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Submitted by Chris Murray, United Kingdom Nirex Limited
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Nirex’s response to the ICRP consultation draft ‘2005 recommendations of the International Commission on Radiological Protection’

Thank you for the opportunity to contribute to the ICRP consultation on the draft 2005 recommendations of the Commission.

Nirex welcomes the Commission’s intentions to draw together its recommendations into a single, simplified framework, and would agree with much of the content. However, we feel that the draft document lacks clarity and structure, and the presentation of many of the issues is confusing.

It would be very helpful if the document were to include an early section outlining any changes proposed since the earlier 1990 recommendations document (ICRP60), particularly in respect of changes that might be reflected in the development of international and/or national safety standards.

Nirex suggests that it would be helpful if the document could explicitly set out its relevance to the disposal of radioactive waste. This could be done relatively easily by:

- amending the text at the end of the third bullet in paragraph 164 to read, “Publications 77 and 81 dealing with radioactive waste disposal and disposal of long-lived waste respectively)”; and
- by noting in paragraph 166 that a constraint of 0.3 mSv/year is appropriate to radioactive waste disposal and disposal of long-lived wastes.

The limitations of the use of collective dose estimates when making decisions on the disposal of long-lived wastes could be mentioned explicitly in Section 7.2.

On a point of detail, Nirex would suggest that Table S1 contains an ambiguity, in that the effective dose value of 0.01 mSv/year is expressed as a ‘Maximum constraint’, but also as the ‘Minimum value of any constraint’, together with the preceding statement “resulting national values of constraints normally will be lower than the maximum value”. Nirex’s understanding is that the ICRP would not expect any national value for a constraint to be set at a lower value than 0.01 mSv/year, and it would be helpful if this situation were clarified.

We would be happy to discuss these issues with you in more detail if you wish. If you require clarification about any of the points raised please contact my office.

We would be grateful if you could send us a copy of the outcome of the consultation and add us to any list of interested consultees that you hold. We would also like to be involved in future consultations that you conduct on this and similar issues.