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Submitted by Per Drake for Rad Prot Man Vattenfall Nuclear Power Installations, Ringhals AB
   Commenting on behalf of the organisation
Document Recommendations
 
Vattenfall, through the radiation protection managers at its nuclear power plants as well as its radiation protection specialists, takes this opportunity to express its view on the present draft for new recommendations by the International Commission on Radiation Protection.

GENERAL COMMENTS
The present draft provides a clear improvement compared to previous versions. A few general comments are as follow:
1. It should be stated more clearly what the use of constraints may mean in the practical context.
2. The scientific basis for some of the reasoning relating to the weighting factors, risks for radiation induced harm etc in chapters 3 and 4 should be clear. What is necessary is thus an expansion in terms of text as well as inclusion of references or footnotes.

SPECIFIC COMMENTS
§ 30 The last sentence under The principle of optimisation of protection:
The wording is unnecessarily strong: We suggest the inclusion of the word “substantial” (as quoted from ICRP 60 in § 199) - thus: “…as well as any substantial inequity in the distribution of doses…”. For consistency the same change should be made in §185, the last sentence under optimisation.

§72 Table 2 and §114 Table 4 regarding gonad/genetic weighting:
Table 2 gives about 3 % of the total risk as heritable whereas wT (gonads) in table 4 gives a value of 8 %. These two values may indicate an inconsistency but perhaps reflect 5 % being related to cancer risks for testis or ovaries. To avoid any misunderstanding, it would be of value to have a clear statement (footnote is fine) in Table 4 saying something like “In turn 0.05 of this value for wT reflects the corresponding cancer risks”.

§74
This paragraph seems inappropriate for several reasons: it is valid mainly for countries with adequate resources for cancer treatment; it gives the impression that the cancer risk estimates are more accurate than they can possibly be; the intervals between ICRP revisions are relatively short.

§86-87 1 Sv vs. 100 mSv:
In §86 the text includes ”…at doses of the order of 1 Sv…” and a threshold of around 0.5 Sv is mentioned. Then as a conclusion in §87 the dose level of around 100 mSv is mentioned. This discrepancy is not possible to understand. Perhaps a comment should also be made regarding the time aspect (high vs. low dose and dose-rate)

§114-120
We are hesitant about the tissue weighting for breast and the related difference between men and women. Perhaps this deserves to be commented upon.

§127, §131 and §133
We are well aware that the symbols used for effective dose and committed effective dose are internationally agreed: Nevertheless, we find the use of E for effective dose and committed effective dose confusing and therefore suggest that E(tau) in Eq. 4.8 (committed effective dose) is changed to C(tau). A corresponding change then needs to be made in Eq. 4.9 (for the committed effective dose coefficient).
The lack of clarity becomes particularly manifest in §133 in Eq. 4.10 when E gets two different meanings. Thus the structure of Eq. 10 should be: E = H + C.
As a consequence Eq. 4.11 needs corresponding changes.

§148 First sentence:
It is not clear what “very low” means. We suggest some type of comment to the wording of this sentence. Examples of appropriate compared to inappropriate calculations might be useful.

§175
It is not clear what the advantage would be with the “representative individual” vs. “critical group”. Therefore it is not possible to express an opinion at this point.

§197
The first sentence: Replace the word ”process” with the word ”application”: “In all situations the application of optimisation…”. Delete “prospectively” in the third sentence. Change the wording in the last sentence to read “…involving operators and national authorities.” to reflect the fact that optimisation of radiation protection is primarily the responsibility of the operator.

§211
The second last sentence should read “…be fixed at the local or national level.” (see comment to §197). As a last sentence of the paragraph, include the last sentence of §223 (or its essence).

§221
Delete the last part of the first sentence, thus ending with….iterative process.”


§222 The last sentence:
We suggest: ”…should normally reject any protection options…”

§223 The last sentence:
We suggest that this sentence (or its essence) also is included as the last sentence of §211.

§224 The last sentence:
Delete it or rewrite it for clarity!

Table 4 Grouping of dose bands:
We suggest that the range 1-100 mSv is taken as one band (instead of two) as the common denominator for the bands 1-20 mSv and 20-100 mSv is that radiation protection measures are needed with increasing ambition for increasing doses.

Table 5
Avoid the use of bold font in the wording on dose limits, i.e. follow the layout in e.g. § 194 in ICRP 60. The present proposal gives the impression that 20 mSv per year (occupational) and 1 mSv in a year (public) are dose limits and not results of an averaging over 5 years.

§322 The first sentence:
Divide the sentence into two “… individuals. Organisations involved …”

§351-§357 Protection of the environment:
We suggest that it is clearly stated in the text that the scientific basis for this issue is vague and therefore only pragmatic approaches of administrative character can be taken. As this section does not include any recommendations it should perhaps rather be included in the first chapter (as an expansion of paragraphs 19 and 20) where the more general framework is given.

§395 Second last sentence:
According to §166 occupational exposure means “… exposures incurred at work as a result of situations that can reasonably be regarded as being the responsibility of the operating management”. Therefore the sentence “The aim should be to ensure that anyone…” is wrong and should be deleted.

Yours sincerely

Ringhals AB
Radiation Protection Manager



Per Drake

This response has been provided by:
Björn Cedervall, PhD (Radiology Specialist, Vattenfall Power Consultant)
Per Drake, PhD (Radiation Protection Manager, Vattenfall, Ringhals AB)
Monica Gustafsson, PhD (Radiology Specialist, Vattenfall, Ringhals AB)
Staffan Hennigor (Radiation Protection Manager, Vattenfall, Forsmark Kraftgrupp AB)
Carl-Göran Lindvall (Manager Health Physics, Barsebäck Kraft AB)