Definition of reference has also been added to glossary. 13 Lines It may not be possible to establish post-remedial restrictions (if any) until the remediation has been carried out Accepted Comment accepted with modifications. Addition of ‘and ongoing review of’ to Line 223 …The establishment and ongoing review of… 14 Lines (b) the remedial action plan is aimed at the timely and progressive reduction of the radiation risks and, if possible, the removal of restrictions on the use of or access to the area For clarity. Accepted Comment accepted. 15 Line 254 The exposure situation being remediated may not be an existing exposure situation. This is a good example of how the term existing exposure (as defined in GSR Part3) is confusing. For an exposure situation to require remediation it must exist, but it may not be an existing exposure situation, which is inconsistent. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 16 Section 3.2.9, Part (c) (i) If the remedial end point conditions have been met, any remaining radioactive material should be unlikely to pose any significant hazard. If the site being remediated is such that inadvertent exposure is highly unlikely, the end point conditions can reflect this. Accepted Comment accepted with modifications. For clarity addition of text has been added to Line 293. …Access by unauthorised persons or for unauthorised activities 17 Section 3.2.12 Proposed new text The conditions prevailing after the completion of remedial actions should be considered to constitute the background radiation for the This is valid whether or not restrictions or controls on the future use of the site are imposed after remediation Accepted Comment accepted with modifications. Modification of text for Section 3.2.12, ‘The conditions prevailing
on factors other than the activity concentrations of those radionuclides present, measurement of activity concentrations does not address the problems mentioned in earlier comments. 22 Lines Proposed new text The remediation process should take into account the relevant aspects of planned exposure situations as described in the Planned Exposure Code, RPS C-1. The sentence as written in the draft is incomplete. Accepted Comment accepted. 23 Section 4.4 The requirements specified in lines 508-509 and 510-512 are contradictory. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 24 Section 4.4 The requirements in lines 526-528 and 529-531 are also contradictory Comment not adopted Comment not adopted. is aligned with GSR Part 3. 25 Lines See earlier comments about consistency. (Comment 8 and Comment 16) Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 26 ANNEX A: Lines line of table Proposed new text Radionuclides of natural origin in bulk material Comment not adopted Comment not adopted. is aligned with GSR Part 3. 27 Line 775 Exemption should also take into account the likelihood that the conditions that justify the exemption will remain valid under all reasonably foreseeable circumstances. Comment not adopted Comment not adopted. Consistent with definition of ARPANSA RPS C-1. 28 Line 791 The graded approach should be based simply on the level of risk, regardless of whether there is a loss of control. Comment not adopted Comment not adopted. Consistent with ARPANSA F-1. 29 Lines This definition is of natural background confusing, because it makes no distinction between Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3.
radiation committee from 2005- 2010, I can see no benefit to the aircrew body in Australia by an increase of these guidance levels. In fact, conversely, I consider it a reduction in potential health benefits to the pilot and cabin crew group, especially in light of the fact of no regulatory compliance regulations and the increased flying in future years for Australian aircrew as outline in my introduction. 56 Captain Dick MacKerras, Technical, Safety and Regulatory Affairs Advisor on behalf of the Australian Airline Pilots’ Association Comment As much as we respect the research and policy recommendations of the International Commission on Radiological Protection (ICRP), we also recognise that attempting to separate and exclusively characterise exposures between “planned” and “existing” events cannot satisfy all situations and, therefore, careful consideration by ARPANSA must replace rote acceptance of ICRP recommendations. More broadly, AusALPA is concerned that ARPANSA may be surrendering its leadership role in radiation protection of air crew by recommending increased exposure monitoring levels to the point where exposure becomes trivialised. Comment not adopted Comment not adopted. Please note that ARPANSA’s role is to promote national uniformity of radiation protection policy and practices across jurisdictions of the Commonwealth, the States and Territories, and provide advice on radiation protection and related issues. However, ARPANSA can only regulate Commonwealth entities. 57 Proposed change AusALPA believes that 6 mSv year-1 retains both national and AusALPA is advised that, of the limited aircrew population monitored in Accepted Comment accepted.
management’s commercial and promotional interests – they have little or nothing to gain from actively managing their workforce’s radiation exposure to the detriment of the roster and there is little incentive for them to select a reference level that might cause that outcome. 60 Capt. A. C. Ruas, Capt. Rodrigues and SFO Theresia Eberbach on half of International Federation of Airline Pilot Associations (IFALPA) Proposed change Air crew exposure should be classified as a planned exposure, not as an existing exposure. IFALPA understands the importance that ICRP 132 and EURATOM BSS converge in the classification of the aircrew as planned exposure situations. Considering that this Public consultation Draft applies to existing exposure situations and given the fact that the document assumes the ICRP 132 definition that classifies the aircrew as existing exposure situations, we reinforce the recommendations presented below regardless of the ICRP 132 and EURATOM BSS divergence in the matter. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 61 Proposed change IFALPA recognizes 20 mSv/y as the average annual dose of ionizing radiation for pilots, so in this regard the reference level of 10 mSv/y is in Those who are liable to receive an effective dose greater than 6 mSv per year should be classified as Category A workers. The Accepted Comment not adopted. The reference level of aircrew has been revised down to 6 mSv per year.
prevent its effective use in practice. 68 General comment The draft guide would benefit with the inclusion of a section which: - Outlines the regulatory context and the ‘fit’ of the guide - Defines the intended audience or user of the guide - Clearly defines how the guide is to be applied. For clarity. Accepted Comment accepted with modifications. Scope has been re-written to clarify the reader of the document and how this Guide is applied. 69 General Comment The draft guide indicates that regulation of radiation is potentially now required below 1Bq/g covering in fact all materials. This means that the scope is essentially infinite which reduces the practicality of the draft guide. This reinforces the perception that radiation is dangerous at low levels. The MCA suggests changes be incorporated to reduce the scope to situations where radiological impacts are significant. The MCA recommends controls should be commensurate with the assessed risk. Accepted Comment accepted with modifications. Scope has been re-written to clarify the reader of the document. Existing exposure situations by is everything, regardless of regulation. 70 Line 7-8 Comment: The MCA supports the statement that the central consideration is the ‘system of dose limitation’. The MCA has stated previously that the principle reasons for the low occupational and public doses are due to the optimization process and supports the draft reflecting this. Accepted Noted 71 Line 20-21 Proposed change – Existing exposure situations are exposure situations that already exist when a decision on control has to be taken’. MCA suggests adding ‘see section 2.2 of this guide’ after this. For clarity. Accepted Comment accepted with modifications. Re-written as follows “Existing exposure situations are exposure situations that already when a decision on the need for control
with ‘all exposure incurred by workers as a result of a practice’. therefore the statement is incorrect. which is considered background radiation. Therefore statement is correct. 80 Line 94 Proposed change – Comment: The term environment is too and over defined (clause 744 to 753). The requirement should be very specific and is radiation risk to ‘flora and fauna’. For clarity. Accepted Comment accepted with modifications. Text has been modified as follows, ‘environmental (associated with protection of the environment (biota)).’ 81 Line 23 and Above 128 Proposed change – Line 23: Amend to ‘Existing exposure situations in this Guide apply to situations where there is significant exposure (in comparison with applicable reference levels) due to:’ Add new paragraph above Line 128 as follows: ‘Although there are a wide range of potential existing exposure situations, only those which have the potential to exceed the reference levels in Appendix XX should be considered existing exposure situations. This is demonstrated in the Figure 2.2. Decision box ‘Is Control Justified?’ This decision point determines that there is no existing exposure situation where there is not a significant potential for radiological exposure. This is required to prevent all activities from being included and so this guide only applies to those situations with radiological impacts. Currently the of what is an existing exposure situation includes virtually every single action, practice or situation which involves handling any material (with the exception of those already identified as a practice). This is the result of there being no de minimus level in the scope and effectively everything under 1 Bq/g is in scope. Using Figure 2.2 as a guide provides a more effective means of determining the ‘real’ existing exposure situations. Accepted Comment accepted with modifications. Line 23 is consistent with GSR Part 3. Additional text has been added to Line 173 to clarify Figure 2.2. 82 Line 97-414 Comment: Care must be taken to not formalise reference levels – particularly when the words are The problem is that the reference level could become another statutory limit. Accepted Noted.
from the Existing Exposure guidelines. 91 Line 578 Proposed change – Reference levels table. Delete line ‘Radionuclides of commodities in bulk material 1 mSv y-1’ Reason This is covered in the previous line. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 92 Lines Proposed change – Delete ‘The requirements for existing exposure situations apply to material containing radionuclides of natural origin at an activity concentration of less than 1 Bq g-1 for any radionuclide in the uranium decay chain or the thorium decay chain and of less than 10 Bq g-1 for 40K. For radionuclides of natural origin, bulk amounts of material are to be considered on a case-by-case basis by using a dose criterion of 1 mSv As explained above. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 93 Radiation Health Unit, Queensland Department of Health Line 14 Who is this guide intended for? The intended audience should be included in the purpose. Accepted Comment accepted with modifications. has been re-written. 94 Line 31 and 41 There is no (a) or (c)(ii). I suggest the dot points be numbered so that these two lines make sense Accepted Comment accepted with modifications. Typo has been corrected. 95 Line 41 to 43 I struggled to understand what this meant. It refers to materials other than the materials in the dot point above (radionuclides of natural origin .....). It seems to be an inversion of an exclusion in order to make it an inclusion. Accepted Comment accepted with modifications. Scope has been re-written.
radionuclide in the U-238 or Th-232 decay series exceeds 1Bq.g-1, or if the activity concentration of K-40 exceeds 10Bq.g-1 (529-531). 113 Line 51-520 Who should develop and implement the protection strategy mentioned here? Accepted Comment accepted with modifications. Text has been modified in line 520-521 114 Line 592 The reference level of 10m.Sv.y-1 is already established – it is not a matter of a reference level “to be selected by operating managers”. The text “to be selected by operating managers” should be removed. Accepted Comment accepted with modifications. Text has been modified to read ‘to be endorsed by employers’ 115 Line 788 “Graded approach” is not mentioned in the guide so it can be removed from the glossary. Accepted Comment accepted. 116 Line 793 “Health authority” is not mentioned in the guide so it can be removed from the glossary. Accepted Comment accepted. 117 Line 917, 923 & elsewhere The term “regulatory body” is used in Appendix 2 and the glossary. The “regulatory authority”, “relevant regulatory body”, “relevant regulatory authority”, and “relevant radiation regulatory authority” are only used in the glossary. The main text of the guide uses the term “relevant authority”. Can a single term be chosen and used throughout? Comment not adopted Comment not adopted. Consistent with ARPANSA RPS 118 Section 4.1 The discussion about areas with residual radioactive material is not structured in a similar wary to the discussion of other existing exposure situations. Not Accepted Text in Section 2.2 has been added to clarify if action needs to occur. Figure 2.2 has been edited to clarify if remediation is required.
In sections 4.2 to 4.4 the guide has an introductory discussion about exposure of persons to radon, cosmic rays, and radionuclides in commodities and bulk materials. It then provides guidance for situations in which exposure are above the relevant reference level (see lines 565, 583, 638, and 643). This is not the case with exposures due to contamination of areas by residual radioactive material - the discussion goes directly to the remediation of these areas (an action carried out if the relevant reference level is exceeded). There is no discussion about habitation of land with residual radioactive material in a situation where the reference level is not exceeded and remediation has not, and need not, be carried out. In these situations the option may be to do nothing at all, or to have in place a management plan that for example, leaves in place the extant natural or built environment so that exposure does not increase (note that this is not the same as remediation which is meant to reduce an existing exposure). Section 4 also states the following “A decision should then be made as to what management or intervening action may be required, taking full account of the costs and benefits of the action. The outcome of the initial assessment should help guide the decision–making process.” 119 Section 4.4 This clause says a protection strategy should be developed by the employers in conjunction with the relevant regulatory authority. However, this type of exposure is only addressed under Section 3 – Guidance for public exposure, so is Noted. Any protection strategy should be developed in conjunction with the relevant regulatory authority.