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Submitted by Lips Marcel, Goesgen nuclear power plant
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
The system of protection

The system of protection in the 2005 recommendation is based on the natural background radiation. This is a reasonable approach. However, my point of concern is, that the definition of the natural background radiation is incorrect. Even if the radon component of the natural background is enhanced by human activities, it can't just be ignored completely. Moreover, the wide range of natural background radiation in some parts of the world (like for example Kerala or Tamil Nadu in India, Esposito Santo in Brasil or Ramsar in Iran, whose population should be relocated according to table 7) have not been taken into consideration.

The definition of natural background radiation has to be reworked as well as the derived dose constraints. Furthermore, the ALARA (as low as reasonably achievable - social and economic factors beeing taken into account!!!!!!!) principle should be considered uncompromisingly. It is not worth to produce social and psychological harm to people, who can not pay for the renewal of their houses due to slightly enhanced radon concentrations, just to come up with new scientificly questionable recommendations.

Exclusion levels

Exclusion levels for radionuclides are very helpful, but these levels should be based more on a nuclide specific toxicity. According to table 10 for example 3-H as an artificial Beta emitter has been put on the same level as 90-Sr. On a scientific basis, this is incomprehensible.

Furthermore, any specific levels should be reviewed on the basis of justification. For example one has to intake an amount of 2 tons of a material containing 3-H at the exclusion activity concentration level of 0.1 Bq per gramm to get an effective dose of 0.01 mSv - the minimum value of any constraint.

I strongly recommend the commission to rework the exclusion levels.


The involvement of stakeholders may be helpful. But the stakeholder definition as "a party who has interest in and concern about a situation" is unacceptable. Neverending, non scientific discussions on the operations of nuclear power plants are the result, causing unnecessary costs. The stakeholderdefinition should be reworked, to reduce the resulting discussions on astrongly scientific basis