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ICRP: Free the Annals!

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Submitted by VĂ©ronique Decobert, AREVA
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
AREVA is pleased to provide its main review comments on the ICRP's proposal for the evolution of the
radiological protection. We appreciate this opportunity for providing our comments during this consultation
process: It is essential that every stakeholder, regulator, nuclear industry member, manufacturer, medical
field member and others, clearly understand the need and the reason for the proposed changes in the
radiological protection system.

We understand that the proposed definition of dose constraints, was introduced to simplify the radiological
protection system and allow quantifying the fundamental level of protection for workers and the public from
single source in all situations. However, the result is not so obvious.

Profound changes to the foundations of ICRP's system will occur. We think that the 3 key principles of
radioprotection must be kept and enhanced : Justification is disgraced and Optimisation and Limitation are
mixed in the new definition of dose constraints that are either an aim or a limit. Consequently, the
simplification goal of ICRP's system is not reached, it is difficult to understand when dose constraints are
used and in which situation dose limits shall be adopted : accidents and emergencies, and controllable

In the same way, for public exposure, the introduction of the principle of dose constraints for single sources
as a complement to the dose limit (e.g. 1 mSv/y) seems only appropriate in the context of practice. But
setting numerical values for dose constraints at ICPR level would be unnecessary, each situation would be a
specific occurrence.

We agree that dose constraints must be lower than dose limit but it is not necessary to introduce numerical
values decided by the regulators, for an optimum optimisation process these values must be operational and
not regulated. In our point of view :
-Regulators decide of the need of an activit y or of a practice (Justification), and adopt limits values
before the implementation (Limitation).
-The manufacturer or the physician, in charge of this activity, establishes target values to optimise the
occupational dosimetry and the public exposure much lower than the limits (optimisation).

Since 1965 with the publication of the ICRP's recommendations 9, good results have been obtained in
occupational dosimetry with the practical use of the present system of protection. Optimisation (ALARA
principle) is achieved without imposed dose constraints that in fact would become new lower limits.

The definition of the source is not clear enough for a correct implementation of the source-related dose
constraints. Knowing exactly "what is a source" is the key point to determine any value of dose constraints in
occupational situation.

We welcome the fact that ICRP propose in these new recommendations a continuous function to determine
the neutron radiation weighting factor. This is a true improvement compared to the 1990's recommendations.
We also notice the decrease of some tissue weighting factors such as the gonads weighting factors in
application of new scientific data.

In conclusion our ma in concern is the issue of dose constraints that may be determined by the regulators
even in practice context. Nevertheless, we appreciate that these new recommendations are in continuation
of the 1990'5 recommendations, as a sign of stability in regulatory system .