Submitted by Tomonori Hirose, The Federation of Electric Power Companies of Japan Commenting on behalf of the organisation
I would like to thank ICRP for the opportunity to provide comments the draft document “Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident”. On behalf of FEPC (The Federation of Electric Power Companies of Japan) I would like to submit our comments on the document as follows.
The paragraph (19) in Subsection 2.2.1.1 describes about the recent research results of low-dose radiation effects associated with heart disease. Considering uncertainties (such as changes in coding rules for International Classification of Disease(ICD), , handling of subtype specific heart diseases, influence on lifestyle, etc.) contained in these studies a sentence below（an underlined part）should be added to this paragraph in order to clearly state the argument; “However these studies include uncertainties and the situation at low doses is still less clear.”
The paragraph (82) in Subsection 3.22.1 describes about Derived Consideration Reference Levels (DCRLs); DCRLs are defined in terms of a band of dose rates for reference animals and plants. DCRLs do not represent the values as a result of direct evaluation of risks on animals and plants. In addition, it is quite difficult to keep both radiation effects on people and on animals/plants under management at the same time in an emergency. ICRP should consider a practical and scientifically reasonable framework for radiological protection by introducing an integrated management of radiation effects both on people and the environment in order to ensure that appropriate actions can be taken in an emergency exposure situation during which multiple activities need to be performed simultaneously.
The paragraph (120) in Subsection 3.3.5 mentions that arrangements for dose records should be made as part of the planning for a response, and should include agreement between the responsible authorities, operator, employers, and workers. In this regard, this sentence should be revised to a sentence below to require the establishment of a guideline; “Arrangements for dose records should be made in advance in accordance with a national guideline.”
The paragraph (173) in Subsection 4.2 mentions that unforeseen sources may exist and unexpected circumstances may challenge the reference level during the recovery process. A sentence below should be added to this paragraph to specifically describe necessary actions; “The Commission recognizes that a higher level than the general reference level may be necessary for a short period of time under unexpected circumstances in the environment at a damaged facility.”