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Submitted by Sylvain Saint-Pierre, World Nuclear Association
   Commenting on behalf of the organisation
Document Recommendations
 
September 15, 2006


Lars-Erik Holm,
Chairman
ICRP, Stockholm, Sweden

Subject: WNA comments on the ICRP draft proposal for its next recommendations (June 2006)

Dear Lars-Erik:

We appreciate this opportunity to provide our comments to ICRP on its draft proposal for the next recommendations.

We have also appreciated the ICRP open consultation process that was launched shortly after the publication of this draft. In particular, we believe that the two workshops that ICRP and OECD/NEA organized in Tokyo (in July) and Washington (in August) were fruitful.

As a result of the Tokyo workshop we were pleased to send ICRP our initial follow-up suggestions (see WNA letter dated July 20, 2006). We understand that the main outcomes from the North American workshop closely mirrored those in Japan.

On this basis, please accept the WNA July 20 letter as the formal WNA comments for the on-going ICRP open consultation process that is closing today. We would like to emphasize that these WNA views are supported by our senior nuclear industry executives and RP experts.

Overall, we thank ICRP for this significantly improved draft. However, more improvements are necessary, especially in relation to the six (6) key outstanding issues that we have highlighted in our July 20 letter.

In conclusion, we urge ICRP to undertake another round of consultation on an updated draft that reflects resolution of these key issues. This would contribute to re-assure industry senior executives of the adequacy of the next recommendations before they are finalized.

We suggest that ICRP further reflects on a reasonable time schedule and process for finalizing the changes that it is proposing. We would see shortcomings in attempts by ICRP to finalize its recommendations quickly. Moreover, further referral to IAEA RASSC/WASSC for an in-depth examination by the Member States would be very helpful in assessing the adequacy of the recommendations before finalizing them.


We would like to draw your attention once again to the real need for the evolved RP system of the 21st century to help improve public understanding of the risk from ionizing radiation. We see this as essential and fundamental, especially for improving public decisions.

We believe that the ICRP draft proposal (June 2006) would fail to help people better understanding how simple common situations (such as those shown in Table 1of the WNA July 20 letter) at very low doses are dealt with in a coherent and consistent manner. In fact, the level of complexity alone that is built in the proposal can possibly increase the public misunderstanding. We urge ICRP to seriously consider this issue in the development of its recommendations.

We believe that the evolution that we are proposing (see Figures 1-3, 5 of the WNA July 20 letter) would make the RP system more coherent and consistent, thus making it conducive to improving public understanding and decisions.

We hope that ICRP will seriously consider the option of continuing to move prudently forward through a further improved draft and consultation stage, and through referral to IAEA RASSC for an in-depth examination by the Member States of the potential practical implications. This process would significantly increase the chance of a successful and satisfactory outcome.


Sylvain Saint-Pierre
Director for Environment and Radiological Protection

c.c. IAEA RASSC and WASSC Chairs and Secretariats, the related IAEA head personnel, and RASSC’s co-sponsor organizations.

Attachments:

WNA July 20 letter to ICRP (L.E. Holm) and to OECD/NEA (H. Riotte).


*****

July 20, 2006


Hans Riotte,
Director, Radiological Protection and Radioactive Waste Management
OECD/NEA, Paris, France

Lars-Erik Holm,
Chairman
ICRP, Stockholm, Sweden

Subject: Initial Follow-Up Suggestions to the Recent OECD/NEA Asian Workshop (July 5-6, Tokyo) as Part of the ICRP Consultation

Dear Hans and Lars-Erik:

Congratulations to both of you for having put together this important and successful NEA Asian workshop (July 5-6, 2006, Tokyo) as part of a series of three World Regions’ (Asia, North America and Europe) workshops all scheduled before the end of October 2006.

We believe that the Asian workshop was extremely useful for getting early feedback on the most recent ICRP draft proposal (June 2006) of its next recommendations and that many participants also share this view.

We recognize that, without this significantly improved ICRP draft proposal (June 2006), such a successful workshop would simply not have been possible. We thank ICRP for the excellent progress made.

Among many other positive things, the early feedback points to a few key outstanding issues and to a related set of suggestions for resolving these issues. These should be very helpful to ICRP in re-shaping a further improved version of its draft proposal that should ultimately get all parties even closer to satisfaction.

To contribute to the smooth and careful evolution of the current RP system, we therefore state below our suggestions for resolving a short list of six (6) key outstanding issues that have been expressed by many stakeholders during the NEA Asian workshop.

Initial Suggestions to Resolve a Short List of Six (6) Key Outstanding Issues:

Issue No.1 Clarify the distinction between dose limits and dose constraints

Issue No.2 Modify the ‘source-related’ approach, the concept of ‘single source’, and the concept of ‘dose constraints’

Issue No.3 Integrate, more clearly, a ‘soft’ lower bound to optimization and to the use of the concept of collective dose

Issue No.4 Remove the recommendation for maximum numerical dose constraints of 0.1 and 0.3 mSv/y for the context of waste management alone

Issue No.5 Clarify the concept of dose constraints for emergency situations and for existing exposure situations

Issue No.6 Provide more factual information on the RP of the environment, and keep the prospective information outside of the next recommendations

These initial suggestions and the related key outstanding issues are explained in Appendix 1 with more details provided in Appendix 2.

Overall Remarks:

The above suggestions are compatible with the current RP system for Practices (or ‘planned exposure situations’) which is widely implemented and recognized as performing well in the worldwide nuclear industry, including the related supporting facilities (such as waste management and disposal sites).

As pointed out by Mr. Sakae Muto (Deputy Chief Nuclear Officer, Tepco), our understanding of the ICRP presentation and through the related discussions at the NEA Asian workshop is that:

· ICRP shares the concern that the proposed evolution of the current RP system for planned exposure situations should not unnecessarily disturb the current RP practices at nuclear industry sites.

· ICRP considers it important to maintain the necessary flexibility that has allowed the nuclear industry to reach its current high level of RP performance for both occupational exposure and public exposure.

· Conscious of the importance of retaining this extensive experience and of continuing to build on it, ICRP recommends that the current RP practices for planned exposure situations (occupational exposure and public exposure) in the nuclear industry continue and that it also encourages other sectors such as the non-nuclear industry sector and the medical sector to develop and use comparable RP practices.

We also understood that with the new proposed ‘source-related approach’, and with the new concepts of ‘single source’ and ‘dose constraints’, the nuclear industry would not have to change anything about what it does already. This is apparently the case because this new approach and these new concepts can be interpreted on a broader level and the well-established comprehensive programs in the worldwide nuclear industry are already compatible with these broad measures.

In principle, we welcome (with reservations) this new “broader level” orientation subject to a careful examination on our part of a further improved draft proposal to be issued later on by ICRP. However, as pointed out by Mr. Muto, we would like to stress the fact that, as proposed, the new ‘source-related’ approach, and concepts of ‘single source’ and ‘dose constraints’ do not necessarily fit well with the current well-established RP practices in the nuclear industry for planned exposure situations, and especially in the context of occupational exposure.

As a matter of fact, on the broad and more specific levels, it is a combination of both a ‘source-related approach’ and an ‘individual-related approach’ that better reflects the reality of the nuclear industry. Both source-related and individual-based dose constraints are commonly used. The overall draft proposal of the recommendations must better reflect this necessary flexibility.

Concerning the concept of ‘single source’, at a nuclear site, current practices use the concept of ‘radioactive areas’ for those site areas in which there are radioactive sources or that are under the influence of such sources. The site as a whole though is not considered as a source. This is particularly important for the classification of nuclear workers with significant implications that go with it: e.g., worker training, monitoring, compensation, etc. There is therefore some potential for confusion in the ICRP draft proposal about what is considered as sources, at multiple levels, for a nuclear site. Mr. Muto also indicated that the concept of single source might hinder the necessary deployment of human resources from site to site. Again, this can have important implications that must be thoroughly addressed in the proposed new approach and concept.

This suggests that ICRP should pay much more attention to the need for a more adequate overall approach and for more adequate concepts that overcome the current shortcomings concerning occupational exposures.

Initial Suggestions for a Smooth and Careful Evolution of the RP system Towards Greater Consistency and Coherence:

We also deem it appropriate to draw your attention to the proposed evolution of the RP system illustrated in the attached Figures 1, 2 and 3, which can help achieve both a smooth and careful evolution, and greater consistency and coherence. This evolution assumes that ICRP will succeed in satisfactorily resolving the six (6) key outstanding issues mentioned earlier.

Figure 1 is the first evolutionary step. It includes the precise numerical provisions for the current dose limits, which help to better visualize the resolution of issue No.1. The ICRP should bear in mind that the (unclear) impression that a dose constraint (single source) cannot be higher than 20 mSv/y (Table 4 of the ICRP draft proposal) departs from the current consensus about the occupational dose limit and that this can trigger the need for regulatory changes. Given that the new ICRP data and analysis on human health risk from exposure to ionizing radiation actually point to a slightly lower risk than originally thought (the basis of the current RP system – ICRP60), it is expected that many countries will not feel comfortable about such changes. This may significantly hinder or delay a potential wide consensus on the proposed next recommendations and on its acceptance.

Figure 1 also shows the scope of dose constraints for occupational exposure in the context of planned exposures (Band 2) and for most emergency situations (Band 3).

Figure 2 is the second evolutionary step. It integrates the ‘soft’ lower bound to optimization and (to) the use of the collective dose in a consistent and coherent manner relative to the concepts of exclusion, exemption and clearance (which have been internationally-agreed through IAEA document RS-G-1.7) and to other common exposures. This helps to better visualize the resolution of issue No.3.

Figure 2 also shows the scope of dose constraints for public exposure in the context of planned exposures (Band 1).

Figure 3 is the end result of this smooth and careful evolution. The graded colour code plays an important role in showing more clearly the relative level of risk. The scope of dose constraints for planned exposure situations clearly ranges from the dose limits down to the ‘soft’ lower bound of the optimization process. Figure 3 also shows all three Bands.

For RP practitioners and for better public understanding, it would therefore be important to modify Table 4 of the ICRP draft proposal in light of Figure 3.

We would like to stress that key Asian RP leaders such as Dr. Kosako (Radiation Council, Japan, and an ex-ICRP member), who flagged up the importance of using the current key numerical values of the RP system, appear supportive of the evolution of the RP system expressed in Figure 3.

A greater consistency and coherence of the RP system is particularly important for significantly improving the public understanding of the risk from ionizing radiation. This can in turn bear significantly on decision-making. This aim was also widely expressed by the Asian leaders during the NEA Asian workshop. As an example, communicating more consistently and coherently about the exposure situations shown in Table 1is warranted and would definitely add value. The evolved RP system must help to achieve this.

This example clearly shows the importance of integrating the concept of a ‘soft’ lower bound to optimization and to the use of collective dose that is consistent and coherent with the concepts of exclusion, exemption and clearance (IAEA document RS-G-1.7) as well as to other common exposures. Also, the lower the dose, the less important the question of accounting for/controlling exposure situations and the question of benefits at the individual level versus those at the collective level.

Moreover, if some kind of a rationale for the maximum dose constraints of 0.1 and 0.3 mSv/y contextual to waste management alone was perhaps possible, Figure 4 clearly shows that it would no longer seem valid. On this specific issue, it is important to point out that at a recent meeting of the IAEA Radiation Safety Standard Committee (RASSC), countries were informed of IAEA document TECDOC-664 (produced in 1992) which may be the only international study of relevance on the particular subject of setting numerical dose constraints for members of the public. (The authors of TECDOC-664 include, among others, key representatives from ICRP, IAEA, and UNSCEAR.) In TEDOC-664, the dose constraints of 0.3 mSv/y seem to have been genuinely presented as a long-range (time and distance scales) prospective example that may have appeared plausible at the time. However, the worldwide experience gained since that time clearly shows that this example is unduly conservative and that there is no trend showing that it will ever materialize.

In all fairness, ICRP should therefore dedicate more effort to helping to resolve this matter as part of developing its next recommendations. Also, given the views expressed by several countries in the context of recent RASSC deliberations on the unclear meaning and basis of such numerical dose constraints at the international level, it is essential that TECDOC-664 gets thoroughly examined as part of the upcoming RASSC activities.

Reducing the gap between how planned exposure situations are dealt with in the nuclear industry and in other sectors (such as for the non-nuclear industry sector and the medical sector) has been expressed by key Asian RP leaders such as Dr. Pan (CNNC, China and a current ICRP member) who stressed the importance of this orientation for the long term. The evolved RP system should allow this to be achieved.

Timing for changes

Although we look forward to a further improved version of the ICRP draft proposal, we noted the apparent incompatible ICRP messages that there is ‘no hurry’ to issue its next recommendations and that it aims to issue them before the end of this year or in 2007. The overwhelming key message from the stakeholders at the NEA Asian workshop was that “It is far better to take the necessary time to get it right [the evolving draft proposal of the next recommendations] than to do it quickly”.

As witnessed during the NEA Asian workshop, there is no clear current common understanding among RP experts and practitioners on essential newly proposed RP approaches and concepts for dose limits, dose constraints, source-related approach, single source concept, etc. This suggests that much more time is required to improve the ICRP draft proposal. ICRP should pay more intention to this serious issue.

At the very least, there is a need for a further improved draft proposal that would take on board the wide range of views and comments expressed as part of the on-going ICRP-NEA consultation, which ends in October. Dr. Pan also seems to see merits in such a further improved draft proposal.

Moreover, as expressed by the South Korean experts (e.g. Dr. Choi, KINS), we agree that once a further improved draft proposal has been completed, it would be worthwhile to seek the views of RP practitioners (regulators and operators) on the potential practical implications before issuing the next recommendations. Perhaps, the best way of doing this would be through IAEA RASSC where ICRP already has a co-sponsor organization role in the context of the on-going review of the IAEA Basic Safety Standards (BSS). Following this process would ensure that the ICRP next recommendations are truly adequate before issuing them. This is very important for all stakeholders.

We thank you for this opportunity to provide our initial input to ICRP on its new draft (June 2006) of the next recommendations. We are committed to providing later on our more refined review comments by the set deadline of September 15, 2006.

We hope that ICRP will seriously consider taking on board the option of continuing to move prudently forward through a further improved draft and consultation stage, and through referral to IAEA RASSC for an in-depth examination by the Member States of the potential practical implications. This process would significantly increase the chance of a successful and satisfactory outcome.


Sylvain Saint-Pierre
Director for Environment and Radiological Protection

c.c. IAEA RASSC and WASSC Chairs and Secretariats, the related IAEA head personnel, and RASSC’s co-sponsor organizations.

Attachments:

*** FOR ALL FIGURES AND TABLES SEE THE WNA WEBSITE: http://www.world-nuclear.org/position/index.htm, under the heading Radiological Protection Working Group. ***


Figure 1 Smooth and Careful Evolution (Step 1) of the RP System Towards Greater Coherence and Consistency
Figure 2 Smooth and Careful Evolution (Step 2) of the RP System Towards Greater Coherence and Consistency
Figure 3 Smooth and Careful Evolution (Step 3) of the RP System Towards Greater Coherence and Consistency
Table 1 Examples of Exposure Situations for which more Consistency and Coherence in the RP System is Warranted
Appendix 1 Explanations on our Initial Suggestions for Six (6) Key Outstanding Issues
Appendix 2 Further Explanations on Some Key Outstanding Issues
Appendix 3 Modified Definition of ‘Single Source’
Figure 4 The Key Issue of Coherence and Consistency of the RP System that Arises if the 0.1 and 0.3 mSv/y Dose Constraints are Kept
Figure 5 Smooth and Careful Evolution (Step 3) of the RP System Towards Greater Coherence and Consistency – Plus Intervention

Figure 1 – Smooth and Careful Evolution (Step 1) of the RP System Towards Greater Coherence and Consistency


Figure 2 – Smooth and Careful Evolution (Step 2) of the RP System Towards Greater Coherence and Consistency


Figure 3 – Smooth and Careful Evolution (Step 3) of the RP System Towards Greater Coherence and Consistency



TABLE 1

Examples of Exposure Situations which warrant more Consistency and Coherence in the RP System


Dose (mSv/y) Exposure Situations Accounted for/controlled Benefits
0.1 One transatlantic air flight Unaccounted for Quick and comfortable travel
0.1 One single X-ray Often unaccounted for Useful medical diagnostic
0.1-0.3 Maximum dose constraint for waste management alone Accounted for and strictly controlled Clean and safe large-scale source of energy
0.01-0.10.01-1 Exclusion, exemption and clearance for (as per RS-G-1.7):-artificial radioactivity-artificial radioactivity (low probability events) and natural radioactivity e.g. recover, re-cycle, and re-use material/waste or dispose material/waste
1 Discharges from the non-nuclear industry sector Often unaccounted for Non-nuclear industry products and services
2-31-10 Worldwide individual exposure from natural background radiation:- average- typical variability Unaccounted for Not applicable


APPENDIX 1

Explanations on Our Initial Suggestions for Six (6) Key Outstanding Issues

Issue No.1: Clarify the distinction between dose limits and dose constraints

At the international level, the key numerical values of protection should be the dose limits alone. As a broad policy, ICRP and IAEA should define the principle of dose constraints whereas local stakeholders (regulators and operators) should have the responsibility and flexibility to set numerical dose constraints that are adequate to their specific contexts. In order to maintain the current international consensus, numerical dose constraints that are more restrictive than the dose limits should be avoided (at the international level) as they can conflict with the above broad policy for setting numerical dose constraints. Moving apart from this would most likely hinder or delay a potential wide consensus on the proposed next recommendations and on its acceptance.

ICRP should also pay more attention to the fact that the (numerical) coexistence of dose limits and numerical dose constraints would raise confusion about what is an acceptable upper bound for an adequate level of human health protection at the international level. This should not be taken lightly as it can bear significantly on the public understanding of the real risk from ionizing radiation and on decision-making in specific contexts.

Issue No.2: Modify the ‘source-related’ approach, the concept of ‘single source’, and the concept of ‘dose constraints’

The outcome should be a more flexible approach and more flexible concepts that can better cover both the ‘source-related’ approach and the ‘individual-related’ approach which are commonly used to adequately address the wide spectrum of planned exposure situations in the nuclear industry. The proposed ‘source-related’ approach, concept of ‘single source’ and concept of ‘dose constraints’ do not necessarily fit well for occupational exposure. This seems to have been overlooked. We see a number of key issues in connection to this. ICRP should therefore pay more attention on the suitability of its approaches and concepts for dealing with occupational exposure.

Further information on issue No.2 can be found in Appendix 2.

Issue No.3: Integrate, more clearly, a ‘soft’ lower bound to optimization and to the use of the concept of collective dose

This “soft” lower bound should be interpreted as the level from which RP measures should be systematically applied, and in turn below which, the lower the dose, the more you need to question the extra gain in protection relative to the effort needed to achieve this gain. The process must also take into account other common types of exposures and risks.

For greater consistency and coherence of the RP system, this ‘soft’ lower bound must also be in line with the recent international agreement on the application of the concepts of exclusion, exemption and clearance (IAEA Safety Guide: RS-G-1.7). In this regard, we would like to emphasize that the proposed use of concepts like ‘unamenable to control’, ‘unwarranted to control’, etc. by the ICRP should be more equitably applied across the whole spectrum of sources, exposures and risks.

The case for a more stringent approach for planned exposure situations in the nuclear industry and a much less stringent approach for exposure situations commonly encountered outside of the nuclear industry is not compelling. ICRP should pay more attention to the fact that this can hinder public understanding of the real risk from ionizing radiation.

Further information on issue No.3 can be found in Appendix 2.

Issue No.4: Remove the recommendation for maximum numerical dose constraints of 0.1 and 0.3 mSv/y for the context of waste management alone

As indicated earlier, recommending numerical dose constraints that are lower than the dose limits is contrary to the ICRP broad policy for setting numerical dose constraints. Moreover, the meaning and the basis for these more stringent dose constraints remain unclear. If their adequacy cannot be supported by relevant international studies (which specifically address optimization, taking into account socio-economic factors on a worldscale), the dose constraints of 0.1 and 0.3 mSv/y should no longer be recommended by ICRP. Figure 4 also illustrates this issue.

Discontinuing the use of the numerical dose constraints of 0.1 and 0.3 mSv/y would not represent an issue. We suggest that ICRP considers dropping out this earlier recommendation. The ICRP’s new way of introducing LNT (as no longer a scientific truth but rather a reasonable judgement call) and the ICRP’s new weighting factor for neutrons are two good examples that illustrate well useful improvements that result from changes in ICRP positions.

Further information on issue No.4 can be found in Appendix 2.

Issue No.5: Clarify the concept of dose constraints for emergency situations and for existing exposure situations

We welcome the fact that ICRP has set-up working groups on each of these two important matters. However, we note that the terms ‘dose constraint’ for emergencies seem in fact more related to post-emergency situations and that the concept of ‘intervention levels’ (which trigger a reaction in case of emergency) may have been overlooked. The concept should be modified accordingly.

Figure 5 integrates ‘Intervention’ (emergency situations and existing exposure situations) more fully than in Figure 3. This is important because it can also help the public better understanding the relative RP effort for planned exposures.
Issue No.6: Provide more factual information on RP of the environment, and keep the prospective information outside of the next recommendations

Re-focus the information on the RP of the environment so that it better reflects the current international consensus that current RP standards do provide an adequate level of environmental protection. Prematurely introducing future plans for potential extra ICRP guidance and recommendations on this particular topic should be avoided. However, it could be addressed outside of the recommendations. ICRP should take good note that key stakeholders (regulators and operators: e.g. in the context of the OECD/NEA CRPPH) have expressed the need to consider environmental protection as a whole and that viewing it from an RP eye in isolation for the rest (e.g. the prevailing environmental stressors) would be ill-advised.

Developing recommendations without considerations for the main environmental stressors that are known to really impact the environment is therefore not appropriate. Moreover, the common understanding is that ICRP thoughts in this matter should be part of the input of the IAEA plan of activities on the RP of the environment which spreads over several years (2005-2009?) and involves several key institutions (e.g. ICRP, IAEA, and UNSCEAR) as well as the participation of relevant representatives from the IAEA Member States.

Concerning the RP of the environment at the IAEA level (context of the disucssions on the IAEA plan of activities on RP of the environment), “There is a consensus on the need for establishing an iterative process to determine the need for, and if necessary, the form and content of, additional or revised standards.” In other words, the case for the need for additional and revised standards is not actually made.

Further information on issue No.6 can be found in Appendix 2.

APPENDIX 2

Further Explanations on Some Key Outstanding Issues

Issue No.2: Modify the ‘source-related’ approach, the concept of ‘single source’, and the concept of ‘dose constraints’

As a matter of fact, on the broad and more specific levels, it is a combination of both a source-related approach and an individual-related approach that better reflects the reality of the nuclear industry. For example, in paragraph 158, it should not only be a matter of a dual ‘assessment’ but also of a dual ‘approach’. (Individual-based and source-based dose constraints are commonly used in the nuclear industry.) The overall draft proposal must better reflect this necessary flexibility.

Concerning the source-related approach, one fundamental problem is that the dose is obviously the result of the source and of the presence/behaviour of the person who is exposed. The latter is particularly important in the context of occupational exposure, and especially in the nuclear industry where a large well managed workforce is the norm. One main concern here is that a source-related approach tends to undermine the important role that staff must play (by their involvement and behaviour) in RP performance.

Generally speaking, the success of radiological protection (RP) in the nuclear industry is based on three components:
· Sources,
· Staff, and
· Administrative measures.

Sources are controlled by design and engineering measures. Establishing a safety culture helps to enhance the safety behaviour of staff. Administrative measures (management systems, programs, work procedures and instructions, etc.) aim to integrate the other two components. Overall RP performance obviously depends on all three components. If one or more of these components gets weaker, the RP performance also gets weaker. As far as occupational exposure in the nuclear industry is concerned, it is clear that safety culture plays a key role in RP performance. This should be fully taken into account in the text of the ICRP draft proposal.

We also noted in particular the following two key weaknesses in the ICRP draft proposal:

· The general description in paragraph 155 that seems more related to public exposure than occupational exposure
· The generalization in paragraph 156 (especially the word ‘unmanageable’) which would be totally incorrect for both occupational exposure and for public exposure.

At this late stage of development, this suggests that much more attention should be paid by ICRP to the need for a more adequate approach and for more adequate concepts concerning occupational exposure throughout the recommendations.

With a view to providing further constructive input to ICRP, we have included in Appendix 3 a modified definition of the term ‘single source’ – even though we sincerely believe that it would be better to keep the concept of ‘dose constraint’ flexible for a better application to sources, individuals, or a combination of both.

Issue No.3: Integrate, more clearly, a ‘soft’ lower bound to optimization and to the use of the concept of collective dose

Concerning risk communication, based on the international RP system, should a normal citizen have grounds for being worried if he learns that he has been exposed to a dose approaching 0.1 mSv/y as a result of the radioactive discharges from a waste management site? Should he be more worried if he learns that he has received twice the comparable dose during a recent transatlantic air flight and also during a recent chest X-ray? Should he be worried and also confused because he learns that countries have agreed that materials containing artificial radioactivity that can result in doses up to 0.1 mSv/y, can be released? Should he be worried and more confused because he learns that discharges from the non-nuclear industry sector that can lead to doses up to 1 mSv/y, can be excluded possibly from control? What about when he learns that the worldwide exposure per individual averages about 2 to 3 mSv/y and that its variability typically ranges from 1 to 10 mSv/y.

The evolution of the RP system must help better address these exposure situations in a more consistent and coherent manner, in a way that improves public understanding.

Issue No.4: Remove the recommendation for maximum numerical dose constraints of 0.1 and 0.3 mSv/y for the context of waste management alone

To further illustrate this key issue, please see Figure 4. It should be noted that the maximum dose constraints of 0.1 and 0.3 mSv/y are applicable to the most exposed group of individuals among the population. This means that the population in general would be exposed to much lower doses. This clearly shows that the value of 0.1 and 0.3 mSv/y are overly restrictive.

Issue No.6: Provide more factual information on RP of the environment, and keep the prospective information outside of the next recommendations

It is important to point out that under the current RP system, environmental protection consists of much more than strictly estimating doses to the public.

Of course, pollution control technologies that have been put in place and improved over time in the nuclear industry address both the protection of the public and of other living things such as animals and plants. The same can be said about the comprehensive Environmental Impact Assessments (EIA) and environmental monitoring programs. On top of this, comprehensive administrative measures such as environmental management systems (e.g. ISO14000) and audits have also significantly contributed to environmental protection.

The bottom line today is that no evidence of harmful effects has been observed in the general environment despite the wide and long-standing use of nuclear technologies. Current RP standards have been and are still adequate to protect the environment from ionizing radiation.

Are we really talking about environmental protection? The clear benefits of nuclear energy outweigh its minuscule and local environmental impact. This must be compared to the multiple environmental stressors that do impact the environment on a much larger scale. For example, consider:

· Climate change due to air pollution
· Chemical pollution
· Urban development
· Agriculture
· Fisheries

Whether radiation effects are one of the prevailing factors that impact the environment remains to be seen.

Regulators and operators do have the responsibility and duty to take balanced and relevant decisions in regulating matters and in implementing measures in their full context – not radiation effects in isolation of the prevailing environmental stressors.

APPENDIX 3

Modified Definition of ‘Single Source’

5.1 The definition of a single source

(160) The Commission uses the term ‘source’ to cover sources of external radiation such as equipment that generate radiation (e.g. radiation generators) and radionuclides (e.g. as sealed radioactive materials and as contained in matters in general), and also, more generally, to cover the cause of exposure to radiation or to radionuclides in radioactive substances, and not necessarily an individual physical source of radiation. For instance, if radioactive materials are released from an installation to the environment, the installation as a whole may be regarded as a source; if they are already dispersed in the environment, the portion of them to which people are exposed may be considered a source.

(161) In the application of constraints, the term ‘single source’ should be used in a broad sense, such as the x-ray equipment in a hospital, or the releases of radioactive materials from an installation. In general a source is an entity for which radiological protection can be optimised as an integral whole. Most situations will give rise to a predominant source of exposure for any single individual, or representative individual, making it possible to treat sources singly when considering actions. Provided that the operator and the regulator both apply the Commission’s broad policies, the definition of a single source is straightforward. Difficulties will arise if the policy is distorted, e.g. by artificially subdividing a source in order to avoid the need for protective action, or by excessively aggregating sources to exaggerate the need for action.

In the case of the nuclear fuel cycle, nuclear power generation and their supporting facilities and sites (e.g. including waste management and waste disposal sites), practical experience shows that a wide range of types and forms of dose constraints, each of them adapted to its specific context, has been used for planned exposure situations. Through various means such as the licensing process, operator’s management systems and comprehensive radiological protection programs that are commonly required, such diversity of dose constraints has been at the basis of the successful implementation of the RP system by the nuclear industry. Conscious of the importance of retaining this extensive experience and of continuing to build on it, the Commission recommends that such current use of dose constraints for planned exposure situations in the nuclear industry continues and it encourages the use of comparable RP practices in other sectors such the non-nuclear industry sector and the medical sector. For this purpose, the term ‘source’ has the broad meaning of ‘site’ or ‘group of sites’ and it is important that the term ‘dose constraints’ is kept flexible so that it can adequately cover the various types and forms of dose constraints that are commonly encountered in the nuclear industry. Moreover, it is important that local stakeholders (regulators and operators) continue, as part of the optimization process, to have the responsibility and flexibility of setting numerical dose constraints that are adequate to their specific contexts. It is recognized that such important task, including taking into account socio-economic factors, cannot be practically carried out in a generic manner at the international level.


Figure 4 – The Key Issue of Coherence and Consistency of the RP System that Arises If the 0.1 and 0.3 mSv/y Dose Constraints Are Kept





Figure 5 – Smooth and Careful Evolution (Step 3) of the RP System Towards Greater Coherence and Consistency – Integrating ‘Intervention’ more fully in Comparison to Figure 3