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Submitted by Stephan Kistinger, privat
   Commenting as an individual
Document Radiological Protection in Geological Disposal of Long-lived Solid Radioactive Waste

The release of radioactive materials from regulatory control for (normal) disposal and the disposal of long-lived solid radioactive waste have simular characteristic features: A planned activity leads to the consequence, that radioactive substances, being today under regulatory control, will be disposed and (in some future point of time) no more under regulatory control. Therefore there is some correspondence between both cases (release respectively radioactive waste disposal in the timeframe "no oversight"), and similar dose/risk-criteria should be applied (to (38). 

In ICRP 81 the Commission acknowledges a basic principle, that individuals and populations in the future should be afforded at least the same level of protection from actions taken today as the current generation. From this I conclude:

·      For the comparison of the level of protection for the distant future with the present protection level, it is necessary that the exposure estimates for the distant future represent the potential future exposures to a sufficient degree according to current knowledge. This should be expressed in the ICRP publication (to (45))

·        For design-basis evolutions, the health risks caused by additional radiation exposure in the distant future should be limited at least to the level that is actually accepted for the operation of a disposal, leading to a constraint of <=0,3 mSv/a (as in ICRP 81, ICRP 103), or better <0,3 mSv/a. The risks should be so low that they are irrelevant to today''s standards. This should be expressed in the ICRP publication (to (48) and Table 1).

The risk limitation refers to the integral risk caused by all developments that have to be considered in the design of a repository. This should be clarified in the ICRP publication (to (48) and Annex 1, line 1528).

For the design-basis evolutions, not only the risk but also the maximum effective individual dose should be limited for each of the possible developments, without a weighting by a probability (to (48) and Table 1).

Even in the case of non-design basis evolutions in the distant future no situation should occur that would be a radiological emergency situation according to today''s standards and that would make radiological protection measures necessary (to (52) and Table 1).

Inadvertent complete intrusion into a repository should be evaluated in terms of the population with the same radiological scale as other non-design basis evolutions. Therefore the inadvertent complete intrusion should not lead in the distant future to a situation that would be by today''s standards a radiological emergency situation and that would make radiological protection measures necessary (to (58) and Table 1).