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Submitted by André-Claude Lacoste, Autorité de Sûreté Nucléaire
   Commenting on behalf of the organisation
Document Recommendations
 
ASN Comments on the new draft recommendations of ICRP (RP 06)

General Comments

ASN is very pleased to note that ICRP has significantly amended the previous draft and we feel that the current draft is broadly improved.

The clear mention of the three principles (justification, optimisation and limitation) is welcome. However, for ASN a last review of the draft should be still needed before publication (see comments below).

The present radiation protection system is efficient and it could be concluded that there is neither need no hurry to change the present radiation protection system.

Justification - The principle of justification previously applied to practices, applies now to “any decision that alters the radiation exposure situation”. This definition is very general and could mean that any decision, whatever it is, has to be justified, the judgement of the justification “falling on the governments or government agencies” (see (190). Some emphasis may be put on the possible contribution of stakeholders in helping the regulator to make a decision on justification, as it is the case for optimisation.

Optimisation - Section on optimisation and dose constraints remains too much detailed and not very clear. For ICRP, the dose constraint seems to be a starting point for optimisation of radiation protection ; for ASN, it should be only one element of the process of optimisation : for occupational exposures, dose constraint is an optimisation tool for operators, while in certain circumstances, for public exposure, dose constraints could be used by the regulator, for example when the source-related dose contributes for a large part to the individual-related dose moving it close to the dose limit. For regulators, the use of dose constraints must focus on very specific situations but not extended to all situations involving radiation exposures. For example, ASN thinks that dose constraints are not needed for reducing activity levels of radioactive effluents from power plants ; the application of the optimisation principle is sufficient.

Limitation - The principle of limitation of maximum doses : delete the word “maximum” (see 30).

Exemption - On ASN’s opinion the use of a single and generic guidance value for exemption such as 10µSv is a source of confusion likely to make it more difficult the task of regulators and the message of safety culture they try to convey to operators. Indeed, regulatory requirements are not only based on health criteria. This is the case, for instance, for radionuclide discharges of nuclear installations for which the “close to zero” addition of artificial radionuclide or ‘BAT concept (Best Available Technology)’ drives the regulatory approach. If the exemption criterion based on a dose of 10 µSv would be applied, radioactive discharges of most of nuclear installations could be exempted. The existence of a guidance value makes it more difficult for regulators to justify, for instance, the decrease of discharge permits down to actual discharges.

ASN would therefore suggest to replace the guidance value of 10µSv by a guidance such as “ a few thousandths of mSv” less likely to appear as a threshold value than a single numerical value.

Addition of artificial radionuclide in foodstuffs - On the same ground as above, the reference to generic exemption criteria for radioactivity in foodstuffs trivializes the likely presence of artificial radionuclide in foodstuffs, whatever the situation and the origin of these radionuclide. Adding that these levels may be acceptable only under certain conditions (post accidental situation, limitation in time, …).



Editorial comments

(75) express the risk coefficient as 5.10-2 Sv-1 to be consistent with the text and table before and with the international unit system
(178) move the last sentence to (180)


(294) wrong reference to Chapter 10

Miscellaneous comments

The glossary has to be reviewed : some terms are not yet used in the document (for example, annual limit on intake, derived air concentration) and other ones are missing.


(170) Delete the definition of “a radiation worker” which is a new one, unused later in the document.
(179) as a self sustainable document, this document should not make reference to a document that is not yet published

(198-233) Too detailed and not clear.

(204) Delete last sentence which is not clear.

(207) A constraint applying to the total dose to an individual from all sources is not any more a constraint; it is a limit. This paragraph introduces confusion.

(210) In a non prescriptive regime, the dose constraint should be selected by the operator and submitted for approval to the regulator, but the prime responsibility for safety lays with the operator, hence his responsibility for choosing dose constraints. Moreover, the operator will be more likely to comply with a requirement he has himself decided than to a requirement imposed by the regulator. Clarification to be added also in 232.

(237) Keep only the value of 20 mSv per year and delete the possibility of averaging over 5 years : feedback has demonstrated the feasibility of limiting the effective dose to 20 mSv per year for occupational exposure.

(263) Make clear which doses are pointed out.

(269) Delete or extend to more examples such as screening for security purposes, aging…

(284) Add some text relating to cosmic radiations dealing with aircrew and astronauts.

(289) “Such industries have not always operated completely within the Commission’s system of protection. Steps should be taken to bring these existing facilities within the Commission’s system. These sentences seem to place the ICRP recommendation at the level of basic safety standards. Reference to regulatory authorities in this context would be more appropriate. Line 11, para 289, after “Commission’s” add “recommended” before “pubic dose limit”.

(294) Justify the numerical values, at least by a reference. Moreover, make clear to which doses these concentrations lead under which scenarios.
(313) reference to a doc to be published should be avoided.

(332) Delete this paragraph, not relevant in ICRP recommendations document.