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Submitted by Atika Khan, Nuclear Wsatew Management Organization
   Commenting on behalf of the organisation
Document Radiological Protection in Geological Disposal of Long-lived Solid Radioactive Waste
 


Nuclear Waste Management Organization, Canada


Comments on


ICRP Draft Radiological Protection in Geological Disposal of Long-Lived Solid Radioactive Waste


November 3, 2011


188-190. Choice of the word “developments” is awkward here.  Also “series of developments” implies a sequential set of events, rather than a number of independent possible events.  We suggest using “a set of scenarios” or “a set of design basis scenarios”.


197.  Suggest that a comma would be useful after “radioactive waste”.


198.  The focus on optimization without reference to the other ICRP principles seems incomplete.  It would be useful in the summary to note how the other principles apply but then to indicate the emphasis on optimization for disposal facility design/operation.


208. Suggest a comma after long term


213. “...are in accordance with applicable regulation”, rather than “...are compatible with regulation”.


221.  Typo.  “looses”


218.  Footnote.  The definition of “radiological risk” is important and should be given in this document for completeness without requiring reader to obtain copy of ICRP 103.  Other definitions from 103 are already provided in Annex 1.  In general, there are many terms that need to be defined early for a reader to have a better understanding of the document (e.g. definitions provided in Section 4.3 should also be brought forward as these terms are used prior to these definitions and are confusing due to the lack of definition. )


257.  Use consistent notation referencing “design basis evolution”.  Here it is in quotes, but it is not in quotes in 242 and 190.  “Normal evolution” would be a better choice of words, as it is more generic and does not limit the term to what one may have assumed as the design basis.


279.  The term “non-design basis evolution” is also awkward as it refers to what may not have been included in design basis, even if it was missed.  A better term would be “Disruptive Events”.


287.  Typo in footnote 4, “exisiting”. 


303.  “long-lived” wastes would require special handling for at least  “thousands” of years - reference to “hundreds to thousands years” seems too short.


305 and 334.  The word “function” is starting to take on a more explicit role in repository safety cases.  It would be better to keep it as per line 334 but use another word in line 305.  For clarity, line 305 could be written as “key aspects:  the duration of isolation and containment, and ...”


320.  Grammar.  Several “and” phrases that would be usefully separated by commas.  Suggest:  “containment of the waste, and to protect humans and the environment, for time scales”


330.  Grammar.  Delete “that”


331. Replace retain with contain for consistency with other text.


332.  Delete “thus” and “functional” as these are not needed. 


333. Suggest “human presence” rather than “the presence of man”; both here and in line 573.


334.  Suggest deleting “independent of man” as this point was adequately made in previous sentence.


346. Suggest “...aiding decision” rather than “...decision aiding”


367.  Suggest replacing “This report” with “The present report” so that it is clear that the report referred to is not ICRP 103 discussed in previous sentence.


369.  It would be useful to explicitly state that this present report supercedes other earlier reports (and state which).  Otherwise it is not clear to reader if this report supplements them and they also need to continue to consult the older documents.


371.  This line says that this document is stand-alone presentation of ICRP 103, whereas later in paragraph it states that other reports/issues may be referenced but no details given.  It is very helpful for this document to be a comprehensive summary, such that the reader has the information in one place and only needs to go elsewhere for background or further details.  It is suggested that this principle be applied more rigorously in this document, and further that the last sentence in this paragraph (lines376 to 378) be deleted (it is largely a generic statement anyway).  In fact only a few cases are identified where further information is needed as is noted in comments provided here, and this information can readily be added to this report.


532.  Why is “concentrate” a fundamental strategy?  This would imply that we should be undertaking waste processing to concentrate wastes as a matter of basic design.  The fundamental strategy should be to isolate and contain.  The optimized design may include concentration.   This word should be deleted throughout anyway, as it is not applicable to all situations.


545.  Suggest removing the word “deposition”.


590.  Suggest replacing “At one time” with “At some time”


738 and 812. While the terminology seems to be used extensively in previous ICRP publications, it is not intuitive that “planned exposure situations” apply to accidents.  That is, we are not planning to expose people in considering accidents.  Rather we have recognized and planned for such scenarios in doing design/analysis. 


 742 and elsewhere.  This document mostly uses the order of: Justification, Optimization, Limitation; whereas ICRP 103 has the order J/L/O.  Should they be consistent?


870.  Suggest “....releases are not predictable...”


994 to 996.  This states that dose and risk constraints do not apply to inadvertent human intrusion.  However the summary table in line 279 and line 1004 identify this intrusion as an Emergency or Existing Exposure Situation.  Although these tables do not state any dose or risk constraint for this case, the footnotes to these tables clearly identifies dose and risk constraints for other cases of Emergency and Existing exposures.  A footnote (#5) should be added to those tables for clarity indicating no dose or risk constraint applies to Inadvertent Human Intrusion, consistent with the text here.


1138. Suggest “Integrated” not “Integrative”.


1169. Extra quotes in the title should be removed.


1232-1234. Suggest that it is not necessary to indicate this is an “increasing” requirement, but simply to indicate that ICRP is providing guidance on this topic.  If the sentence is to be included, it should say  “....is increasingly becoming a requirement in national legislations”.


 


Annex 1.  The scope of this report is already stated as bringing the content of ICRP 103 explicitly into guidance for waste disposal (e.g lines 166, 167).  Having done so, this summary of ICRP 103 appears to be largely repeating information already incorporated into the main report and therefore is duplicative.  We suggest that this annex is not needed except for those definitions from ICRP 103 that are not already incorporated into the main report.


Annex 1.  The other information from ICRP 103 that is not presently included anywhere in this report or Annex, but would be useful, is definition of “radiological risk” and also possibly of Table 8 of ICRP 103.


Annex 2.  It is suggested that the detailed repetition of the “first” comprehensive discussion of “potential exposure” in lines 1665 to1731 be deleted, and only the current position as defined in Publication 103 be included here (lines 1736 to 1800).