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ICRP: Free the Annals!

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Submitted by Alexandru Rodna, National Commission for Nuclear Activities Control- Romania
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
We support the extension of the concept of exclusion for sources with low activity.
In fact, we have included the concept of eclusion of materials with low activity, low concentration of activity and low surface contamination in our Fundamental Norms for Radiological Safety, issued in 2000.
However we find two problems that make unacceptable your approach:
1. There are more than 5 order of magnitude between different radionuclides producing the same dose of 10 microSv.
2. In the draft Recommendation there are not defined the surface contamination levels.

We consider that, in order to make applicable the 2005 Recommendation, you should introduce exclusion activity concentration for each radionuclide and exclusion surface contamination levels.