|Comments on the ICRP foundation document draft: "Optimisation" is reviewed by Working Group of International Issues(WGII), the Japan Health Physics Society (JHPS)
The five foundation documents provide no replies to the numerous comments(200 reports)@submitted in response to the previous yearfs consultation (no replies are given in these documents). The ICRP should provide answers in a specific form, not in the form of the five foundation documents, at least to many common comments such as constraints and the concept of intervention which many organizations including the Japan Health Physics Society (Working Group on International Issues) are concerned about. Holding an international conference to give an explanation about the results of the consultation for comments is crucial. The ICRP should make clear what parts of the documents have been changed and what parts are left unchanged in relation to the previous recommendations; and documents otherwise things will get mixed up.
If the basic definition of the optimisation process still remains valid, constraint is a tool of optimisation as defined in Pub 60. The description of draft recommendations is different from Pub 60. The ICRP should clarify what parts of the documents have been changed and what parts are left unchanged in relation to the previous recommendations and documents.
If the basic definition of the optimisation process still remains valid, the optimisation is the one of three basic principles described in Pub 60. So this paragraph should be revised based on Pub 60.
There are many kinds of practices that a process of optimisation is applied. For instance, radioactive waste treatments are the very long-term practices, on the other hand, routine works are relatively short term practices. Optimaisation processes and numerical values of constraints should be different from case by case. The specific clarification of optimisation process and constraint should be significant based on each case.
The definitions of authorized level and intervention level should be clarified based on Pub 60.
The gselection of relevant dose constraintsh contains the important part about sources, so this part should be included in the general description. But the description about gallocation of constraintsh should be deleted because dose limit for public in a single facility or a nuclear power plant has been kept by using the concept of controlled area.
The application of optimisation of protection in emergency situations and in controllable existing situations is not similar to those for planned situations because the target doses are totally different based on Pub 60. The description of this part is the mixture of undefined some concepts.