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Submitted by Vandenhove Hildegarde, Belgian Nuclear Research Centre
   Commenting as an individual
Document Environmental Protection - Transfer parameters for Reference Animals and Plants
Hello, I just give it a start without decent introduction ... no time at the moment. Friendly.

General comments

I understand ICRP intends to create a simple and straightforward system of protection, limiting itself to a restricted number of RAPs for which in this document transfer parameters are presented.
With this gross simplification of the environment to 12 RAPs (omitting key species in the food chain as e.g. invertebrates) and the consequent extremely reductionist approach in environmental risk assessment, the overall usefulness and credibility of the approach is, in my opinion, at stake.

Following this reductionist approach in the collection of transfer data, only collecting transfer data for selected RAPs, also narrows the possibility and the adequacy of data gap filling. If data would also be collected for herbs these CR would very likely be the better surrogate CR for RAP-grass; CR for reptiles could be adequate CRs for RAP-frog, CR data for goose or swan would perhaps provide good candidate CRs for RAP-duck for which there are actually no data etc.

Allusion is made in the document on a similar exercise conducted by the IAEA. I think for interested stakeholders it must be very confusing to find so different CR values in both documents. Why do we have a CR for U of fish of 21 in the ICRP document and of 110 in the IAEA document; a Ba-CR value for fish of 20 (ICRP) vs a value of 180 (IAEA). The basis is for sure a more restrictive approach in data collection by the ICRP, but the stakeholders will they know which values to select/apply?

It is further clear that the data are far more abundant in the IAEA database than in the ICRP database. The vast majority of the CR data had to be derived using a combination of data gap filling methods which in the end will result in CR values which very unlikely a touch of realism.

IAEA has also launched a very large campaign asking people to contribute with data, followed by a QA/QC of data entered. Why has ICRP/IUR not launched such demand? Moreover, there are contributors that are involved in both the ICRP and IAEA data collection. So why this difference in datasets and resulting CRs? Even for specific species (here limiting ourselves to grasses since terrestrial plants is more my domain of expertise) there is more data out there than what is presented actually in the document. I volunteer to hand over to ICRP the SCK grasses and herbs CR database that was also handed over to IAEA. And even the database SCK provided is unlikely complete wrt CR to grasses – I assume that there are still non-included references that appear in the grass-TF database from TRS-472 (but to which we do not have access). So, if interested, send me an email and I will forward mentioned SCK database (established with help of SCK colleagues G. Olyslaegers, J. Wannijn, M. Van Hees and L. Sweeck).

In the ICRP document, no mention is made on QA/QC analysis of data. For example for the U and Ra-CR data to grasses, CR data from tailings are included: these CR are very unlikely ''average'' and should they be included?

CR are defined for whole-organisms. No mention in document which conversion factors were used to convert organ CR (e.g. fish CR data are often for muscle) to whole organisms CR.

Maybe the annotation of references will still be looked at, but there is a lack of consistency. E.g. (dummy examples)
Johnson M.J. vs Johnson M J vs Johnson MJ
NRPA (2005) vs NRPA (2005).

Detailed comments
Reading (54) leaves the impression that there are a lot of CR data available but actually there is a majority of data gaps filled with analogy approaches resulting in unlikely very robust CRs. Will the variability introduced by the fact that it is an emergency situation compared to a situation considered in equilibrium add more variability or uncertainty to the CR than the applied data gap filling methods would?

Remark to table 3.1: as already mentioned: there are still a large amount of CR data for ''comparable'' organisms out there which could have contributed to more robust derivation of CR data.

L920: elsewhere (not eslewhere)

Table 4.1. and Table 4.2
Title – perhaps add per Bq kg-1 soil)
Why ?? for K? Should K be included in the database? It is an omnipresent natural radionuclide considered in homeostatic equilibrium.
Annotations under table – some start with capital, others with small caps – should be made uniform (this remark holds for all tables)

Table 4.2.
Grasses are perhaps the most research species and so little TF.
Unbelievable not to have grass-CR values for Sr.
Some strong examples of discrepancy between IAEA and ICRP (and no judgment which values are the more robust – but imagine the stakeholders going through both documents in search of the optimal value; consultants having to justify their choice in CR towards the authorities) Se-CR: 83 (IAEA); 0.1 (ICRP); Am-CR: 0.1 (IAEA), 0.002 (ICRP).

(84) talks about the relative abundance of data for earthworms (CR for 18 out of 40 elements exist) which can be interpreted as slightly contradictory to sentence 1196-1997.

(89) Here is a clear example of problems in data gap filling caused by the reductionist approach to only collect CR data for a given RAP, in case Duck. ICRP only CR for 4 elements, IAEA for 11). Same for (92) There are likely some data for other amphibians, reptiles which cannot be used as analogue for Frog since not collected.

Table 44
Why ?? for K, La?

Some detailed remarks on Table A1.1. Other tables I did not evaluate.

Table contains a lot of Canadian (?) AREVA data (ref 334 and 344) which is linked with U-mining exploitation – adequate reference.

334 and 344 both point to AREVA 2000 and just one reference to AREVA 2000 in ref list

I presume that there are more CR-grass data for Cs than in the reference by Dowdall et al 2005 (272)

Reference 291: title refers to terrestrial animals – adequate CR-grasses in?

References 266 and 291 are for U-mill tailings – does this provide adequate, acceptable TFs?

Ref 287 – no name given

Table A.1.2.
In all table a "." is used, here a ",".