|Thank you for the opportunity provided by ICRP to comment on the consultation document on the Scope of the Radiological Protection Regulations. These are the views of the United Kingdom Ministry of Defence (UK MOD).
It is noted that this document has been produced in response to comments made in a previous ICRP consultation and recognise ICRP willingness to address such issues. It is assumed that this is a foundation document underpinning ICRP recommendations. We suggest that its status should be explained within the publication and a description provided as to how it fits within the hierarchy of ICRP publications.
The UK MOD support the Commission’s position on the issue of regulatory scope (paragraph 130) which is that radiological protection regulations need not be established that are deemed to be unamenable to control. UK MOD also strongly supports the principle of good governance (paragraph 131) that Governments have obligations not to allow societal resources to be squandered on unproductive legislation and fruitless regulatory control and not to limit individual freedoms.
The concepts of exclusion and clearance are clearly explained in the document but the explanation of the term exemption appears to be complex and at times confusing and it is suggested that the ICRP task group consider simplifying the description of the term. The use of text boxes within the publication may be useful to highlight ICRP’s position on these three concepts and other key points in the document.
It is considered that the exclusion levels proposed at 1 Bq kg-1 for alpha and 10 Bq kg-1 for beta are set at far too low a level. Even at significantly higher levels (factors of 10 or 100 higher), for many radionuclides such levels are minute and difficult to monitor (comparable with commodities in paragraph 123) with large uncertainties in measurement that they could still be considered to be taken to be unamenable to control in practice. Aside from the practical problem of measurement at such low levels and the uncertainties associated with the measurement the report does not recognise the significant range of radiotoxicities of different radionuclides. Whilst acknowledging the benefits of a two-tier system for alpha and beta in communication we believe that ICRP should increase significantly the above values quoted and reconsider whether these two values are sufficient to cover all radionuclides.
Applying these levels to the topical issues of decommissioning and radioactive waste disposal this would have the impact that material previously excluded and treated as such would now be classed as radioactive and brought within regulation. The consequence of this would be that the material/waste, posing negligible risk, would have to be disposed of to waste disposal sites. This would use up valuable capacity that could be used for hazardous wastes thus increasing the pressure on a country’s limited disposal capacity. This also has implications for historical activities and the levels previously used for the clearance of sites which have been agreed with national regulators. To impose these levels would lead to excessive regulation. Therefore ICRP are requested to rethink their position on this proposal.
The implication of using different activity concentrations for naturally occurring radionuclides compared to artificially created radionuclides of approximately 100/1000 will create in the mind of the public that the latter are significantly more hazardous than those that occur naturally. Clearly this should not be the case. By increasing significantly the exclusion values for artificial radionuclides this would to some extent overcome such a mistaken perception. ICRP will also need to stress that ability to control a source of radiation is the explanation for any residual difference.
We would like to see in the publication a stronger indication from the ICRP working group that the currently accepted level of “trivial dose” set at 10ìSv per annum is too prescriptive and should take into account societal factors making a range of values from in the order of a few tens of microsieverts per annum up to 1mSv per annum depending upon circumstances.
The proposal to exempt “type-approved devices containing sealed radioactive sources subject to limited potential for leakage and dose rates not exceeding 1 ìSv/h at 0.1m from any accessible surface” is supported and any further guidance will be welcomed.
The statement in paragraph 143 that dilution may be the optimum regulatory option is noted with interest.
In conclusion we welcome ICRP’s willingness to tackle issues raised in comments to past consultations and clarification of the difficult radiation protection concepts. UK MOD have a number of concerns which are described above and look forward to seeing how ICRP address these issues.