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ICRP: Free the Annals!

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Submitted by Masami Ikai, Tokyo Electric Power Company
   Commenting on behalf of the organisation
Document Rehabilitation
 
The representatives of 9 electric power utilities, using nuclear energy, discussed the ICRP draft report on the gRehabilitationh, with the representatives of Japan Atomic Power Company (JAPC), Japan Nuclear Fuel Limited (JNFL) and Central Research Institute of Electric Power Industry (CRIEPI).
The following comments were prepared based on their discussion.

1.General Comments
This draft report on gRehabilitationh is sure to be a significant guide describing details of the implementation on the commissionfs recommendations for emergency exposure situations in the 2007 Recommendations of the ICRP, Publication 103.
Therefore, the report on gRehabilitationh needs consistency about radiological protection with the ICRP, Publication 103. Especially, with regard to the optimization of radiological protection, the report should describe more practical measures to reduce radiation dose after a nuclear accident or a radiation emergency from various points of view.

2.Specific Comments
(1)Equity
For paragraph (8), (25), (30), (33), (38), (49)
Comment: The gequityh in existing exposure situation should be deleted from this report or be clearly described in this report.
Reason: There is no line describing about gindividual equityh as the purpose of the optimization of radiological protection in existing exposure situation in the ICRP, Publication 103
(2)Band of Reference level
For paragraph (48)
Comment: gi.e. close or equal to 1 mSv/yh should be deleted from this paragraph.
Reason: There are some cases where it is not reasonably achievable to reduce the radiation dose rate to 1 mSv/y if radioactive contamination occurs in a wide area after a Nuclear Accident or a Radiation Emergency.
Various measures to reduce radiation dose will be applied as goptimization of radiological protectionh after a nuclear accident or a radiation emergency.
Therefore, regarding the optimization of radiological protection after a nuclear accident or a radiation emergency, the report should describe more practical measures to reduce radiation dose from various points of view without emphasizing gReference levelh too much.