ML20043B966
| ML20043B966 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1988 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006010118 | |
| Download: ML20043B966 (40) | |
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UNITED STATES h~
8 NUCLEAR REGULATORY COMMIS$10N l
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WAtmNG TON, D. C. 20665
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O March 29, 1988 e....#
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1 MEMORANDUM FOR:
Hugh L. Thompsen, Director Office of Nuclear Material i
Safety and Safeguards V
FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS SUdJEC7:
INTERNATIONAL GUIDANCE ON THE DE MINIMIS ISSUE A joint IAEA/NEA expert group met during trch 21-25, 1988 in Vienna to prepare a guidance document on the de minimis issue. The enclosed draft represents the final markup on the last dayof the meeting. The document needs editing and to be cleared through various approval groups within IAEA and NEA before publication.
Based on the broad representation within the expert group, !
believe it will be approved without significant problem.
EPA as well as NRC was-represented at the meeting. A list of participants is enclosed.
The vacument uses the term " exemption rules" which means exemption from the basic radiation safety standards adopted by IAEA and NEA. These radiation safety standards are consistent with ICRP recommendations. The document provides the analytical approach to granting exemptions, i.e., "below regulatory concern." Within that framework it also establishes a level of trivial individual and collective dose and describes the conditions for its use. The document also provides in the Annex criteria by which a " practice" and " source" can be defined.
Unless unforeseen problems arise during the final approval process, I believe the international guidance will now provide a solic basis for preparing broad NRC policy on "below regulatory concern" and trivial dose.
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,h Richard E. Cunningham, Director 9006010118 891130 Division of Industrial and hihiIbFR49886 PDC Medical Nuclear Safety, NMSS
Enclosures:
As stated cc: w/ enclosures R. Bernero, NMSS G. Sjoblom, NMSS 1
J. Hickey, HMSS
- 4. Cool, NMSS.
H. Denton, GPA R. Hauber, GPA M. Congdon, GPA L. Roche, EDO B. Morris RES B.Lahs,EES R. Brovning, NMSS M. Knapp, NMSS
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EXEMPTION OF RADIATION SOURCES AND i
PRACTICES FROM REGULATORY CONTROL 1AEA/NEA Expert Group March 21-25. 1988 i
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The 1 R&/1LO/ttA(ogCD)/nnio Basic gefety standards for Radiatico protection (BSS)'
(1), published in IAEA Safety Series No.9, provide guidance
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en regulations for radiation protection, based en the recespondations of the Entomational ceanission en Radiological protection (ICRp) (2). These include a system of dose limitation d ish sentains three basic principios, namslp, l
justification of a practice, optimisation of protection and limitation of individual risk.
2.
The bests of regulatory contro1* in the 388 is a system of notification, registration and licensing, d ich makes it p6ssible for the coepetent authority to impose appropriate requirements for preteetten. The 388 envisese varying degrees of regulatory control. The" highest of these Le the full system'of licensing of the the operations involving radiatica. Deler l
that is a system of general authorisation, in With the precise dotatie of l
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A ere all radioactive material is, or even how many users exist at one time, may be lost, but in which the congetent authority attil has a osans of kneering sore generic information through notification and possibly registration, oush as the total amount of material in the country, the design of devices approved for distri ution,.nd the use/s remaim woet to certain as,ects of f'/
regulatory control, e.g'. Sp1 in an approved waste disposal facility.
In j
some cases, even this level of control is not required, and there are then reasons for exemption from all the controls recommended in the 388.
3.
Exemptions may be either generity or specific to one application by one propostant. In either case exemptions may be granted at levels above these that could be regarded as being intrinsically negligible.
4 The tem " control" is used in this document to mean " exercising restrair.t" rather than " checking or verifying" (vis-a-vis applicable to all derivations from the torn such as " controllable", " controlled", etc.).
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0003y 1988-03-24 7
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De esepe of this document is to recessnond a policy en asesyttons free
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the 388 system of notification, registration and licensing.
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Virtually all materials are rodiesetive, because they sentain natural j
radionuclides er are contaminated with artificial radionuclidos, seve117 et very low levels. The nature of eene of these asteriale end essa ether eeuroes of exposure is such that sentrol by tempotent authorities is not practiesble er perhaps not possible. An example of that is the potassium-40 in the human body. Therefore, such sources are by their nature excluded from regulatory l
control. However, when technological enhancement ecours, there any be reason to institute a system of control. For example, the competent authority might decide to control redon levels inside buildings, while it is obviously j
impracticable to control the levels of naturally-occurring reden outdoor.
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6.'
When reaching decielons about exempting sources of radiation er practices involving radiation exposure, the competent authority should be e
assured that the risk and detriment connected kith the use of the sources or performance of the practices will be so small as not to warrant the application of the system of notification, registration, and licensing.
7.
The forsulation of exemptions from regulatory control should not allow the circumvention of controls that would othetvise be applicable by such means as deliberate dilution of material or fractionation of a practice.
8.
The authority will also need to take account of the probability and-severity of possible consequences of accidents or misuse. such consideration may contra-indicate the exemption of a practice, even if it gives rise to very small doses under norinal conditions, f
t risk and detriment are defined in the Radiation protection Clossary (SS No.,f)
00037 1933 03 34 l
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9.
Campetent authorities may have reasons different from these seneerned with radiation protection for either exempting er not exempting particular sources.or practicos from regulatory control. Beroever, bearing in sind the
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principle of justification, they any went to prehlbit frevegerrus s radioactive materials even if the essociated deses are trivial, e.g. frivolous Atoms.
10.
It is expoeted that recesmondations regarding opplication of the emesption policy in this document will be issued by the appropriate internattenal bodies and that the competent nattenal authorities will form iste explicit rules and guidance for application.
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LC 00057' 1933 03-24 AlPTER 21 hasis concentp 2.1 Excluded Sources and prpetists I
l In the 3.8.8. (Annex 1. para. A.I.3), it is suggested that aanpetent f
authorities do not regulate the fo11 ewing
"(a) Devices producing a rays of quantum energy not succeding S kev (b) Radioactive substances in the form in which they ecour in nature without preparation intended to increase the concentratica of l
radioactive nuclides."
The phrase "in the form in which they occur in nature without preparation" is subject to various inter?retations. The control of espesures l
from these substances is not always practicable and they are therefore excluded from the whole system of control specified in the 3.8.8.
Examples of these are exposures resulting from potassium-40 in the human body, covnic rays, and radon in the open air.
Although many naturally-occuring sources are excluded from regulatory control, certain practices result in the inadvertent mobilisation and/or concentration of the radionuclides, such that workers or the public sight receive doses high enough to warrant regulatory control of the practices. For example, redon daughters can concentrate in the air inside houses. built on radiunitich soil. leading to high doses to the occupants breat'hing that air.
Other examples are concentration of nuclides of the uranium series in phosphate fertilisers, or in building materials, mineral water factories, thermal spas, industrial uses of aircon sands, and coal fired power plants.
Specific guidance for controlling practices that result in enhanced exposures to naturally-occuring radionuclides is being considered intetmationally 1928. ICRP 39), and should also be considered by the national competent authorities.
'9005y 1988-03-34 3.3.
ha meneests of practies and Seurae 2.2.1 Introduction 1
The term " practice", vousily associated with such tera 6 as " operation" and "sourse",has been used very frequently in the last few years in radiatten V protection reconssendations and reguistions to sharsetorise the object of specifts guidance er assessment. Exemples of this are the definitten of
" justification of an operation er a oracties", the sensept of "sellective dose por unit oractice", the " exemption of eeurces and erectises free regulatory sentrol", etc.
The guider.co given in this report en the principles and criteria to he l.
applied to exemption from regulatory control would be ambiguous and difficult to apply if a definition of what should constitute a " practice" and a "sourse" in the concrete situations for which exemption is considered were not given.
The exemption principles reconenended in this report may be expected to find use in a variety of applications. These include, for example, the exemptionfros/ notification,registrationandlicensing f the disposal of l
certain types of low-level radioactive wastes in terrestrial and equatic envaronments and the recycle of slightly contaminated materials from the nuclear industry.
Also, in some applications the practice being considered for exemption may involve the +4: ale cycle comprising the use and disposal of a source.
In other cases, it may be appropriate to consider the disposal
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process itself as a separate practice.
l it is clear, therefnee, that the sources or practices may be of a widely varying nature; however they should all correspond to the following general definitions.
2.2.2 Fracties A practice may be defined as "a set of co-ordinated end continuing activities involving radiation exposure which are sieod at a given purpose, or the combination of a 4
number of similar such sets".
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3 The sise, scope and time duration of a practice can be different,
' depending en the purpose and the intended impact of the radiation protection assespeent er,coguistory action oddressing the prestice. For 'esemple, these j
three features tan be difforent in the ease of justification of the practise,
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er optimisation of protection er lisensing er esemption of a given activity.
f in any event, when tweeption from reguletory control is sensidered, the fone.ingfosiuros.ssed.haracterisean,identi,io.e,o.ifi.,ra.iise, i
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a) the activities composing the practices gaat be ee-ordinated and aimed at a cesumen objectival
-the sources.hich are the e,30.t of the,rs.ti.e 4.e cleari,
identified; 1
c) it,syst be possible to identify a specific crittsal group (or groups) uniquely linked to the practicel- -
thedosetotheindividualsofthetriticalgroupj)andthedoseto d) the whole population exposed by the prectice ipdt not be significantly affected by other similar (or identical) practises (e.g., several waste disposal sites in a sono region).
e) the activities composing the practica post be easy to identify and l
describe, both in spatial end temporal tems, and be sufficiently
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well defined to facilitate impact analysis and regulatory assessments and to minimise the complexity of the procedures I
required for exemption from regulatory control.
2.2.3 Source The " source" can be defined as "the ohysical entity Whose use, manipulation, operation, decomissioning and/or disposal, constitutes the t
In other co-ordinated set of activities defined as " practice" in para 2.2.2".
words, the "tource" is not equivalent to the " practice", but is simply the radioactive material, the equipment esitting radiation or containing radioactive material or the installation (or group of inets11stions) producing or using radioactive material,'which is the object of the practice.
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4 ic Speelfie features to be used to therectorise a source include the I
pessibilitF of distinguishing it free other sources not only in tems of its f
,,,sitet e,are.terisu es end loca u en..ut oise in to.s of n,,orent environmental pathways, eritical group, etc.
2.2.4 Aeolicotten l
The appliestion of all the above sensiderations to the field of exemption is liable to be different for the different practices, & few major esses are currently of primary interest. They include the wee of eeneumer products, the disposal of very low level solid radioactive westos, the recre'1e l
end reuse of motorisis resuiting from doesseissioning of nusteer facilities.
andthedischargeofveryemellquantitiesofradiesetiveeffluents.{The proposed]...^i.J%f)efI" practice" and " source" for thi in Annex x P
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l Salance of Chanter 2 Amelicable seinciales of radiation erotection M
1.
The system of dose Ifmitation, which is applied in the 888 to the regulation of practices involving espesure to ionizing radiation that are subject to control by a competent authority, must, of nec
- sity, also be considered in esempting practices from such control.
This system is comprised of three basic elements justificati fa W
practice, optimization of protection, and limitation of individual ris i
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We consider here only those practices which have, in eone manner, been justified, since this decision may be made outside the content of l
regulatory control (or esemption from such control, in the present cess).
l Ostimization of Protection 3.
Aq y used in the optimisation of radiation protection is the health detriment.
It is defined as the espectation of deleterious consequences to health as a result of esposure to radiation, weighted according to their severity. In the consideration of esempt practices, these consequences will be Ifmit>d to stochastic effects (cancer deaths and serious genetic effects) (ref, tSS). The health detriment is assumed, for the purpose of radiation protection, to be proportional to the collective effective dose equivalent commitment (ref. 888). We will refer to this quantity henceforth, as the collective dose commitment.
4.
The collective dose commitment, rather than simply the collective dose, is the appropriate quantity since the operation of a practice in a given year may produce doses in the future. Further, since incremental costs for regulat' ion will be incurred on an annual basis, we use the collecti ose commitment per voar of orectice. The size of a 1sb
%M%e. ty~r the purpose of making decisions ile Fo pract7emay s
about optimization, the year of relevance is that in which the practice reaches its maximum sire,
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The collective dose commitment je assessed si L i :f m ;
Md average behaviour'of radionuclide'sae 4 pert and esposure of individuals. The os unit of collective dose commitment is the man sievert (man Sv)
Limitation of Individual Risk se 4.
In the case of esemptions, the limitation of individual risk is carried out by controlling the radiation doses in a gewup of individuals most likely to receive the bishest doses free the practice.
For this p rpose, the concept of the critical gtg g is introduced.
This group is chosen to be representative of individuals receiving the highest levels of dose from the particular practice, and is defined so that it is reasonably homogeneous with respect to factors that affect the dose received.
It is also necessary to choose that i
. time when these doses'are at their maximum value. The assessment then i
proceeds in terms of the average dose in the critical group.
7.
Unless otherwise stated, throughout this document the ters " dose" refers to the sum of the effective dose equivalent from enternal j
esposure in a given period and the committed effective dose equivalent a
from radionuclides taken into the body in the same period.
additional considerations 8.
Under the assumption of proportionality between dose and risk, a given increment in the irdividual dose or collective dose will always result in the same increment in the individual risk or in the Jollective health detriment independent of other contributions to individual or i
collective dose.
This makes it possible to ass'ess the consequences of the esposure from any arbitrary group of radiation sources, such as the l
group of radiation sources subject to enemption from regulatory control, and to limit these consequences without consideration of other sources.
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.pw The proportionality factor for radiation-induced lethal cancers and serious hereditary effects is taken to be of the order of magnitude 10-2 per sievert.
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and the collective dose will be directly proportional to the number of sources used within a practice.
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- 10. In considering the enemption of a particular practice, from the radiological point of view either the a) optimization of practice er b) limitation of individual risk may turn out to be a more restrictive l
factor, depending upon the nature of the practice.
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Cupft1.3 There are two basic criteria for determining whether er met a praatise is a sand'idate for en ensartion free bas radiation protection %et bev s_spe >
y x optimised and individual risks masst be g eufficiently low.
-... 5-.. x is usually anowNseo through a oest benefit analysis, Latuitive or formal, or sans other sLa11er form of analysis. Severtheless, it is useful for authorities to have guidelines about typical exemption levels Whiah are teamenly believed to be trivial and oceeptable without a great deel of detailed entlysis. That Whish follows is a derivation of those guidelines.
3 l IrDIVIDUAL,-art.AtaD Tatvut star in t.he case of individual members of the public, the toneest is over the risk to which the individuals will be exposed. There appears to be agreement from many authors, that it is appropriate to apply the soneept of a trivial level of dose, or risk, in a purely individual-related assessanatt very small doses and the corresponding minute risk should not be of any I '#'
concerm. either for the regulator or for the individual himself For the individual thers are two asin considerations to deciding upon a trivial level of doset firstly choosing a level of risk which is of no significance to individuals thence a level of dose; secondly to use the existence of the natural background or radiation exposure, to the extent that it is normal and difficult to avoid, as a relevant reference level.
3.1.)
TheRisk-Basedconsiderat$1ons /
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In the first consideration it is widely recognised that levels of individual risk, which can be treated as insignificant by the decision-maker, can be judged as the point at which individuals Who are aware of the risks they tvn would not constit significant resources of their own to reduce them This is a diffleult point to judge because few people are conscious'of the magnitude of small cists and have little opportunity to demonstrate their preferences. There is likely to be a wide range of individual views on this subject and any decialen is likely to leave some people feeling that they are exposed to risks calling for further control.
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thatfewpeoplewouldseusnitkheirownresourcesisredutoanannualriskof deathofkO'andthatevenfewerwouldtakeactionatanannuallevelof
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10 Ilost authors proposing values of trivial individual dose 9er r N on have set the level of annual retteteen risk of death
~0 to 10"I d ich is held to be of no eencern to the individus1 at 10 Taking a rounded risk factet of 10"I Sv' for whole body a
exposure as a broad everage over age and ses I I, the level of trivial j
individual effective dose equivalent would be in the range 10-100 psy per year.
J 3 (2 setural tackaround Radiation considerations i
^i The level of natural background radiation has been judged to give a.
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dose of about 2 m8V per year This' average conceals a wide varieties i
due to different concentrations of radioactive asterials in the ground and in-building materials, as well as differences due to living at different altitudes. About h N f this dose is due to redon exposure, a source for l
which controls are suggested. The other half comes from exposure to sessia l-l rays, terrestris1 game rays and radionuclides in the body for which control l
is impractical.
l Individual members of the public do not generally take account of this variation in whole body natural background radiation when considering moving from one part of a country to another, or when going on holiday.
It can l-therefore be judged that a level of dose which is small in comparison with the variation in natural background radiation, can be regarded as trivial.. The figure of whole body or effective dose equivalent suggested by authors is of I'
the order of one to a few percetit of natural background
, i.e.20-100 wSV per year.
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The senclusion to be drawn is that a level of individual radiation dese, regardless of its source, is likely to begitt atsty be regarded as trivial if it-is of the order of eena 10's of wSv in a year.
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It is noted that this level of dose serresponds to a few persent of the annual dose limit for members of the publie is m ch emeller than any upper.
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f bound set by regulatory authorities.
7 The trivial individual risk level is most helpful in putting radiation risks to individuals into perspective. In most practical situations however.
l the regulatory need for en exemption arises in consideraties of eeurse.colated assessments, where the total detriment, is the primary parameter of interest.~
I L g SOURCE-RELATED RADIATION PROTECTION CRItent_A l
I Doses resulting from sources or practices involving exposure to ionising radiation or to radioactive substances shall, according to the Basis Safety Standards (para 401), be restricted b'y a system of dose limitation which shall include justification of the practice, optistsatten of radiation l
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protection, and annual dose limits. Acceptance of a practice will depend on many factors, mainly unrelatd to radiation protection. For this reason i
justification is not discussed further.
once a practice has been justified, it is necessary to design, plan and subsequently use the sources of exposure involved in'the practice to ensure that " exposures are as low as reasonably achievable, economic and social factors being taken into account". This means that although the doses to the l:
most exposed individuals, as a result of introducing a source of exposure, are L
below the relevant dose limits, it is ett11 necessary to " optimise", that is, i
reduce the doses to as low as reasonably achievable. One of the techniques to carry out this optimization introduced by ICRP is the use of differential cost-bonefit analysis
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la differential sost-benefit analysis, the seet of radiation health detrimmat ested, i.e. by reducing the doses, is eenpared erith the sost of intressing the level of protection. The optimum level of protection is achieved when the.next level opent on preteetten essoods the value of health detriment thereby everted. This technique therefore provides a meshenism for i
deciding on the terrect allocation of ressursos in protection against ionising radiation.
For eeurse-related assessments to be sortled out, the IAEA recommands a j
precedure of assigning a seet for unit health detriment se that detriment aan be'" costed" and eenpared trith costs of protection (1). The Internettenal
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Atomic Energy Agency has developed guidance on the minimum value to be assigned to unit collectivo dose till and has proposed US$ 8000 por aan.tv La 1983 prices.
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" Source / Practice-Related" Examotions 5rf Individual Dose considerations For the purpose of exemption, it was concluded that a level of individual effective dose equivalent of some 10's of v8v in a year sould reasonably be regarded as trivial by regulatory authorities.
secause an individual may be exposed to radiation doses, each of which t
j is from a source or practice that may have been judged e?.vapt, in' order to l
ensure his total dose does not rise above the individual exemption dose criterion, each exengt eeurce can only ut!!ise a part of that criterion. If
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14 is possible that an individual night be significantly exposed to doses frea L
several exempt sources or praettees, it may be reasonable for nettonal-authorities to apportion a fraction of the upper bound to each. This fraction could lead to critical group doses of the order of 10 vsv in a year from each exempt source.
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~It has to be recog sed.that the undertaking of optimisatten studies and Wir'taplementttien may be costly in tems of regulatory time and resources.
It can therefore be argued that where, in W absence of further protection esasures, the residual individual doses.and W selloative dose connitment are sufficiently small, W sost of performing the:optimisation any - j in itself outweigh the sayings in W sost of the potential reduction in.
health detriment.
In euch situations W rigorous use of eest-benefiti analysis would not be justified and the initial assessment of levels of, exposure may lead to e decision to exempt W material or sourse.. This.is not.
because the levels of dose and health detriment are of ne concern per so,'but because they are already optimaly A primary implication of.this approach is that each source mast' initially be assessed as if it were to be femally subjected to en optimisation procedure. practical experience suggests that the soot of femal optimization procedures will be et least several thousand. dollars [2,6). The uus of the IAgininua alue ofJ.he) men a of g. would lead to a-source-related Eo11gelige.
2n' 1 of the order of a few aan sv..For
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3 continuing practices this can be interpreted as a cosaitment of about 1 man Sy
'l per year of practice.
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7 RlLTERESCBS (1) 1ABA.'Rasic Safety Standards for Radiation Protection, Safety Series.
go. 9. (1982).
-(2)
ICRP.- The Application of Radiological Protection Principles to Radioactive Weste Disposal. Draft reprot of a Task Group of Committee 4 (1985).
[3]
WEA, Long Tara Radiological Protection Objoetives for Radioattive Weste.
-Disposs1. Experts report f or the WEA Radioactive Waste Managessot Cossnittee and the Cossaittee'on Radiation Protection and Publis Neenth, Paris (1984).
[4]
Royal Society of London. Risk Assessment A Study Group Report. by the Royal Society London (1983).
(5)
Baker. R.E., Cool. W.S., and Mills, W.A., WRC Draft revision of 10 CFR Part 20.
Cut-off level for Regulatory concern (De Minimis) p.17 (1983).
(6)
Clarke, R.H.. Fleishman. A.
The Establishment of de minimis radioactive wastes.-IRPA 6th Congress. West Berlin, May (1984).
[7]
Menhold. C.B.
Criteria for a de minimis level, US Health Physics Society. New Orleans 3-8 June-(1984).
[8)
ICRP. Recommendations of the ICRP. Publication 26 (1977).
[9]
UNSCEAR. - Report of. the United Nations Scientific Cossaittee on the Effects of Atomic Radiation. Ionisirig Radiationt Sources and Biological Effects, United Nations, New York (1982).
(10)
ICRP.
Cost-Benefit Analysis in the Optimitation of Radiation Protection. Publication 37 (1983).
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Itss-03 34:
00187
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- [11) 1 ARA. Costing Transboundary Radiation Erposure (The minim a value.
opplied to unit collective dose in differential cost-benefit analysis)
(1984).
I
[12)
.Outaand, R.J., Galpin, F.L., EPA's view on De Minials limits for.
nuclear radiation practice. Us Health rhysics society, sev Orleans, 3-8 June (1984).
[13)
-Davis, J.P.. The feasibility of establishing a "de sintais" level of radiation dose and a resulatory eut-off policy for nuclear reguistion.
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conoral Physics corp., Maryland, Us. er-a-33040 (1981).
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00197 1988-03 84 Chaster 4 Presaration and Administration of Ruanstions Derivation of exempt eventities in general, the methodologies to derive exenptions will be based on assessments of individual and tellective doses that any arise from the exempt practice. These assessments should be appropriate to the practice under examination and as comprehensive and reliable as to satisfy the authorities that respect of the radiological protection eriteria will be ensured. Other factors Which may bear on the final decision to axempt a practice saast also lee considered, in particular relevant national provisions (e.g. conservation laws) and social and econcate factors.
L-If a generic assessment, at its early stages, indicates that the likely con. sequences of exemption, in terns of dose, are below the chosen criteria, the authorities may well decide to lay down the quantities thus derived for insnediate use. There may be cases, howsvar, where such simplified procedure will be not satisfactory and more detailed assessments, including comparisons
& vo options, will,be required.
I with other available C ;,.
w In both situations, the assessment will be carried out using calculational models which take account of:
the characteristics of the practice to be exempted; the characteristics of the sources involved in the practice.
Sufficient flexibility should be allowed in the choice of models and in their sophistication in order to avoid the expenditure of resources out of proportion to the task involved. Thus, simple deterministic models may suffien for the purposes of a generic study addressing a well defined case for
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exemption. More elaborate modals will be needed in other situations and these i
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' ean be deteministici covering in detail a sufficient number of exposure scenarios, and/or probabilistic designed to provide a asasure of the vncertainty inherent in the modelling and the database used.
o.
W' The cholee of scenarios should be such as to aover all the likely pathways and exposure situations that arise as a result of the decision to exengt the practice in question. The national authorities will have to exercise judgment in considering exposure situations, associated _with low probability of occurrence, in which the chosen radiological protectica eriteria any be exceeded. In most esses, however, the adoption'ef suitably conservative assungttons would be sufficient to provide the desired degree of confidence in the results of the assessment. Otherwise, acre realistit-assumptions using more detailed models any be required.
In general the models will be required to provide estimates of doses _to workers and to members of the public. Both nomal and accidental exposure conditions should be covered; the letter, although unlikely, any have consequences serious enough to contra-indicato exemption. This eenelusion any also apply to cases of misuse of sources involved in the exempted practiae, and, therefore, the possibility of such misuse,will have to be considere(..
Approaches to setting the derived quantities using the models may involve either en iterative process whereby representative values of these quantities.
are selected and modell!ng carried out-to demonstrate compliance with the criteria chosen, or a normalisation process in which doses are computed corresponding to a unit exempt quantity, which subsequently leads to the evaluation of total amounts of sources that may be exempted in a given practice, which may continue for a well-defined time. In both cases the ultimate fate of the sources involved, and their likely re-utilisation sust be,
adequately covered.
In the calculation of individual and collective doses, particular attention should be paid to:
type of materials involved, physical and chemical characteristics, isotopic composition, surface and mass activity concentrations; total mass (es) and activities involved.
3
<3 J.
-00197 1984-03-24,
i aseeifiention for an examotion
[Sadiation sources. involved in an exemption usually pass from a stag r
t where they are regulated under a system of notification, registration er licensing to an exempt status. In other words there is a transfer from a sentrolled activity to an exempt activity.
It is important to clearly define the exemption so that persons making the transfer as well as regulatory authorities and persons in possession of exempt material have a cosumon understanding about What is exempted.
Exemptions are rarely, if ever, expressed-in tems of individual or sellostive dose since these parameters are not practical to measure at the operational I
I-
' level. Rather, exemptions should be expressed in quantities that are l
asesurable at the point of transfer so that compliance with the provistens of the exemption can be determined. A-cosuoon method used-to express the basic parameters of exemptions reisted to waste streams or recycle scrap are concentrations of specific radionuclides. In the case of-consumer products containing radioactive materials, the exemptions are often in tems of total setivity of a specific radioisotope in a sourc's and product.
t In addition to the basic parameters for-the exemption, there can'be-additional provisions in the exemption which enhance the probability that the assumptions about individual and collective doses upon which the optimization study for the exemption is based will not be invalidated and minimise accidents as well as misuse. Examples.of these additional provisions include:
i a) a constraint on the total activity penaguR5r which may be released in a year from a reguisted activity in an exempt waste stream; p.
E b) the chemical and physical form of the radionuclides permitted in the exempt waste strema as' well as a specification of the origin or the C
nature of the weste stream, e.g. cor aminated oil from reactor pumps; c) the chemical and physical form of the radionulcides contained in sealed sources employed in consumer products as well as design of the source and quality assurance requirements.
a.
'i
[., 4
/00197c 1983-03 l
~
.d.
d).the identification of the type of person to een recycled scrap any a
be sold, e.g. an automobile parts annufacturer, in order to better-
.soeurs that recyled scrap will not ents? products giving rise to high' i
. individual. exposures during the period of first recycle.
JL N;. l WG.
1
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)
Once the conditions of an exemption are clearly epocified, the next stop is to establish a method whereby the regulatory ~euthority een dete:1aine.
sempliance with the exemption conditions as transfers are made from a j
controlled status to an exoneted status. One practical method.to aceeglish this objective is to include in the regulated user's licence, authorisation to transfer the material to a recipient exempted from reguistion. The
]
application for a licence provides the regulatory authority an opportunity to review'in advance the procedures and methods )y Which the licensee will assure l,
compliance with the provisions of the exemption. The licence een sentain j
specific provisions which also enhance compliance with the provisions of the y
exemption.
For example the license can contain record keeping requirements L
which are subject to inspection. In the. case of contaminated scrap to be p
recycled, the license can specify the person to whom the scrap can be sold.
In the case of waste streams, the license can identify a' specific. land fill in' W ith the exempt wastes tan be placed. It can also contain reporting requirements regarding the amounts released under the exemption so that the regulatory authority can monitor the status cf use of the exemption, thereby-providing data for revalidation of the initial optimization study which formed the bases of the exemption. Wile not necessarily appropriate in all cases, these types of techniques can be used in the licensing process to better understand and control the ultimate impact of the exemption.
l
. Retrosoective snelvsis Finally, good radiation protection practice involves periodic reanalysis of the original optimization study which formed the basis of the exemption to l'
detemine if adjustments are appropriate. The foundation of such a reanalysis should include rarports of quantities released under the exemption, the results of compliance inspections of licensees making the exempt transfers, reports of misadventures with exempt materials and environmental sampling where feasible as well as testing of radioactive consumer products purchased in the market place.
_..~ _. _
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.000gy 1933 o3 3a Wo - 1 l
ADR$JLI
.j e
Proposed Definitions of some Practices and sources
- 1. ' Consumer products.
1 The ters consumer products covers a large variety of items of general use'and. emitting radiation or containing radioactive substances. They inalude,' for example, smoke detectors, tinspieces,' static eliminators, optical lenses,~ glassware, electron tubes, etc.
In principle. the sale and distribution of a number of sensumer products are subject in Member countries to notifisetton, registration and, often, licensing. There may be, however, some types of consumer products
)
[
Whose associated radiation risk and detriment are so ses11 that their sale and-I distribution could be exempted fron-licensing and, perhaps, even from I
notification and registration. -The general definitions and conditions given L
in sections qe-expressed in the following way for consumer products:
31.2 Q 'it.1,'4)
The " practice" is defined as the sale. distribution, use and diseosal of a niven troe of consumer oroduct on a jdational scale (the production of these items is considered as a separate practice Which 2
is usually subject to regulatory control.
The " source" is defined as the whole of individual radiosetive sources represented by the sinale items of the consumer oroduct being-considered.
As fer ce the correspondence to the features indicated in section 2.2.2 i
At.ctsectned, the situation is the following:'
conditiche. a) and b) are obviously satisfied by the definition given here for the practice;
5 1988 08-34 h'
00097-
=
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)
esadition c) can be fulfilled (the identified critical group een be aspeelfiegroupofusers,'efgroupoftransportanddistribution I
workers, or other; i
condition d) een be generally fulfilled. Thedtherslailer.
praettees" to be considered for the assessment of their fractional i
sontra on to the doses associated with the praettee under.
sonsideration are the sale and distribution of other types of consumer products; condition e) een be fulfilled without significant difficulties if the practice covers gag type of consumer product. This would be 1
acre difficult from the. technical viewpoint and complicated feca the administrative viewpoint if.the detinition of the practico, La order to comply with condition d), had to cover several different types of consumer products.
'2.-
Low Level Solid Radioactive Wastes In principle, the pract ce being considered for exemption is the disposal of very low level.oli radioactive wastes-to municipal landt111s or-j incineration facilities, or ato-the sea at coastal disposal sites. However, it is appropriate, for practical reasons, to' deal with exemption from each site at which the practice is carried out. Therefore in this case the
" practice" is defined as the disoosal of very low love radioactive wastes at a alven nunieinal landfill, or incinerator, or tal discesal site. This includes the operation of the site and the period of its remaining
'in existance after discontinuation of dispoor1. However, if more than one disposal sites-were located at a short distance from each other and gave comparable contributions to the dose of a same critical group, the practies should be defined to cover the combination of these disposal sites in order to satisfy condition d).
The " source" is defined as the complex of radiesetive wastes disposed of in the considered site (or group.cf sites).
As far as the correspondence to the features indicated in section 2.2.2. is concerned, the situation is the following:-
=
- j. ;,
ll 00097 1943-03-24 tendition a) is obviously satisfied by the definiton given here for' l
the practice; y
sendition b) any be less easy to fulfil. to fact.'although the;-
1 definition proposed above for the source refers to the Whole of waste stroane terminating in the disposal site, the regulatory out%itycouldfinditmorepracticaltoconsiderasthesourse'the.
installetion (or group of installation) from which the wastes are senerated; condition n be fulfilled (the identified critical group saa be the workers at the disposal site or a specific population group);-
i condition d) can be satisfied by a judicious choice of.the site (sites) to be included 12. a given practice and the installations l
,n from which the rele54 4 wastes are generated; condition e) any be less easy to fulfil due to the potentiel complexity and the variability of the set of installations and waste.
streams composing the source.
4 R
It is to be noted that a practice defined as in.this case would. cover one disposal facility or a small group of such facilities out of a much' p
):
greater total number of potential disposal facilities existing in a country.
I In this case...therefore, the national authority should apply the recommendation of section and take due account of the potential impact (1
.of the totality of disposal facilities in the country when decidit3 on its exemption policy.
According to another proposal which suggests s full application of the L'
above mentioned recomendation of section
, the " practice" to be l
considered for exemption should encompass the whole of low level solid wastes j
disoosal activities aeroes a country. In this case, the " source" should be defined as the whole of radioactive wastes disoosed of in the totality of
- _
- .ici;;! 1:ndfill :nf in:'n:::tir sites in the counter, i
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1988-03-24 j
0009y..
.d.
This definition of practice would certainly better costly with
.recosmondat1[ms of section
. However, its correspondence with the
]
features indicated'in section 2.2.2 would only be incomplete and the practical' application of the regulatory assessment and procedures for exemption would be-difficult.
In fact, as far as the above mentioned features are concerned:
o j
senditions a) and b) would, of course, sentinue.to be fulfilled;
"?,
- condition c) would be very difficult to apply in practice. It is.
in fact, unlikely that a unified. critical group could be identified r.
4 for the complex of disposal sites in the couttry; 1;
condition d) would not be relevant any further; condition a) would be very difficult to fulfil in practice.
h l
3.
Low Level Radioactive Effluents 1.
N In principle, the practice bein5 considered'for exemption is the-discharge of very small. quantities of airborne or liquid radioactive effluents from certain types of facilities where radioactive materials are produced-or manipulated. Examples of such facilities may include some radiochemical laboratories, research and educational institution, hospitale, manufacturing i
or other industries, etc.
Therefore, in this case the " practice" is defined as the discharme of low level _ radioactive effluents into the atmosphere or the savatic environment at a niven site. This covers the whole duration of the discharge operations.
If more than one installations were discharging thole effluents into the same environment and p, ave comparable contributions to the dose of a same critical group, the practice should be defined to cover the combination of the discharges from these installations in order to satisfy condition d).
3, i
0009y-1933 03-24
%].-
t The " source" is defined as the installation (or arous of installations) discharmina'the affluents considered, i
s As far as.the correspondence to the features indicated.in section 2.2.2-is concerned..the fellowing considerations apply:
conditions a) and b) are satisfied by the definitions given here for the practice and the sources condition'c) can be fulfilled (the critical group is usually a specific population group living in the surrounding of the installation or having particular living or dietary habits):
c condition d) een be satisfied by a judicious choice of the installation (s) to be defined as the " source":
-v condition e) may be more or less easy to fulfil depending on the 2
features of the environment receivint the discharges and of characteristics of'the population exposed.
4.
' Recycle or Reuse of Materiale Activated or contaminated materials-(steel, aluminum, concrete, etc.)
p
[
resulting, for example, from decomissioning of nuclear facilities could be l.
recycled or reused without radiological restrictions if a regime of exemption l
were. applicable to them.
In this case, the " practice" is defined as the set of activities startina from the release of the material (or materials) out of the boundary.
of reaulatory contr_n1 (for example, the boundary of a nuclear site) and i
includirig all,thA ooerations. manioulations and uses which lead to eroosure of a critical 1r.2gg (or groups).
The " source" can be defined as the radioactive material (s) to be recycled or reused or as the nuclear feellity(its) releasina the mat gial for recycle or reuse.
._ y
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Q-0009y -
1988-03-24 y'
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The scope of the defined practice and the definition of souco depend on-the features of these activities with reference to section 2.2.2 and on the particular exemption policy preferred by a national authority.
l: ;f.::
If it is preferred, for practical reasons, to dost with esemption h path. site producing material for recycle or reuse (e.g., an exemption for each
-(
1 nuclear power station to be decommissioned), then the " practice" would be defined to cover 3DlL.the matorist released from a given site end'it should be made sure that the critical group and population doses relative to that-q h
practice are not significantly affected by the contribution of materials 1
1 released (for the same kind of uses) from other nuclear sites in the country.
on the other hand, it could be considered that, be'eause different
-j E
asterials (e.g. steel, concrete, aluminum) are likely-to be used in largely l
different ways and-expose different groups of workers tad popuation, it eay' L
be sensible to define each material as a different " source".
In this ease.
the recycle and reuse'of each separtte stream of_ materials could be defined as a separate crectice, because it would have a different purpose-and would involve difforent exposure pathways and critical groups.
Moreover, some material (i.e. steel) released one year could well add to the exposure of the same group (s) as the (same type of) asterial released in another year from a same site or group of sites, so the " source" could comprise all the material of one type from one site', irrespective of the time' of.its production and release, and the " practice" definition could refer to4 L
the recycle and reuse of all that asterial igIespective of the time of its oroduction (i e. all the steel from decommissioning of-one or more power.
stations).
l The correspondence to the features indicated in section 2.2.2 can be seen in the following way:
condition a) can be fulfilled for any of the above-mentioned possible definitions of the source;
}4 condition b) can be more or less easy to fulfil, depending on the choice adopted for the definition of the source;
r..I
\\
M.. f* -
p 0.
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0009y.
1933 0s.34
~1-l;
' agndition c) can be fulfilled with different degrees of difficulty and specificity' depending on the definition' adopted for the sources'.
f 1
+
' eendition d) can be fulfilled by a judicious choice of the material (s) and site (s) composing a practicet.
[
a c
sendition e) can be more or less easy and comples to satisfy depending on the choice of the material (s) and site (s) comprising a l
practiae.
.i Once assin as for example 2. of this Annex, another possible proposal r
would be to consider as the " practice" to be exempted the ehole reevela er l
reuse of materials-moint on in a counter.
j In this case, the " source" would be the totality-of radioactive-materials beina recycled or reused, or the totality of nuclear sites oriainatinn-these materials.
X
.Once'again, as previously noted, such a broader definition of the practice would cattainly satisfy to the reconsmendation of section
, but it would. partially fulfil the conditions of section-2.2.2' and introduce o
J o
idifficulties anel complications-in the practical implementation of the p4
' E:
. regulatory asseessent and procedures required for the exemption.
s
- 5..la conclusion, although the general definitions and conditions. suggested l
in this document should be applied, it'is felt that national authorities will have, in practice, to define practices and sources taking into account their 2
local situations. For example, if several neighbouring power stations were L.
being decosmissioned at the same time and all their steel was going to the
.same smelter, explicit consideration should be given to the " overlap" question (see condition d) with regard to the workers at the smelter. This situation l,
would, of course, affect the definition of " practice" and " source" to be i
established in concrete.
[
F k,
[
r 3
.g,-
2988-03 24
? z,1 L90097' L L.
sendition e) can be fulfilled with different degrees of difficulty and specificity depending on the definition adopted for the source; sendition 4) een be fulfilled by a judicious shoice of the asterial(s) and site (s) eesposing-a praetteel condition e) can be more or less easy and scaples to satisfy depending en the choice of the mate =1al(s) and site (s) sosyrising's-practice.
Once-again as for example 2. of this Annex, another possible proposal wouldbetoconsiderasthe" practice"tobeexemptedthepolereeveleor reuse of materials moina on in a counter.
In this case, the " source" would be the totality of radioactive materials beir.a reeveled or reused or the totality of nuclear sites oriainatina these materials.
j ll Once again, as previously noted, such a broader definition of the practice would certainly satisfy to the recommendation of section
,but it would partially fulfil the conditions of section 2.2.2 and introduce difficulties and complications in the practical implementation of the
-l regulatory assessesnt and procedures required for the exemption.
f 5.
In conclusion, although the general definitions and conditi~ons suggested
-in this doeunent should be applied, it is felt that national authorities will have, in practice, to define practices and sources taking into account their local situatl@ns. F.or example, if several neighbouring power stations were
- being decommissioned at the same time and all their steel was going to the.
same smelter, explicit consideration should be given to the " overlap" question j
[see condition d) with regard to the workers at the smelter. This situation would, of course, affect the definition of " practice" and " source" to be established in concrete.
'4i
. u
.Depcrtment ef'Wuclerr Energy and SNfety-1ssue No. 2
~ Division of Nuclear Puel Cycle.and 1968 03-23' l
Division of wuclear safety-NOTIFICATION OF AN ACENCY-SPCWSORED MEETING l
i Title of meeting:
ACM on " Principles for the ExemP ion of'Rediation Sources and-t l
Practices from the Basic Safety Standards'fer Redletion ProtectionL l
Dates of_ meet _ing:
21-25 Merch 1988-Scientific Secretaries:
Mr. C..S. Linsley. WEWF Room A-2656; Ext. 2666 l
Mr. A. J..Conz61ez. NEWS Poom'A-2643; Ext. 2704~
l Mr. O. I1er1.-OECD/NEA Place of meeting:
Meeting Room C07-IV. VIC Secretary:
Ms. N. Barrios Room A-2661; Ext. 2667 PARTICIPANTS ADDRESS ABROAD ADDRESS IN VIEWWA PERIOD ARGENTINA Mr. D. Beninson CNEA Motel Astorie-19-26 Merch Avenide del Libertador 8250 1010 KErtner Stresse 32 l
1429 Buenos Aires Tel. 52 65'85-0 CANADA Mr. C. Jack Atomic Energy Control Board Motel Wendl 20-26 Merch Martel Building 1010. Petersplatz 9 l
270 Albert Street Tel. 636317 Ottowe, Ontario KlP 559 CZE_CHOSLOVAKIA Mr. 2. Dlouhy Nuclear Research' Institute Motel Alte Donau 21-25 North Ret 25068 Wagremerstresse 51 1220 Vienna 5
.'I
3.
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~
~
9'E 4j,y, 2-PARTICIPANTS ADDRESS. ABROAD ADDRESS IN VIENNA P d R I O D; FINt.AND 3
Ms. A. Selo
.Finnish Centre for P9distion Hotel Wendt 26 Merch' and Nuclear Safety 1010 Petersplatz 9
-P. O. Box 268 Tel. 636317 SF-00101 Helsinki t
F_RANC_E Mr. L. Fitoussi Adjoint au Directeur des Pension Pertschy-20-25 Merch j
Recherches de S4curith Nuc14alre 1010. Hobsburgergesse 5 IPSW/DRSW Tel. 533-70-94 l
Comunisseriet & l'Energie Atomique i
B. P. No. 6 l
92265 Fontenay-six-Roses Cedex i
l CERMAN DEMOCRATIC REPUB M Ms. S. Przyborowski Steetliches Amt fGr Atossicherhelt~
und-Strahlenschutz der DDR l
Weldowellee 117 1151 Berlin HUNCARY Mr. L. B. Sztenyik Frederic Joliot-Curie National Hotel Posi 20-25 MerchJ-i Institute for Radiobiology and
. 1010 Fleischmarkt 24 -
Rediation Hygiene Tel. 51 583-0 P. O., Box'1010 H-1775 Budapest :
ITALY Mr. M. Larste ENEA/ DISP Notel Nordbohn via Vitelleno Brancati 48 1020. Proterstresse 72 1-00144 Rome Tel. 24-54-33
'i l
JAPAN 20-29 March Mr. Minoru Okoshi
' Science and Technology Agency Motel Royag.
2-2-1 Resumigsske '
A-1010 Wien. Singerstresse 3-l Chiyode-ku
.Tel. 52-46-31 l
- Tokyo 9'
A &
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sMi 2_________,_ _ _ _ _ _ _ _<_ _ _ _ _ _ _ _ _ _,, _ _ _
___,,___w___-
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7
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PARTICIPANTS
-ADDRESS ABROAD ADDRESS IN VIENNA' P E R I g[3 '
SWITZERt.AND gc
~
20 26 Merch Mr. U. Wiederer Swiss Wuclear Safety Inspectorate Hotel'Kalserin Elisabeth 7
CM-5303 Wiirent ingen 1010. Weihhurggesse 3 Tel. 51 526-0 IMf1TED KINCDOM Mr. R. H. Clarke National Radiological Protection Board Pension Christine-20-25 March Chilton, Didcot 1010 Hefnersteig 7 0xon OR11 ORQ Te1. 5332961 U. S. A.
il Mr. A. Richardson Office of Radletion Programs U. S. Environmental Protection' Agency 401 M.: Street S. W.
Washington, D. C. 20460 U.S.S.R.
Mr. R. M. Berchuderov institute of Biophysics Schiffaillenstresse 95 20-27 March Moscow 1220 Vienne OBSERVERS:
Mr. C. Pomroy Atomic Energy Control Board Motel Wendt 20-25 Merch Mortel Building.
1010. Petersplatz 9 270' Albert. Street Tel. 636317 Ottawa Ontario
-K1P-SS9
+
CANADA Mr. C. Couvres Meelth and Safety Directorate Motel Am Stephensplatz.
20-25 March-COIWIISSION OF THE EUROPEAN CofGEMf1 TIES 1010 Stephensplatz 9:-
Jean Monnet Butiding Tel. 534 05 0 6
Rue'Alcide de Casperl L-2920 Luxembourg
- ~ ~.
~
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= -
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l
-.;[ 9
-4.
PARTICIPANTS ADDRESS ABItOAD
- ADDRESS IN VIEWWA-
.p E*R I O 9 Mr.
S.- Benassel EKA Motel R6saischer Kaiser.
21-23 March Vie vitelleno Broncett 48
..Tel. 512 17 51 1010.1 Ann *gesse 16 l
Y-00144. Rome ITAI.T Motel Royet-20-26 Merch-Mr. Toshikaru Toshide JAERI Tokal-sure. Wake-gun 1010. Singerstresse 3 Iberekt-ken JAPAN Mr. Shinichi Suge
'JAERI Motel Reyel 20-29 Merch-Tokel-unsre. Wake-gun 1010. Singerstresse 3 D erski-ken JAPAN Mr. F. Andalur
'Empresarios Agtvpedos Erzherzog Reiner 21-25 March l
C/Nege11ones 3-1040 Morertgasse 28015 Madrid (Wiedner Neuptstr. 27)
SPAIN Tel. 65-46-46.
Mr. D. J. Teple Empresarios Agrupados' Erzherzog Reiner 21-25 March C/Megollenes 3-1940. Morertgesse 28015 Madrid
- (Wiedner Hauptstr. 27)
SPA 1W Tel. 65-46-46 Ms. A. Magen INFITED WATIONS-SCIENTIFIC CUISTISSION OR
{
}.fFECTS OF ATontC RADIATION
'l Rm. E0421. Vienne Internet.lonel Centre
?
vienne. Austrie Mr. R. E. Cunningham US Nuclear Regulatory Commission Washington, D.' C. 20555 j
USA Ms. O. A.2vetkovo All Union Scientifle Center on Radletion Medicine-
-Elev USSR h
8 a.
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y
,y.
- mm_,
Issue No.12 DePertsent of Nuclear Energy,and Safety 1988 03-23~-
Division of Nuclear Puel Cycle end
' Division of Nucteer Safety NOTIFICATIOt8_OF AN ACEWCT-SPOWSORED 8WtETING Title of meetinE:
'ACM on " Principles for the Esemption of Radiation Sources'and Practices from the Basic Safety Standards for Radiation Protection l
Dctes of meeting:
21-25 March 1989 Scientific Secretaries:
Mr. C. S. Linoley WEWF 1
Room A-2654; Ext. 2666' Mr. A. J. Cons &ler WEWS Room A-2643; Ext. 2704 Mr. O. Ilari. OECD/WEA Floce of meeting:
Meeting Room C07-IV. VIC Secretary:
Ms. W. Barrios Room A-2661; Ext. 2667 PARTICIFAFTS ADDRESS ABROAD ADDRESS IN VIENe9A PEWIOO ARCEWTINA Motel Astoria 19-26 learch '
Mr. D. Beninson CWEA Avenido del Libertador 8250 1010 Kiirtner Stresse 32 1429 Buenos Aires Tel. 52 65 85-0 CANADA Mr. C. Jack Atomic Energy Control Board Notel Wendt 20-26 00erch~
Mortet Building 1010. PetersPlotr 9 270 Albert Street Tel. 636317 Otteere. Ontario EIP 559 CZECHOSLOVARIA 21-25 Merch Mr. 2. Dlouhy Muclear Research Institute Notel Alte Donau Ret 25068 Wagremerstresse 51 1220 vienne
l
, ;(
- 2 _. -
i 1
' PARTICIPANTS ADDRESS _ ABROAD ADDRESS IN VIENNA FERIOD t
F1NLAND Ms. A. Salo Finnish Centre for Radiation Notel Wandt 20-26 March-and Ikeclear Safety.
1010 Petersplatz 9 F. O. Box 263 Tel. 636317 SF-00101 HeIsinki
. CM_E l
l j
Mr. L. Fitoussi Adjoint au Directeur des Pension Pertechy 20-25 north Recherches de Securtte Nucleaire 1010 Habsburgergesse 5 IPSN/DRSN Te1. 533-70-94 l
Comunissariat & l'Energie Atomique l
B. P. No. 6 l
92265 Fontenay-six-Roses Cedex CERMAN DEMOCRATIC REPUBLIC i
Ms. S. Przyborowski Staatliches Amt fiir Atomsicherheit und Strahlenschutz der DDR Waldowellee 117 1157 Berlin H_UNCARY 8
Mr. L.
B. Sztenylk Frederic Joliot-Curie National Motel Post 20-25 March 1
Institute for Radiobiology and 1010. Fleischmarkt 24 Radiation Hygiene Tel. 51 583-0 P. O. Box 101C H-1775 Dudapest ITALY Mr. M. Larain ENEA/ DISP Motel Nordbahn via Vitaliano Brancati 48 1920. Proterstrasse 72 I-00144 Rome Tel. 24-54-33~
l JAPAN Mr. Minons Okoshi Science and Technology Agency Notel Royal 20-29 March-2-2-1 Kasumigaske'-
A-1910 Wien, Singerstresse 3 Chiyoda-ku
.Tel. 52-46-31 Tokyo.
~.
~ -
,+f7;,
4: -a- '
^
~
PARTICIPANTS
' ADDRESS ABROAD ADDRESS-IN VIENNA P E R I O 9.
SWIT2ER1AND Mr. U. Niederer Swiss Nuclear. Safety Inspectorate Motel Kaiserin Elisabeth 20-26 March CM-5303 WiirenIingen
- 1910. Weihterggesse 3
-Tel. 51 526-0 UNITED KINCDOM Mr. R. H. Clarke Wettonel Radiological Protection Board Pension Christine 20-25 Merchl Chilton. Didcot 1010. He'nersteig 7 Oxon 0K11 Ong
- Tel. 5332961 U. S. A.
Mr. A. Richardson Office of Radletion Programs U. S. Environmentel Protection Agency 3
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Mr. S. Benassel ENEA 1010. Annagesse 16
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ITALY l
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Mr. R. E. Cunninghen US Wuclear Reguietory Ceaunission L
Washington, D. C. 20555 USA Ms. O. A.Zwetkove All Union Scientific Center on Redistion Medicine-Kiev USSR
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