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Submitted by Dr. D.N. Sharma, Bhabha Atomic Research Centre,
   Commenting as an individual
Document The scope of radiological protection
 
Comments on ICRP document on
The Scope of Radiological Protection Regulations


The document has been drafted giving very logical explanation to most of the complex issues in the areas of exclusion and exemption of various activities and contents of radionuclides in commodities and construction materials both of artificial and natural origins. However, we have the following comments:

1. Executive summary (f) Line 7-11:
This states that substances containing around 10 Bq / kg for â, ã emitting radionuclides may be excluded from regulatory legal instruments. But what about K-40 in table salt. The concentration of K-40 exceeds substantially in table salt. Does this mean even table salt need to be brought under regulation?

2. Executive summary (g) line 1-3:
This states that unjustified situations should not be granted exemption. But at times unjustified situations may have such insignificant exposures that may be inconsequential. While justified exposures may not in that category but may have exposures that are not amenable to control. How do we deal with such contradictory situations?

3. Executive summary (m) line 10-13:
ICRP should come out with a universally accepted no. either in terms of activity present in the body or in terms of dose received by others from a treated patient as discharge criteria. This may bring coherence in the regulation worldwide.

4. 1.1 (3) line 10-11:
Leaving the situations needing regulation to national bodies is okay but why not the international recommending bodies like ICRP recommend some lower and upper bounds of these boundaries which should not be exceeded by any national regulator. This may help in bringing common approach world over.

5. 2.1 (12) line 7-9:
The natural exposure forms the background. Why it has been included here? It should be only exposures from ‘artificial’ sources. Even in case of radon in mines though the levels are natural but the increased levels are created due to mining activity and hence can be treated as artificial.

6. 2.3 (19) line 2-7:
Yes it is ok that any environmental radioactive material resulting due to authorized discharges should not be further regulated. But what about situations where such discharged radionuclides may get concentrated either in sediment, soil or in the marine cultures like fish, crab etc? Should not some regulatory control be imposed in such situations?

7. 3.2 (31) line 7-11:
Does this mean that source of natural origin that forms part of natural BKG and generally unamenable to control should form part of the ‘radiological protection regulatory systems’? This may please be cleared in the text in unmistakable language.

8. 5.2.1 (45 + 47) line 12-13:
It is not clear that in which situation natural BKG can be zero. It may be clarified by including some examples.

9. 5.2.1 (48) line 23-28:
Yes, it is okay to exempt such practices which do not deliver dose to the workers even equal to the dose limits for member of the public but monitoring of radiation levels should be made mandatory in such practices if there is potential for sudden rise in dose levels.

Apart from above comments following remarks may also be looked into:

1. Para 25:
In this para whether the public / society is referred to general public or a special group like media or nuclear experts working as NGOs that can generate public opinion?

2. It is advisable to include a glossary of terms used in the document to avoid diverse interpretations of the text.