|Comments from NPP Beznau (HP-Chemistry-Radwaste dep.), Switzerland
Compared to the previous version the draft was significantly improved. Some additional developments are desireable to improve on high radiation protection performance for occupational and public exposure and to bring radiation protection to a reasonable excellence.
Dose constraints and dose
For us a dose constraint is a tool for the dose optimization process and should be in the responsibility of the stakeholder (e.g. the nuclear industry). This is not made clear enough in the current text. We therefore strongly recommend clarifying the use of dose constraints.
We further expect that the Commission defines the principles of dose constraints. The responsible stakeholder should have the flexibility to set numerical values adequate to its specific context for all situations.
The only key values of protection should be the dose limits. This would reduce the risk that dose constraints become de facto new dose limits.
LNT hypothesis adopted by the ICRP is certainly a very reasonable approach and excellent tool for RP personnel. But you should give an advice due to the limits of using LNT. Adding a small risk of dying to a large number of individuals leads mathematically to a certain number of deaths. Please mention in your paper that doing so would be the wrong way!
Otimization and justification
The draft contains no lower bound for optimization and justification. This leads to the impression that optimization has to reach zero. This is not compatible with the ALARA principle and will lead to confusion. We recommend defining a lower bound for optimization and justification and to base radiation protection practice consequently on the ALARA principle.
Radiation protection of the environment
There is no need for a new standard for radiation protection of the environment.
NORM and existing situations
The application of radiation protections standards to NORM situations often lead to confusion. If the corresponding stakeholder would be responsible for an adequate constraint to a specific NORM situation, the necessary flexibility of the radiation protection system would be maintained even for a big variety of natural background.
Beznau, September 15th, 2006