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Submitted by Peter Webster, British Energy Generation
   Commenting as an individual
Document 2005 ICRP Recommendation
Comments on 2005 Recommendations of the International Commission on Radiological Protection - Draft for Consultation

British Energy Generation operates 15 reactors across 8 nuclear licensed sites, generating some 20% of electricity within Great Britain. As its Director of Safety and Regulation, I welcome the opportunity to respond to this set of fundamental ICRP recommendations.

Aim and Principles

I support the general aim for a clear, consolidated set of recommendations to update those made in over a decade ago in ICRP 60, and I am reassured that the ICRP has not found reason to change the dose limits set out there. This supports consistency and stability in the regulatory regime.

However, I am concerned that the new emphasis on dose constraints has not been sufficiently thought through and clearly explained. This means that their potential benefit in advancing the practice of radiation protection may be more than outweighed by weakening of the existing well understood focus – on justification, optimisation and limitation as key principles, and the maturing approaches to goal-setting and self-regulation – that has been remarkably effective in reducing both occupational and public doses.

The explanation of what constraints are and how they should be set is unclear, with real risk that the distinction between constraint and limit will be confused by both industry and regulators. Allied to this, while the emphasis on involvement of stakeholders within a strengthened safety culture has clear potential benefits, I am concerned that it may not take account of regulators’ need for independence. Furthermore, the recommendations are notably lacking in practical guidance on how constraints should be derived.

In sum, there is a clear need for a foundation document to set out the ICRP’s thinking in detail.

Exclusion of Radiation Sources

Again, the treatment of exclusion and exemption levels is not as clear and rational as is necessary. This is an area where adoption of a ‘lowest common denominator’ approach, poorly supported by technical justification and yet removing the scope for regulators to take into account risk and benefits as well as hazards, may have very substantial economic consequences.

Effective dose

The recommended change in terminology to radiation-weighted dose adds to clarity and is acceptable, though I see no need to change the specific named unit. The proposed radiation and tissue weighting factors are acceptable, while the introduction of a continuous function for the radiation-weighting factor for neutrons is practical and helpful but should not be used for retrospective dose calculations and assessments.

Protection of non-human species

Again, there is the risk that introduction of an approach poorly explained and supported by technical justification may have very substantial economic consequences – and yet also be unsatisfactory to ecological and environmental scientists. I suspect that the ICRP’s thinking is as yet not sufficiently developed to be crystallised as firm recommendations.