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Submitted by Christepher McKenney, U.S. Nuclear Regulatory Commission
   Commenting on behalf of the organisation
Document Reference animals and plants
The U.S. Nuclear Regulatory Commission (NRC) staff appreciates the opportunity to review and
offer comments and observations on the International Commission on Radiological Protection
(ICRP) Committee 5 draft report, “Environmental Protection: The Concept and Use of
Reference Animals and Plants.” We continue to applaud the ICRP for providing draft reports for
consultation and comment.

The NRC staff appreciates the clear and careful cautions included in Chapter 6 stating that the
Derived Consideration Levels are not intended to be dose limits, or substitute values. The NRC
staff strongly agrees with these statements. We urge the ICRP to continue to clearly articulate
this viewpoint. We also urge that ICRP clearly affirm that the objective of this effort is not the
creation of new standards or requirements.

The NRC has a well established system for considering environmental impacts to non-human
species associated with its regulatory and licensing decisions. This system is derived from the
requirements within the United States under the National Environmental Policy Act, and
includes consideration of the full spectrum of possible impacts from regulatory decisions. The
NRC staff has therefore examined the draft ICRP Committee 5 report in the context of
this system.

The draft report provides a useful step in summarizing the current state of knowledge of
radiation effects in various animals and plants. As such, the majority of the report contains
scientific and technical information, and the NRC staff does not have many specific comments
to offer on this material. It is important to note that there are many areas, for many of the
suggested reference animals and plants, where there is little or no information on radiation
effects and there is currently no method to extrapolate radiation effects to other nonreference