Foundation docs Optimisation; Dose to Individual

Draft document: Foundation docs Optimisation; Dose to Individual
Submitted by Hiroshi Noguchi, Japan Atomic Energy Research Institute, Department of Health Physics
Commenting on behalf of the organisation

General Comments In the probabilistic assessment, less than about 5 % people are allowed to exceed the dose constraint. This method can be applied to practice or normal situations for a single source. However, in case of applying to an emergency situation where the dose constraint is 100 mSv/y, this method would not be appropriate, because any member of the public might not be allowed to exceed the level. If there are limitations for applying the probabilistic assessment, these should be clearly described in the report. Similarly, in the probabilistic assessment, doses for a few % of the public may exceed the dose limit of 1 mSv/y as shown in Fig. B-2. This may not be accepted in many countries where the dose for the public in normal situations is regulated by the limit of 1 mSv/y. Thus the interpretation for the case of exceeding the dose limit is needed. Specific Comments Page 1, paragraph (7) We agree that one of the main objectives of the report is to update the principles necessary to implement the system so that it is consistent with improved technology. However, there would be other objectives of making the report. To avoid the potential weakness of the critical group concept (p.14, paragraph (65)) could be another important objective of the report, and this should be emphasized. Page 2, paragraph (9) It would be needed to make additional discussion and to describe here about how the concept in this report relates to the critical group concept that was developed in Publication 81, because the description in this paragraph seems to be too simple to understand the relation. Page 19, Table 3 Table 3 summarises the discussion in Section 3, but the section does not refer to the table. Table 3 should be referred to and its contents should be described in the text of the section. Page 10, Section 2.5. Additional explanations for regulators would be required to determine the case where the probabilistic method is preferred to or the case where the deterministic method or their mixture works sufficiently. Page 15, paragraph (75) The sentence gThe Commission allows averaging over a five-year period in evaluating compliance with the dose constraint.h seems to be a new concept. gthe dose constrainth might be gthe dose limit for occupational exposureh. Page 21, Section 4.3. Since the draft of ICRP 2005 Recommendations mentions that the stakeholder involvement plays an important role only in optimization processes, another role of stakeholder involvement seems to be added in this document. Thus the relationship should be more discussed between the decision-making process and the characterization of the representative individual.