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Submitted by Igor Linge, Sergey Kazakov, Sergey Utkin, Nuclear Safety Institute of Russian Academy of Sciences
   Commenting on behalf of the organisation
Document Recommendations
In our opinion, it is necessary to discuss once more the appropriateness of using requirements of radiation protection of biota in an explicit form in the radiation protection system. The appearance of ecological criteria of radiation protection by developing Reference Animals and Plants may lead to serious negative consequences in using atomic energy:

• Essential and unjustified complication of radiation monitoring systems of environment in regions where radiation-dangerous objects are exploited. Modern radiation monitoring systems are directed to collect data which allow to assess conditions of environment by hygienic factors (it is first of all specific activity of different components of biota);
• Complication of substantiation procedures of atomic energy objects safe exploitation. Here problem of adequacy of models and authenticity of assessments of real doses received by population representatives on which permissible radiation effect criteria exist stays unsolved because of a wide variety of sources of radionuclides and ways of dose forming. The question of sufficiency of environment radiation protection substantiation always remains open due to lack of arguments of radiation protection ensuring for all of biota components upon condition that maximum permissible dose regulations are observed only for small part of objects of environment.

Within the bounds of necessity of complement and perfection of present radiation protection system we offer different approach than a Reference Animal and Plant approach. We have shown that advanced interpretation of anthropocentric thesis of radiation protection (protected is man – protected are the biota) and its unification with ecocentric approach to radiation protection allows to eliminate the problem of propriety of its (anthropocentric thesis) using and create radiation protection system which would be clear and – that is the most important thing – similar to present radiation protection system that operates successfully.
The essence of approach suggested is to supplement an “ecosystem – human” model with a certain “virtual human” who use resources of environment with no radiation restrictions (considering the present situation and future expansion of activity). We obtain a total conservatism: in terms of time, space and socially and age-specific status of human.
As to structure of radiation protection substantiation, taking into account advantages of both anthropocentric and Reference Animal and Plant approaches “virtual human” approach allows to reach higher level of abstraction. Essentially the method may be identified as “biospheric” where human loses its preffered position with respect to objects of environment in the view of mental and ethical principles. It is only considered in analysis that human is one of the most radiosensible elements of biosphere. It should be emphasized that “virtual human” radiation dose levels regulations guarantee radiation protection of non-human biota components.
The viewpoint reflects modern scientific and philosophical opinion on society, science and biosphere evolution. It also allows to avoid serious scientific and technological difficulties of changing the way of human and biota radiation protection ensuring.

1. Kazakov S., Linge I. On Hygienic and Ecological Approaches in Radiation Protection // Radiation Biology. Radioecology, 2004, vol. 44, ¹4, p. 482 – 492.
2. Kazakov S. The Principles of Radiological Quality Assessment of Water Resources // Radiation Biology. Radioecology, 2004, vol. 44, ¹6, p. 694 – 704.
3. Kazakov S., Utkin S. Principles and Methods of Water Body Radiation Conditions Assessment under Different Water Consumption Variants // Preprint / Nuclear Safety Institute RAS, January 2006, ¹ IBRAE-2006-01, 19 p.

Igor Innokentyevich Linge
Sergey Victorovich Kazakov
Sergey Sergeevich Utkin