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ICRP: Free the Annals!

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Submitted by Yoshihisa HAYASHIDA, Japan Nuclear Energy Safety Organization (JNES)
   Commenting on behalf of the organisation
Document Optimisation of radiological protection
Comment 1(Page 44)
ICRP shows the concept of ALARA about public exposures due to releases, and
doesn't discuss the concept of BAT(Best Available Techniques). The idea of BAT
need not be suddenly taken in this report.

Comment 2(Page 45)
When a licensed facility includes several installations or sub-divisions producing
radiation, it should be entrusted to the judgment of the state whether to allocate
dose constraint to each radiation-producing process/device within the licensed facility.

Comment 3(Page 46)
Rationale of the constraint 100 mSv for emergency situations and 20 mSv for
less severe accidents should be provided, in relation to the Foundation
Document "Biological and Epidemiological Information on Health Risks
Attributable to Ionizing Radiation: A Summary of Judgements for the Purposes
of Radiological Protection".