1.1 As the regulator of radioactive waste discharges from nuclear and non-nuclear sites in England and Wales, the Environment Agency has a clear interest in the revised version of the 2005 Recommendations of the International Commission on Radiological Protection (ICRP).
1.2 We provided comments on the first version of the ICRP 2005 Recommendations, jointly with UK Governmental organisations. We are pleased to see that many of the comments we made on the first version of the 2005 Recommendations have been addressed by ICRP.
2.0 CONSULTATION COMMENTS
2.1 We welcome the clarity provided in Para. 188 on the principle of justification, i.e. that in a planned situation, justification applies to a generic type of practice, the essential features of which are not dependent on external factors such as the site on which it is carried out.
Uncertainty in dose coefficients
2.2 ICRP has acknowledged that there are uncertainties in the models used to derive radiation dose coefficients which are used for radiation protection purposes. However, ICRP states that the dose coefficients it has published are reference values for fixed model parameters and are therefore not subject to uncertainty (para. 152). This appears to be a somewhat contradictory position. It is important that there is an understanding of the total uncertainty in dose assessments. We request that the ICRP considers providing further guidance, which can be used by regulatory authorities, to help decide how to include uncertainties in the estimation of dose.
2.3 The ICRP 2005 Recommendations have made it clear that, in future, radiation protection for members of the public will be based on the concept of a ‘representative individual’ rather than the average member of a critical group. The ICRP will be publishing a foundation document which provides further guidance on the representative individual. The draft foundation document states that the term representative individual is “the equivalent of, and replaces, average member of the critical group described in previous ICRP recommendations”. However, the ICRP 2005 Recommendations do not make it clear that the representative individual is equivalent to the average member of the critical group. It is important that this clarity is provided, for example in Para. 175.
2.4 The Environment Agency believes that there could be a significant administrative burden arising from a change of assessment methodology, if this clarity of the equivalence of the old concept of average member of the critical group and the representative individual is not provided. ICRP should consider the costs and benefits of a potential change to the methodology.
Protection of the environment and wildlife
2.5 ICRP provided a framework for protecting the environment in the first version of its 2005 Recommendations. We note that ICRP has removed much of the detailed recommendations on the protection of the environment in the revised 2005 Recommendations. We support the development of a framework based on the use of Reference Animals and Plants and it is important that this is included as a central pillar of any future recommendations from ICRP. We encourage ICRP to provide the detailed recommendations that are needed in order to establish a radiological protection system for the environment as soon as possible; also ICRP should maintain an awareness of the developing national and European frameworks as they progress.
For further information on this response please contact Rob Allott, Technical Manager, either by e-mail at email@example.com or by telephone on 01772 714367 (mobile: 07818 015491).