Optimisation of radiological protection

Draft document: Optimisation of radiological protection
Submitted by Janice Milne, SEPA
Commenting on behalf of the organisation

The Optimisation of Radiological Protection Thank you for providing the Scottish Environment Protection Agency (SEPA) with the opportunity to comment on the above consultation document. In any further consultation, we would urge the Commission to ensure that all stakeholders are provided with the means to engage fully. A useful model for relaying technical information to audiences with various levels of awareness of specific issues is that developed by the organisation ‘GreenFacts’ (http://www.greenfacts.org). GreenFacts provides an information and educational website on environmental issues in which the information is presented in several layers, beginning with the most basic description of the issue where terminology is defined, and progressively including more technical information within each of the subsequent layers. We believe this format provides a valuable approach for information provision that acknowledges the different needs of stakeholders. SEPA uses the principle of optimisation in many of its considerations of authorisations to ensure that discharges use best practicable means (BPM) to minimise the impact on the environment which is comparable to the ALARA concept. It is our belief that the application of optimisation principle before the commencement of an undertaking can reduce the potential impacts on the environment and we therefore consider that the schematic in Figure 1- Planned situations should be revised to demonstrate that application of optimisation can reduce the dose as the operation begins. As an environmental regulator, SEPA are aware that the principle of protection of biota is being considered by ICRP. SEPA are interested to know how environmental considerations would be included in an optimisation principle, when such a principle is built around doses to man and therefore explicitly exclude any environment where man is not present. Do these considerations relate purely to man’s use of the environment or more broadly? SEPA is supportive of paragraph 39, which introduces BAT and BATNEEC and moves the focus from reduction of the probability of exposure/harm to emission reduction at source. Paragraphs 48 to 54 outline the possible role of an individual in determining the outcome of an optimisation process. It is unclear to SEPA, how such an individuals’ concerns could facilitate the optimisation process. Although it is vital that all information is gathered and individuals view that a given dose is acceptable should not mean that the optimisation process has been completed. The concept of a dose matrix is of potentially high value. However, the critical group should be retained and relative weights should be assigned to this group rather than the mean individuals’ dose. As a public body committed to openness and transparency, SEPA feels it is appropriate that this response be placed on the public record. If you require further clarification on any aspect of this correspondence, please contact Paul Dale, SEPA Corporate Office, at the address shown below. Yours faithfully Janice Milne Head of Environmental Policy