with exposure incurred by therefore the statement is which is considered background ‘all workers as a result of a practice’. incorrect. radiation. Therefore statement is correct. 80 Line 94 Proposed change For clarity. Accepted Comment accepted with – Comment: The term environment is modifications. too and over defined (clause 744 to 753). The requirement should Text has been modified as be very specific and is radiation risk follows, ‘environmental to and fauna’. (associated with protection of the ‘flora environment (biota)).’ 81 Line 23 and Proposed change Currently the of what Accepted Comment accepted with – Above 128 Line 23: Amend to exposure is an existing exposure modifications. ‘Existing situations in this Guide apply to situation includes virtually situations where there is significant every single action, Line 23 is consistent with GSR exposure (in comparison with practice or situation which Part 3. applicable reference levels) due to:’ involves handling any Add new paragraph above Line 128 material (with the Additional text has been added to as follows: there are a exception of those already Line 173 to clarify Figure 2.2. ‘Although wide range of potential existing identified as a practice). exposure situations, only those This is the result of there which have the potential to exceed being no de minimus level the reference levels in Appendix XX in the scope and effectively should be considered existing everything under 1 Bq/g is exposure situations. This is in scope. Using Figure 2.2 demonstrated in the Figure 2.2. as a guide provides a more Decision box Control Justified?’ effective means of ‘Is This decision point determines that determining the ‘real’ there is no existing exposure existing exposure situation where there is not a situations. 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. 82 Line 97-414 Comment: Care must be taken to not The problem is that the Accepted Noted. formalise reference levels reference level could – particularly when the words are become another statutory limit.
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.
rpsg-2_public-consultation-comments.docx