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Submitted by Peter Girkens, German Ministry of Transport, Building and Housing
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Comments from the German Federal Ministry of Transport, Building and Housing
on the ICRP 2005 – Recommendations

The following comments refer only to the Chapter 8. „Exclusion of sources from the scope of the recommendations“.

In the draft in Table 10 the recommended activity concentrations for the exclusion levels are stated only for the most restricted radionuclides without using radionuclid – specific values as currently applied in the inter-Agency Basic Safety Standards and the EURATOM Basic Safety Standards. These activity concentrations are recommended by the Commission as the levels below which materials do not enter the scope of its recommendations.

Contrary to that, in the IAEA “Regulations for the Safe Transport of Radioactive Material”, 1996 Edition (As Amended 2003), No. TS-R-1, the activity concentration for exempt material, which are radionuclid - specific, mean: the transport of radioactive material below these levels is outsite the scope of the IAEA Transport Regulations. The basis for these radionuclide – specific values is the 10 Sv/a concept which is the same as used for the derivation of the exclusion levels in ICRP 2005.

For this reason, the values of activity concentration provided in the IAEA Safety Guide No. RS-G-1.7 “Application of the Concepts of Exclusion, Exemption and Clearance” (former IAEA DS 161) do not apply to the “Material in transport in accordance with the IAEA Transport Regulations” (item 1.8 of the RS-G-1.7).

The IAEA Transport Regulations are world-wide the basis for most of the national and international binding agreements for the transport of radioactive material.
Therefore, a lot of practical problems can occur, because the exemption values in the IAEA Transport Regulations are 10 – 1000 times higher than the exclusion levels in the ICRP 2005.

This discrepancy should be considered in finalizing the draft of the new ICRP recommendation.