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Submitted by Shinji Mitani, Japan Nuclear Energy Safety Organization
   Commenting on behalf of the organisation
Document Foundation docs Optimisation; Dose to Individual
 

@In the paragraph (9) of this draft it is described that guidance for the protection of future individuals in the case of disposal of long-lived radioactive waste is provided in ICRP Publication 81(2000a). However, Pub.81 and other existing relevant ICRP documents including this Fundamental Document are not necessarily be satisfied at present for the prospective assessment of geological disposal of high level radioactive wastes(HLW). When this Fundamental Document is going to be applied to the geological disposal which ought to include a variety of uncertainties in the result of consequence analysis implemented in a time period of hundreds of thousands of years or more, it should be strongly recommended in the Fundamental Document that it be explicitly described that an interpretation of the results should be made in a fully cautious manner considering the high degree of the influence of relevant uncertainties to the consequence.
The evaluation of the safety on the geological disposal cannot help containing uncertainties related to events and processes of radionuclide release from buried HLW, radionuclide migration through engineered and geological barriers, human diet and life style, and the scenarios other than groundwater scenario, etc. Therefore, improvement of interpretation on a final consequence could not be achieved even if how to assess doses of the Representative Individuals would be made in more details as shown in the Fundamental Document, because such overall system of assessment including those uncertainties and relevant issues have been@broadly accepted.