General comment, could be connected to 3.3.1 and Para (54):
As mentioned at several occasions in the document, radiological protection and the system of RP are normally not the primary health and safety concerns of NORM industries. One can therefore not assume that many of the readers of this document are familiar with the RP terminology. In order to avoid confusion between dose limits and reference levels, which is often the case and where RL:s are perceived as limits, the document should introduce one or two sentences explaining the difference between reference levels and dose limits and pointing this out, possibly in Para (54).
NORM as existing or planned (several paragraphs but in particular Para 58):
For a regulator it is very difficult to see how a practice which in many cases receive licensing for other reasons than RP, and where the work activities are (or at least should be) well planned, should not be seen as a planned exposure situation. This is also how the International Standards and the EU legislation have chosen to tackle the regulatory aspects of NORM industries. ICRP does however still see NORM industries as an existing exposure situation. In that light the wording of Para (58), line 627 is not surprising but still less favourable to us.
Line 627: “…not unacceptable…” should be changed to something along the lines of “beneficial” or “adequate”. The rest of the sentence mentions well characterised sources and established programs for RP protection and we fail to see why the same RP protection measures as for other practices should not apply, incl dose limits.
Other:
Section 2.2: The title of the section “The NORM cycle” gives the impression that there is one cycle for all NORM and that NORM commonly is part of an (endless) cycle. Recycling of residues or by-products could be the case, but just as often it isn’t. Therefore rethink 2.2 and put this either as one or two paragraphs under 2.1 or clarify the text, possibly with examples of different variants of the so-called cycles.
Para (32): Why use the same structure of Para 176 of ICRP 103 without using the same text? If the document wants to elaborate on the almost definition-like text of Para 176 in ICRP 103, this should be clear to the reader. If not, the wording of Para 176 should be used (quoted) as these three terms are fundamental in the present RP system.
Para (49) and (51): In Para (49) ICRP points out that optimisation is the driving principle for selecting actions for protection of the environment. A bit further down in Para (51) the text says “The optimisation process should consider protection of the environment”. We cannot decipher how this should be interpreted. If the meaning of “consider” in (51) is “include” then please change to this word, otherwise please clarify.
Para (135): Delete sentence “However, experience shows….” Connect sentence 2 and 4: “… protection purpose. However, the Commission recommends…. attitude, based on the risk assessment.”. The wordin of sentence 3 (which we propose to delete) conveys a rather pessimistic way of looking at the issue. A realistic and pragmatic attitude should be based on risk assessment, not on a notion that the RP system is perceived to be “very specific and …difficult…”. The sentence also somewhat contradicts what is written in Para (69) which mentions that because these industries normally have health and safety protection measures, RP and HSE measures could be integrated. It is also our opinion that for practices where the undertaking is adequately handling health and safety issues, RP measures are more easily introduced.
Editorial:
Line 291. Should it be Appendix or Annex?
Line 698. …authorities set a derived…
Line 701. …, if radiation mitigation …