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Submitted by Dr. Carl J. Paperiello, Independent Nuclear Consultant - Certified Health Physicist
   Commenting as an individual
Document Recommendations
Section 4.6, "Uncertainties and judgements," presents a serious problem. I would hope, that before the ICRP publishes new internal dose conversion coefficients, it continues to engage in the type of stakeholder involvement it has engaed in with the establishment of these new recommendations. The regulatory assessment of many potential exposures from some practices is dominated by internal dose. These include most forms of waste disposal and effluent discharges from major nuclear facilities. The uncertainty in the overall assessment most be known. Currently, this is being done (perhaps less than perfectly) for the other parameters in the assessment models for these facilities. These uncertainty assessments are frequently based on "monte carlo" sampling of parameter distributions. There needs to be a similar assessment of the uncertainty in the internal dose coefficients. In addition, where parameters are based on expert judgement, there are expert elicitation methods developed and used by the United States Nuclear Regulatory Commission for Probabalistic Risk Assessment that allow the development of uncertainty estimates.

I believe, if the models used by ICRP and the computer codes used to implement them were made available to the stakeholders, along with the basis for the parameters in the models, researchers in the US, as well as in other countries, could make estimates of uncertainty. Furthermore, if such a programme were run simular to the "Open Software" model (LINUX is an example), a mechanism for continual improvement of the models could be established. This would also help in the education of a new generation of radiation protection experts.

Section 7.4, "Constraints for radon in dwellings and workplaces," needs to explain why the constraints on radon are an order of magnitude above the constraints on potential exposure of the public. Radon exposure dominates both the highest collective dose and the highest individual dose in both the United States (NCRP Publication 93) and the world (UNSCEAR 2000). Furthermore, radon control in dwellings, at least in the US, is relatively inexpensive in most cases. The cost of reducing dose from licensed nuclear facilities in the US is much more expensive per dose saved than the same money spent on radon reduction. This section needs to explain why the constraints are not lower.

ICRP is to be commended for its efforts to involve stakeholders in its activities. I do believe this review of recommendations is warrented.