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Submitted by Takatoshi Hattori, CRIEPI
   Commenting on behalf of the organisation
Document Rehabilitation
Comments on the ICRP TG report entitled gApplication of the Commission''s Recommendations to the Protection of Individuals Living in Long Term Contaminated Territories after a Nuclear Accident or a Radiation Emergencyh

The ICRP TG report has been reviewed by the working group in the Central Research Institute of Electric Power Industry (CRIEPI).

1. General comments
This report is intended to serve as a guide for the protection of individuals living in contaminated areas for a long term after a nuclear accident or other situations involving exposure to dangerous levels of radiation; however, expressions that are incompatible with Publication 103 are included and readers may become confused.

2. Specific comments
1) Compatibility with Publication 103 regarding intervention exemption level
It is stated in Paragraph (82) that gThe term eintervention exemption levelf was introduced by ICRP in Publication 82 but is no longer used.h and gIt had the connotation that no action is warranted below this level (enon-action levelf), as opposed to the concept of reference level introduced by ICRP in Publication 103 below which optimisation is required.h However, the intervention exemption level is not negated in Publication 103, and the above sentences should be removed or revised so as to clarify that no further optimisation is needed for existing situations with exposure of 1 mSv/y or lower.

It is stated in Paragraph (f) of Publication 103 that gImportantly, existing numerical recommendations in the policy guidance issued since 1991 remain valid unless otherwise stated.h Moreover, Publication 82 is mentioned in Paragraph (261). However, the intervention exemption level is not issued at all. This suggests that the ICRP concluded that the validity of the intervention exemption level had not changed in Publication 103 compared with that in previous reports. Therefore, the lower limit of the bandwidth of the reference level for existing exposure situations (1-20 mSv/y) of 1 mSv/y corresponds to the intervention exemption level, and the further reduction of the dose by optimization is not required in the dose range with the reference level of 1 mSv/y or lower.

2) Annex C
gAnnex C, 1. Risk of radiation induced cancer deathh is unnecessary because it is a rewording of an existing document. In particular, Fig. C.1 and Paragraphs (C4)-(C6) are inappropriate.

Figure C.1 in Annex C is essentially the same as Fig. C.9 in Annex C of Publication 60, where the evaluation was carried out on the basis of the equation, strength of low dose ~ large population size ~ long duration, which is considered inadequate in Publication 103. It is inappropriate to substantially revive this principle, which has been considered inadequate in the main recommendation, in supporting documents. Even though the principle is needed as a guideline, there is no need to describe it in the Annex. It is sufficient to clearly cite the reference in Publications 103 and 60 and to comment that in the calculation of the probability of fatalities, the principle shown in Fig. C.9 of Publication 60 can be used for convenience to obtain an upper limit or a prudent value, although the general use of this principle is inappropriate, as stated in Publication 103.

3) Editorial errors
p. 26 L. 6: gIAEA, 2005, Safety Guide No. GS-R-1.7.h should be corrected to gIAEA, 2005, Safety Guide No. RS-G-1.7.h