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Submitted by Harold Peterson, Consultant
   Commenting as an individual
Document Recommendations
 
General Comment

This version is a much improved revision of the 2005 Recommendations and accomplishes its objective of providing a clear, coherent and concise system for radiation protection.

Typographic Problem
The font used erroneously substitutes a “?” for a summation sign (Greek Sigma), cf. equations in (S15)
and (198).

Specific Comments
(S4) line 7 – Suggest replacing “as a failure” with “as unsatisfactory, requiring improvement.” This change specifies a remedy that the ICRP draft doesn’t.

(S19) Is an international agreement on discharges necessary or even technically feasible? Doses from radionuclide discharges into the environment do not always have a direct relationship to the source as do occupational doses. The complexity of the atmospheric and hydrospheric dilution processes and bioaccumulation mechanisms make the relationship between environmental releases and dose to the receptor very dependent on the nature of the environment and highly variable from one location to another location. This presents a major difficulty in standardizing releases and keeping uniform risk goals. The Commission should seriously rethink appearing to be advocating uniform release levels or environmental concentrations instead of uniform dose constraints. Suggest revision of this paragraph to:

(S19) The Commission recognises that a consistent and practical system
for radiological protection of the environment is difficult to implement
because the complexity of the atmospheric and hydrospheric dilution
processes and bioaccumulation mechanisms make the relationship
between environmental releases and dose to the receptor very
dependent on the nature of the environment and highly variable from
one location to another. The adoption of reference plants and animals
for these evaluations will provide some degree of uniformity in these
calculations.

(38) line 5 – Suggest adding “independent of dose rate” after “with no threshold” as this assumption is implicit in radiation protection philosophy and measurements.

(112) last two lines – The fact that values (like the risk factors) are expressed as 0.05 or 5 x 10 –2 does not make them equal to 5 %. Percentages refer to a fraction of some larger quantity. The radiation risk estimates are not fractions of some larger quantity.

(143) Why not simplify this concept and end the last sentence after “at work”? The concept of being “under the control of management” does not provide the differentiation desired. For example, it could be extended to include such things as natural radioactivity in the walls of the building (management could relocate the work force).

(166) The last sentence of this paragraph is confusing, probably due to its length. Suggest:

It must be remembered that the chosen constraints are
necessary, but not sufficient conditions for protection.
They must be modified, if necessary, by the process of
optimisation to ensure that doses are ‘as low as is
reasonably achievable.’ This is dealt with further in Chapter 7.

(172) The concept of the critical group goes back (at least) to ICRP Publication 7, “Principles
of Environmental Monitoring related to the Handling of Radioactive Materials,” Oxford:
Pergamon Press (1965) (15). The guidance in that paragraph concerning selection of
the critical group should be repeated.