK already applies ALARA and in this case only partially, with a minimum dose of 100 mSv per year. Below this limit, measures are then no longer necessary, such as shelter (intervention value 10 mSv) in the event of an off-site incident, smaller zones can be planned around a nuclear power plant and only very rare events (low event frequencies à la F <10-4) are yet to be somewhat avoided.
16 Medische en biologische gevolgen van kernrampen’, Nederlands Tijdschrift voor Geneeskunde, 2012-156:A4394 - Academisch Medisch Centrum, afdeling Radiotherapie, Amsterdam; Dr. L.J.A. Stalpers, radiotherapeut-oncoloog; dr. N.A.P. Franken, radiobioloog, Leids Universitair Medisch Centrum afd. Veiligheid, Gezondheid en Milieu; Drs. S. van Dullemen, docent stralingsbescherming.
17 United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), rapport over gezondheidseffecten van ‘Fukushima’: https://www.unscear.org/unscear/en/fukushima.html
18 Eurare: EuRare Project | Home.
19 Masterplan Aardwarmte in Nederland (Microsoft Word - 20180529 Masterplan Aardwarmte in Nederland v11.docx (ebn.nl))Microsoft Word - 20180529 Masterplan Aardwarmte in Nederland v11.docx (ebn.nl) worden
20 Naturally Occurring Radioactive Material (NORM)