1. RER/9/111: Establishing a Sustainable National Regulatory Infrastructure for Nuclear and Radiation Safety TCEU School of Drafting Regulations 03-14 November 2014 Presentation 1.12: Existing Exposure Situations Cait Maloney

2. Content of the Presentation Contents: Concept of existing exposure situations Requirements/responsibilities of Government/Regulatory body Employers 2

3. Definition An existing exposure situation: A situation of exposure that already exists when a decision on the need for control needs to be taken. 3

4. Scope Exposures due to: contaminated areas from past unregulated practices or from an emergency commodities containing residual radioactive material from the contaminated areas above natural sources that may be controllable in some situations e.g. radon, radionuclides of natural origin in drinking water, occupational exposure to cosmic radiation 4

5. Generic requirements – government (1) Requirement 47: the government shall ensure that existing exposure situations that have been identified are evaluated to determine which occupational exposures and public exposures are of concern from the point of view of radiation protection. 5

6. Generic Requirements- government (2) The government shall: ensure that, when an existing exposure situation is identified, responsibilities for protection and safety are assigned and appropriate reference levels are established. include provision for management of such situations in the legal and regulatory framework. 6

7. Generic Requirements- government (3) Definition of reference level in existing exposure situation: “the level of dose, risk or activity concentration above which it is not appropriate to plan to allow exposures to occur and below which optimization of protection and safety would continue to be implemented.” Typically, reference levels are expressed as an effective dose in the range of 1-20mSv/year 7

8. Generic Requirements- government (4) The management shall: specify the exposure situations that are in scope specify general principles underlying the protection strategies assign responsibilities for establishment and implementation of strategies (to regulatory body or other relevant authority provide for involvement of interested parties in development and implementation of the strategies 8

9. Generic requirements: regulatory body/relevant authority (1) The authority who has to establish the protection strategy shall: (a) ensure it defines: objectives to be achieved by the strategy appropriate reference levels (b) implement the strategy including: arranging evaluation of remedial and protective actions and their efficiency ensuring people subject to the exposure have access to information on health effects and means for reducing exposures. 9

10. Public exposure: justification and optimization (1) Requirement 48: The government and the regulatory body or other relevant authority shall ensure that remedial actions and protective actions are justified and that the protection and safety is optimized. 10

11. Public exposure: justification and optimization (2) The government/regulatory body/relevant authority shall ensure: the protective management strategy is commensurate with the radiation risks planned remedial and protective actions will be of more benefit than detriment. 11

12. Public exposure: justification and optimization (3) The regulatory body/relevant authority shall ensure that remedial and protective actions are optimized. (In the optimization process, priority shall be given to those whose residual doses exceed a reference level.) The regulatory body/relevant authority shall periodically review reference levels to ensure they remain appropriate 12

13. Remediation of contaminated areas (1) Requirement 49: The government shall ensure that provision is made for identifying those persons or organizations responsible for areas with residual radioactive materials, for establishinh and implementing remediation programmes and post- remediation control measures, if appropriate, and for putting in place an appropriate strategy for radioactive waste management. 13

14. Remediation of contaminated areas (2) The government shall ensure provision is made in the framework for protection and safety for: identifying those responsible for the contamination and those responsible for financing the remediation (and alternative sources of funding if necessary) designating responsibility for planning, implementing & verifying result of remedial actions establishing restrictions on site use/access record management system 14

15. Remediation of contaminated areas (3) the government shall ensure the framework for protection and safety contains an appropriate radioactive waste management strategy 15

16. Remediation of contaminated areas (4) Those responsible for remedial actions shall ensure that: a remedial action plan with safety assessment (RAP) is prepared and submitted to the regulatory body/relevant authority the RAP is aimed at reduction of radiation risks and, if possible, the removal of access/use restrictions any additional public dose received because of remedial action is justified on the basis of future net benefit Optimization considers radiological and non-radiological factors & technical, societal and economic factors 16

17. Remediation of contaminated areas (5) Those responsible for remedial actions shall ensure that: there is a mechanism for informing and involving the public and interested parties in all phases of the remedial process a monitoring programme is established and implemented establishing a system for maintaining adequate records a mechanism to inform the regulatory body of abnormal conditions The work is conducted in accordance with the RAP 17

18. Remediation of contaminated areas (7) The regulatory body/relevant authority shall take responsibility for: review of the safety assessment, approval of the RAP (and significant changes to it), granting any required approvals establishing criteria and methods to assess safety reviewing work procedures, monitoring programmes and records 18

19. Post remediation of contaminated areas (1) The regulatory body/relevant authority shall: if necessary, establish regulatory requirements for post-remediation control measures designating who has responsibility for compliance with the post-remediation control measures periodically reviewing/updating restrictions 19

20. Post remediation of contaminated areas (2) The entity responsible for post-remediation controls shall establish and maintain a programme to verify long-term effectiveness of the remedial actions If the government allows resumption of social and economic activities in areas with long-lasting contamination, it shall ensure appropriate arrangements are in place for ongoing control of exposures. 20

21. Public exposure due to indoor radon (1) Requirement 50: The government shall provide information on levels of radon indoors and the associated health risks and, if appropriate,shall establish and implement an action plan for controlling public exposure due to radon indoors 21

22. Public exposure due to indoor radon (2) The government shall ensure that: information is gathered on Rn in dwellings and other building with high public occupancy the public is provided with relevant information on exposure to Rn an associated health risks if areas of high Rn concentration are identified, an action plan is established that includes reference levels and reducing Rn levels to optimize protection Rn-222 prevention and control measures are included in building codes 22

23. Radionuclides in commodities Requirement 51:The regulatory body or other relevant authority shall establish reference levels for radionuclides in commodities. Reference levels in commodities shall be based on effective dose of about 1mSv/yr and take into account relevant guideline levels established by FAO/WHO (Codex Alimentarius) and WHO 23

24. Exposure in workplace (1) Requirement 52: The regulatory body shall establish and enforce requirements for the protection of workers in existing exposure situations. Except in specific situations (next slide), the requirements of public exposure shall apply to workers 24

25. Exposure in workplace (2) Exceptions: Doses to workers shall be controlled as occupational exposure in planned exposure situations for: workers undertaking remedial actions workers subjected to workplace Rn-222 activity concentrations above established reference levels aircrew members whose exposures due to cosmic radiation are likely to exceed established reference levels 25

26. Air crews When doses to aircrew members are likely to exceed established reference levels, employers shall: assess doses and keep records make records available to aircrew members inform female aircrew members of the risk to the embryo or foetus due to exposure and the need for early notification of pregnancy adapt working conditions for pregnant aircrew members to afford embryo or foetus the same broad level of protection as a member of the public 26

27. Space-based activities Where appropriate, the regulatory body/relevant authority shall establish an appropriate framework for radiation protection for individuals in space-based activities. Dose limits in these Standards do not apply; however, all reasonable efforts should be made to optimize protection. 27

28. Summary / Conclusions need for government engagement and policy framework to deal with existing exposure situations challenge to decide who has responsibility (and who pays) 28

29. References GSR Part 3 paragraphs 5.1-5.33 29