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Submitted by VP SINGH, NUCLEAR POWER CORPORATION OF INDIA
   Commenting as an individual
Document Occupational Intakes of Radionuclides Part 1
 
I am very happy to find new document with revision and including new finding in Radiation Protection. I have reviewed the document and giving some comments which may be helpfull for finalising the document.

General:
The accidental management of exposure for various radio-nuclides needs to be documented which will be helpfull to all nuclear facilities to follow written proceudres/guidelines to manage accidental exposure. 

Page No: 108, Section: 5.3:
1) The categorization of the occupational workers needs to be addressed to assess the internal dose monitoring program. In Indian NPP, for tritium internal dose monitoring the workers are categorized in Category-A (more prone to tritium) and Category-B (less prone) to monitor the internal tritium contamination as well as optimization for bioassay sample analysis. In Category-A: weekly sample submission and Category-B: monthly one minimum.

2) Additional concept for other than tritium i.e. gamma emitter’s internal contamination monitoring may also be explores as Category-A (more prone like fuel handling group) and Category-B (less prone). Category-A: quarterly and Category-B: once in year.  
 
Page No: 112, Section: 5.5:
  Internal dose record for individual nuclides must be one parameter of Radiological Performance Indicator to control internal risk by radiation. This statement may be added in the document.  
 
Page No: 112, Section: 5.5:
This state may be added “The removal of radio-nuclides from individual’s body, medicine interruption in activity measurement, effect of medicine on individual’s dose estimation and any abnormal pattern of radioactivity variation in the body must be documented which will be helpful for accidental situations”.

 
Page No: 112, Section: 5.5:
   Each facility must have facility specific biological half-life, removal pattern of nuclides, interference of medicine intake for excreta measurement for nuclides (like tritium measurement is interfered by medicine intakes or increase in luminescence in the sample) workers behavior against the exposure.

 Page No: 117, Section: 6.3.1:
Various approaches for dose estimation (exponential, average etc) are available. Please give reference for the same as well as address the uncertainty involved in each type of measurement. If possible write also best suitable fit for various cases.

  Page No: 118, Section: 6.3.1:
Mid-point method may be valid in many cases however in a very acute intake of tritium midpoint will overestimate amount of tritium activity in the body and then committed effective dose. 

   Page No: 118, Section: 6.3.2:
It has been found exposure/contamination through wound, but it is better to mention that “Personnel with any wound” are not allowed in nuclear establishment. The statement may added in the commision's document.

  Page No: 118-119, Section: 6.3.3:
The default particle size of the various nuclides may be added in the appendix. As tritium is one of them a major source for exposure in form of vapor, gas, particle size.

  Page No: 123, Section: 6.3.4:
More details for chronic tritium exposure, measurement and data analysis may be given with references.

  Page No: 136, Section: 7.1:
  Radio-nuclides specific description must be included in the chapter to explore more information for personnel involved in the dosimetry.