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Submitted by Daisuke SUGIYAMA, CRIEPI
   Commenting on behalf of the organisation
Document Radiological Protection in Geological Disposal of Long-lived Solid Radioactive Waste

Radiological Protection in Geological Disposal of Long-Lived Solid Radioactive Waste


Reviewed by CRIEPI


Central Research Institute of Electric Power Industry (CRIEPI) is a Japanese nonprofit foundation to undertake research and development activities related to energy and environment.


CRIEPI has reviewed the draft ICRP report ‘Radiological Protection in Geological Disposal of Lon-Lived Solid Radioactive Waste’, and understand that the document will be a good step to update and consolidate previous ICRP recommendations related to long-lived solid radioactive waste disposal, by applying the 2007 ICRP system of radiological protection.


Our comments below on some issues are given by members of Radiation Safety Research Center of CRIEPI. We hope these could contribute to improve the report.



1. General comments


Clear description of the concept of ‘oversight’ should be needed to employ it in the radiological protection system.

‘Oversight’ is introduced in this report as a new term. For a good understanding of the concept, it should be effective to carefully explain it by contrasting ‘direct oversight’, ‘indirect oversight’ and ‘no oversight’ with known words of ‘active institutional control’ and ‘passive institutional control’. Although paragraph (36) states ‘Another type of passive control that may continue after the direct oversight ceases is provided by memory or records of the presence of a geological disposal facility or other measures decided by the authorities in interaction with the different stakeholders, however for a much shorter timescale’, it is not understandable why the concept of ‘oversight’ is necessary and why the concept of ‘oversight’ superseded ‘institutional control’. Again, clear description of the concept of ‘oversight’ should be needed to employ it, to be established as a basic concept and to make it meaningful in the radiological protection system.


Description of an individual receiving a dose to be assessed for existing exposure situation and for emergency exposure situation is desired. Recommendations for radiological protection from radioactive waste management in existing exposure situation will be also a necessary update step.

Although reference levels for existing and emergency exposure situations are recommended in the report, the representative person as the endpoint for exposure has documented only for planned exposure situation. The representative person could be defined for existing exposure situation, with some modification of the concept.

In addition, recommendations for radiological protection from radioactive waste management in existing exposure situation should be prepared by integrating the discussion on endpoint considerations in this draft report. It could contribute remediation of environment in long-term contaminated areas resulting from either a nuclear accident or radiation emergency.



2. Specific comments


[4.4] For paragraph (64), we propose a revised test;

The stepwise decisional process for geological disposal facility development and implementation constitutes the framework for the optimisation process. As a central component, optimisation has to cover all elements of the disposal system in an integrative approach, i.e. site (incl. host formation), facility design, waste package design, waste characteristics as well as all relevant time periods, by application of Best Available Technique.

The application of Best Available Technique is not just an element of the disposal system. It should be employed as an overall and comprehensive concept in the optimisation process.

(Line 141: best available technology -> best available technique)


[5.2] For paragraph (86), delete ‘offers on one hand a challenge for waste management which is at least similar to the challenges of demonstrating compliance with dose/risk standards; but, on the other hand, also’.

Assessment of risks and doses for the long-term radioactive waste disposal should not be regarded as a forecast of detriment, but could provide an indication of whether the repository is acceptable given current understanding of the disposal system. The application of an approach using dose/risk standards to the protection of Reference Animals and Plants are still under discussion and we have not reached a consensus on it. Therefore, for waste management, it is not appropriate to recommend the challenges of demonstrating compliance with dose/risk standards for Reference Animals and Plants.