Ireland’s National Plan For
The Implementation of the OSPAR Strategy With Regard
to Radioactive Substances
Revised 2010
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Table of Contents
Executive Summary
4
1.
RSS Regions in relation to OSPAR Areas of Interest
5
2.
Legislation
6
3.
Natural Sources of Radiation in Ireland
6
4.
Use of Unsealed Sources in Ireland
7
5.
9
5.1
Trends in Irish Radioactive Discharges between 2004 and
2008
Discharges from the Medical Sector
5.2
Discharges from the Education and Research Sector
10
5.3
Discharges from the Oil and Gas Sector
15
6.
Environmental Monitoring
17
7.
Forecast to the Year 2020
20
8.
Review of Intermediate Goals
22
9.
Review and reporting procedures
28
10.
Looking Forward 2010 - 2015
28
9
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EXECUTIVE SUMMARY

The OSPAR Strategy with regard to Radioactive Substances (RSS) agreed at the 1998 OSPAR
Ministerial Commission Meeting at Sintra, Portugal has as its objective the prevention of pollution of
the maritime area from radioactivity through progressive and substantial reduction of discharges,
emissions and losses of radioactive substances with the ultimate aim of achieving concentrations in
the marine environment near background values for naturally occurring radioactive substances and
close to zero for artificial radioactive substances by the year 2020.

Contracting Parties to the OSPAR Convention agreed to publish national plans to show how the
RSS is being implemented in their respective countries. These should include, to the extent
necessary to ensure achievement of the objective of the Strategy, details on:
o
modifications of discharge authorisations;
o
technical improvements to reduce discharges; and
o
forecasts to the year 2020, as precisely as possible, of anthropogenic discharges and
releases of radioactive substances which may reach and affect the maritime area, according
to sector/activity and according to the region of the maritime area affected or likely to be
affected.

It also describes progress made since Ireland’s first National Plan adopted in 2002, including an
update on the intermediate goals contained in that Plan. This document outlines the current plans for
the implementation of the OSPAR RSS.

Ireland has no nuclear installations nor is there significant production of technologically enhanced
natural radioactivity. Consequently, the only sources of radioactive discharge to the OSPAR
maritime area from Ireland arise from the use of unsealed sources of radiation in the medical,
education and research sectors and from discharges of produced water by the oil and gas industry.

The use of unsealed sources of radiation at hospitals and at teaching and research facilities is
controlled by licence issued by the Radiological Protection Institute of Ireland (RPII) which is the
independent statutory body which regulates all uses of ionising radiation in Ireland. Licenses have
conditions attached which are specific to the nature of the activities carried out by the licensee.

The radionuclides used in largest amounts and which are discharged to the marine environment are
technetium-99m and iodine-131. Discharges to the environment are only permitted in accordance
with licence conditions set by the regulator. Such discharges are governed by clinical requirements
which take into consideration, inter alia, the ALARA (as low as reasonably achievable) concept.

Of the radionuclides discharged, the only one present in measurable concentrations in the marine
environment is iodine-131, which has a short half-life of 8 days. In 2007, the RPII undertook a
regulatory review of the need for installing iodine ablation holding tanks in hospitals. A multi-agency
Governmental and regulatory steering committee reviewed the RPII’s regulatory position and found
that position to be consistent with Ireland’s national commitments as a contracting party to OSPAR
(see further on page 26).

The use of unsealed sources, particularly in hospitals, is kept under regular review by the RPII.

The RPII carries out a monitoring programme of the Irish marine environment. This monitoring
programme is reviewed at regular intervals to ensure it is fit for purpose, including regarding
implementation of the OSPAR Strategy. This monitoring programme will continue to be kept under
review into the future. Further changes to the programme are expected to be made in 2010-11 when
the recommendations from a peer review of the RPII overall environmental monitoring programme,
carried out in 2009 are implemented.
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1. RADIOACTIVE SUBSTANCES STRATEGY (RSS) REGIONS IN RELATION TO
OSPAR AREAS OF INTEREST
1.
The OSPAR Convention for the Protection of the Marine Environment of the North East Atlantic
includes countries that have either a North East Atlantic coast or countries that discharge into the OSPAR
maritime area via their rivers. The map below shows the Radioactive Substances Strategy regions
(numbered 1 to 15) in relation to the five OSPAR Regions (colour-coded). Regions 1 and 4 are the regions of
relevance to all tables for Irish discharges profiles (or trends) provided later in this document.
© OSPAR Commission
1. Wider Atlantic, Iberian Coast and Biscay and Channel West
2. Channel - Cap de la Hague
3. Channel East
4. Irish Sea - Rep. of Ireland
5. Irish Sea - Northern Ireland
6. Irish Sea - Sellafield
7. Scottish waters - Dounreay
8. North Sea South - Belgian and Dutch Coast
9. German Bight
10. North Sea - Northwest, Southeast and Central
11. North Sea - Skagerrak
12. Kattegat
13. Norwegian Coastal Current
14. Barents Sea
15. Norwegian, Greenland Seas and Icelandic Waters
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2. LEGISLATION
2.
In general, Irish regulations governing the use of ionising radiation are derived from European
Directives which in turn are based on the recommendations of the International Commission on Radiological
Protection (ICRP).
3.
As a result of a continual process of reappraisal, ICRP recognised during the 1980s that the risks of
exposure to ionising radiation were greater than had previously been thought. ICRP published new general
recommendations in 1991, ICRP 60 1, which updated the standards in ICRP 26 2 and further developed the
conceptual framework. In particular ICRP 60 distinguishes between practices (activities that increase human
exposure) and intervention (actions taken to decrease human exposure in an actual situation). ICRP 103 3,
which supersedes ICRP 60, will underpin the new European Basic Safety Standards Directive (usually
referred to as BSS) which is currently being developed.
4.
The current BSS Directive (Council Directive 96/29/Euratom) is implemented in Irish national
legislation by the Radiological Protection Act, 1991 (Ionising Radiation) Order, 2000, (Statutory Instrument
No. 125 of 2000). This statutory instrument provides the framework for the Radiological Protection Institute of
Ireland’s (RPII) licensing system and details the general radiation protection requirements for all users of
ionising radiation.
5.
The objective of the RPII in exercising its licensing function is to prevent unnecessary uses of
radioactive substances, to minimise their use to the levels required for the intended purposes and to maintain
tight control on the quantities of radioactive wastes discharged to the environment. In the context of the
OSPAR Strategy, specific conditions are attached to each licence granted to ensure that, with the exception
of patient excreta arising from the medical sector, discharges are kept within specified daily limits and
stringent recording requirements are included. Discharges of radionuclides contained in patient excreta are
regulated through the maximum licensed activities of individual radionuclides that facilities are authorised to
use, and hence discharge, each year.
3. NATURAL SOURCES OF RADIATION IN IRELAND
6.
Hazards from ionising radiation due to natural sources of radiation are covered within Ireland’s
Radiological Protection Act 1991 (Ionising Radiation) Order 2000 (S.I. No. 125 of 2000) Part 6 (Work
Activities Involving Natural Radiation Sources). NORM (Naturally Occurring Radioactive Material) in Irish
workplaces is subject to regulation if it is liable to give rise to a radiation dose of greater than 1mSv/year.
7.
Between 2002 and 2008, the RPII investigated the main industries operating in Ireland that deal with
NORM to determine the level of radiation to which workers and members of the public were exposed as a
result of their work practices4. The conclusions from this investigation were that:
-
Radiological Protection Institute of Ireland (RPII)none of the industries reviewed was giving rise to an
effective dose to workers or members of the public in excess of 1 mSv above background in any 12month period;
-
None of the industries reviewed were giving rise to significant production of technologically
enhanced natural radioactivity with subsequent discharge into the OSPAR maritime area.
8.
It was therefore concluded that Irish NORM industries were not falling under the scope of Irish
legislation from the point of view of the discharges or occupational exposure and, as a consequence, these
are not regulated by the RPII.
9.
The natural gas extracting industry is the only sector currently operating in Ireland discharging
natural radionuclides into the OSPAR maritime area5. These discharges arise from small quantities of
1
ICRP, 1991. 1990 Recommendations of the International Commission on Radiological Protection. Publication 60. Ann.
ICRP 21(1-3). International Commision on Radological Protection. Oxford: Pergamon Press.
2
ICRP, 1977. Recommendations of the International Commission on Radiological Protection. Publication 26. Ann. ICRP
1(3). International Commision on Radological Protection. Oxford: Pergamon Press.
3
ICRP, 2007. The 2007 Recommendations of the International Commission on Radiological Protection. Publication 103.
Ann. ICRP 37(2-4). International Commision on Radological Protection. Oxford: Pergamon Press.
4
Organo C. and Fenton D. (2008) Radiological assessment of NORM industries in Ireland – Radiation doses to workers
and members of the public. RPII report available at www.rpii.ie.
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radium-226, radium-228 and lead-210 that are contained in the produced water which is extracted with the
natural gas at the point of extraction. Arrangements are in place to report these discharges to the OSPAR
commission on an annual basis.
10.
The enhancement of natural radionuclide concentrations arising from these industries is dealt with in
accordance with best international practice. Policy in this area is kept under continuous review in order to
ensure that the highest possible standards are maintained.
4. USE OF UNSEALED SOURCES IN IRELAND
Nuclear Installations
11. There are no nuclear installations in Ireland and there are no industrial activities giving rise to
significant radioactive discharges to the marine environment. The development of a domestic nuclear power
industry is prohibited by law and current Government policy is that nuclear power is an unsustainable energy
source and not an option for Ireland.
Artificial Radioactivity in the form of Unsealed Sources
12.
Discharges of artificial radionuclides to the Irish marine environment arise from the use of unsealed
sources of radiation at hospitals, teaching facilities and research establishments. These are controlled by
licences that are issued by the RPII.
13.
Each applicant for a licence is required to specify the particular radioactive substances to be used,
the purpose for which they are to be used and the expected quantities. All applications are carefully
examined by the RPII. Licensees are licensed for custody, use, disposal and, where appropriate, importation
on an annual basis, of a maximum amount of a given radionuclide or combination of radionuclides.
14.
A schedule is attached to each licence specifying the maximum activity of each radioactive
substance which may be used by the licensee in a year. Specific conditions relating to the disposal of
radioactive substances are also attached to each licence. The licensee is required to keep detailed records
of all acquisitions and disposals of radioactive substances and to make these records available to the RPII.
15.
Guidance published by the UK Environment Agency6 is used to obtain best estimates of the quantity
of each radionuclide discharged. Table 1, which summarises the guidance, gives information on the fraction
of the activity administered to patients that is assumed to be present in liquid discharges from hospitals.
Percentage of Administered Radionuclides in Discharges
(Medical Sector)
Radionuclide
I-131
Tc-99m
Application
Percentage discharged
Ablation therapy
100%
50% - in-patients*
30% - out-patients*
Thyrotoxicosis treatment
Diagnostic imaging, functional
studies
P-32
Ga-67
I-123
Others
As MIBG
Any other compound
30%
30%
30%
60%+
100%+
100%ψ
5
There are a small number of oil exploration sites in the Atlantic Ocean off the West Coast of Ireland under licence from
the Irish Government and natural gas is exploited from an offshore location on the South West Coast. Further plans for
the exploitation of a natural gas field in the Atlantic are under way.
6
McHugh J.O. (1999) Regulation and Management of Radioactive Waste Establishments in the UK. Workshop on the
Management of Radioactive Waste from Medical Establishments, CEC.
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* For thyrotoxicosis treatment, there is no specific information on the distribution of administrations between
in-patients or out-patients. Based on knowledge on procedures in certain hospitals, it is assumed that most,
if not all, will be treated as out-patients. Therefore the 30% fraction is applied.
+There are no data on the fraction of I-123 used for MIBG (meta-iodobenzylguanidine). Therefore it is
assumed that 100% is discharged.
ψ In the case of all other radionuclides used in diagnosis and treatment and other applications of unsealed
radioactive sources, it is conservatively assumed that 100% of the licensed amount is discharged to the
sewage system.
16.
No account is taken of reductions in activity due to radioactive decay between importation and
usage/discharge. Where licensees are known not to discharge to the sewage system, the data for these
licensees are not included in the calculations of total amounts discharged.
17.
The radionuclides used in largest amounts and which are discharged to the marine environment are
technetium-99m and iodine-131. The use of fluorine-18 in PET/CT studies is increasing in Ireland, however
due to its short half life (109 minutes) it does not persist in the environment and thus, is not considered in this
report. Of the radionuclides discharged from the medical sector only iodine-131 is present in measurable
amounts in the marine environment.
Unsealed sources used by the Medical sector
Technetium-99m
18.
Tc-99m is used extensively in hospitals for diagnostic imaging purposes. It is often the radionuclide
of choice due to its short half life (6 hrs) and the emission of a readily detectable 140 keV gamma ray. It is
used for a variety of imaging and functional studies for organs such as the brain, lungs, liver, gallbladder,
kidneys as well as for the skeleton, blood and tumours.
19.
At the end of 2008, twenty-one hospitals throughout Ireland were licensed by the RPII for the use of
Tc-99m for in-vivo applications. There are an additional six hospitals which are licensed for in-vitro
applications involving unsealed sources, but these are not considered further in this report as the
radionuclides used are not discharged but rather stored to decay.
Iodine-131
20.
I-131 is used for treating overactive thyroids (thyrotoxicosis), in which MBq activities are
administered to out-patients, and for the treatment of thyroid cancers (ablation therapy), where GBq activities
are administered to in-patients.
21.
In Ireland, patients undergoing thyroid ablations where high activities of I-131 are administered are
always treated as in-patients. Special facilities, including a dedicated recovery room, which is designed and
equipped to minimise the spread of radioactive contamination, must be provided for the patient.
Unsealed sources used by the Education and Research sector
22.
The nature of activities resulting in discharges is principally biological and pharmacological science
research-based and discharges take place via a dedicated sink to a foul sewer.
23.
In general, the discharges are estimated by analysing an aliquot of the relevant waste by liquid
scintillation counting.
Manufacturing of GTLD’s and ICSD’s
24.
No gaseous tritium light devices (GTLD) are manufactured in Ireland. While ionisation chamber
smoke detectors (ICSD) are assembled in Ireland with imported americium-241 sources, a requirement
exists whereby any disused sources are returned to the original supplier at the end of their useful life and
exported to the source manufacturer. Some difficulties have been noted regarding the return of third party
ICSDs but efforts are underway between the relevant stakeholders in trying to resolve the matter under the
framework of the Waste Electrical and Electronic Equipment Directive (2002/96/EC) as implemented in
Ireland by S.I. No. 875 of 2005. These sources are not discharged to the marine environment and so are not
considered further in this document.
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5. TRENDS IN IRISH RADIOACTIVE DISCHARGES BETWEEN 2004 and 2008
26.
The magnitudes of discharges of different radionuclides and from the different sectors vary widely.
For this reason, discharge data are not standardised to one unit of activity, instead the most appropriate unit
of activity is used. For comparison purposes, 1 gigabecquerel (GBq) is equivalent to 1000 megabecquerel
(MBq) and 1 MBq is equivalent to 1000 kilobecquerel (kBq).
5.1 Discharges from the Medical sector
27.
The main radionuclides discharged by the medical sector are iodine-131 and technetium-99m, both
of which are short-lived.
28.
In 2008 twenty-two medical facilities were licensed by the RPII to use unsealed sources of radiation
which resulted in routine discharges of radionuclides to the sewage system. As one facility used fluorine-18
exclusively, it is not considered further in this report.
29.
At the end of 2008, nine hospitals in Ireland were licensed for the use of I-131 to treat thyrotoxicosis,
three of which additionally carried out ablation therapies.
30.
Two of the hospitals licensed to carry out ablation therapies are located on the East Coast of Ireland
while the third one is located on the South Coast. Each of these hospitals operates a single ablation suite
with the two East Coast hospitals discharging waste (patient excreta) directly to the sewage system and
ultimately into the marine environment. The South Coast hospital uses a bespoke 1000-litre holding tank
which allows for the decay of patient excreta, containing iodine-131, prior to discharge to the sewers.
Trend in technicium-99 (Tc-99) discharges (in kBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
15.0
17.7
16.3
15.6
15.5
Discharges to Irish Sea
(Region 4)
27.6
28.8
29.3
29.8
31.0
42.6
46.5
45.6
45.4
46.5
Discharged in
(reported in )
Total
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here have been scaled up accordingly (i.e.
multiplied by 2).
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Trend in iodine-131 (I-131) discharges (in GBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
20.54
43.97
53.15
46.06
59.95
Discharges to Irish Sea
(Region 4)
327.0
337.1
366.1
429.4
420.5
347.54
381.04
419.25
475.41
480.46
Discharged in
(reported in )
Total
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here have been scaled up accordingly (i.e.
multiplied by 2).
5.2 Discharges from the Education and Research sector
31.
The practices giving rise to discharges from this sector are principally biological and pharmacological
science research based and discharges take place via a dedicated sink to a foul sewer. Data on discharges
of tritium, carbon-14, phosphorus-132, sulphur-35, chromium-51 and iodine-125 are presented and yearly
variations for individual radionuclides are described below.
Trend in tritium (H-3) discharges (in MBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
2825.0
194.9
10.3
14.4
101.7
Discharges to Irish Sea
(Region 4)
475.6
770.6
998.5
837.1
3231.4
3300.6
965.5
1008.8
851.5
3333.1
Discharged in
(reported in )
Total
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1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
Trend in carbon-14 (C-14) discharges (in MBq) between 2004 and 2008
Discharged in
(reported in )
Discharges to Atlantic Ocean
(Region 1)
Discharges to Irish Sea
(Region 4)
Total
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
28.68
0.00
3.80
0.00
0.00
0.1
60.6
1006.6
67.1
405.8
28.78
60.63
1010.40
67.10
405.80
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
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Trend in phosphorus-32 (P-32) discharges (in MBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
87.2
334.9
9.4
8.3
100.0
Discharges to Irish Sea
(Region 4)
93.5
63.3
31.6
46.0
46.0
180.7
398.2
41.0
54.3
146.0
Discharged in
(reported in )
Total
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
Trend in sulphur-35 (S-35) discharges (in MBq) between 2004 and 2008
Discharged in
(reported in )
Discharges to Atlantic Ocean
(Region 1)
Discharges to Irish Sea
(Region 4)
Total
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
101.80
92.50
31.00
0.66
37.50
14.1
0.0
629.5
4.0
5.0
115.86
92.50
660.51
4.66
42.50
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
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Trend in chromium-51 (Cr-51) discharges (in MBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
0.00
0.00
0.00
0.00
0.00
Discharges to Irish Sea
(Region 4)
0.96
0.12
0.95
0.02
0.00
0.96
0.12
0.95
0.02
0.00
Discharged in
(reported in )
Total
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
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Trend in iodine-125 (I-125) discharges (in MBq) between 2004 and 2008
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
Discharges to Atlantic Ocean
(Region 1)
0.00
0.00
0.00
43.68
0.00
Discharges to Irish Sea
(Region 4)
52.5
106.8
141.0
195.0
195.0
52.5
106.80
141.00
238.68
195.00
Discharged in
(reported in )
Total
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here for the Education and Research sector have
NOT been scaled up due to the irregular discharge frequency throughout the year.
Yearly variations in discharges from the Education and Research sector
32.
The use of radionuclides in this sector varies from year to year, as their use is linked to specific
research programmes and projects. Some of these projects are ongoing but others are for short periods of
time only.
2004 (July to Dec):
 The figures are based on results reported by 8 educational establishments and 8 commercial
research laboratories that use the specified radionuclides.
 For some establishments no radionuclides were discharged during the period in question.
2005:




The figures are based on results reported by 8 educational establishments and 6 commercial
research laboratories that use the specified radionuclides.
For 3 establishments, no radionuclides were used or discharged during the period in question.
The discharges for H-3 have decreased reflecting the decreased usage of the radionuclide at a
number of centres.
For strontium, chromium and iodine, each radionuclide is discharged from a different
establishment.
2006:


The figures are based on results reported by 8 educational establishments and 5 commercial
research laboratories that use the specified radionuclides.
Five of the 13 establishments reported no discharges for the period in question.
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




The discharges for P-32 have decreased since last year reflecting the decreased usage of the
radionuclide particularly at one site.
The discharges for S-35 have increased since last year reflecting the increased usage at
another site.
The contribution for chromium is from one site.
The increase in the C-14 discharges was a result of a once-off discharge by a Government
research laboratory. The use of radionuclides has now ceased at this facility.
The figures for tritium reflect the increased usage by one university due to a particular research
programme.
2007:





The figures are based on results reported by 9 educational establishments and 4 commercial
research laboratories that use the specified radionuclides.
Two of the 13 establishments reported no discharges for the period in question.
The discharges have decreased since last year reflecting the decreased usage of the
radionuclides, particularly S-35.
The discharge value for I-125 has increased due to an additional university contributing to the
data.
The contribution for chromium is from one site.
2008:




The figures for 2008 are based on results reported by 9 educational establishments and 3
commercial research laboratories that use the specified radionuclides.
Four of the 12 establishments reported no discharges for the period in question.
The discharges have increased compared to 2007, reflecting the increased usage of the
radionuclides, particularly H-3 and C-14, in the research programme of one university.
Increases in the discharges of P-32 and S-35 were also noted, which were due to specific
research programmes.
5.3 Discharges from the oil and gas sector
33.
As previously noted, the natural gas extracting industry is the only sector currently operating in
Ireland discharging natural radionuclides into the OSPAR maritime area. These discharges arise from small
quantities of radium-226, radium-228 and lead-210 that are contained in the produced water which is
extracted with the natural gas at the point of extraction. The discharges are relatively constant and reflect the
volume of produced water discharged.
Trend in lead-210 (Pb-210) discharges (in MBq) between 2004 and 2008
Discharged in
(reported in )
Discharges to Atlantic Ocean
(Region 1)
Total
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
3.60
2.70
2.04
2.20
3.00
3.60
2.70
2.04
2.20
3.00
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here have been scaled up accordingly (i.e.
multiplied by 2).
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Trend in radium-226 (Ra-226) discharges (in MBq) between 2004 and 2008
Discharged in
(reported in )
Discharges to Atlantic Ocean
(Region 1)
Total
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
5.60
4.10
2.36
3.11
4.39
5.60
4.10
2.36
3.11
4.39
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here have been scaled up accordingly (i.e.
multiplied by 2).
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Trend in radium-228 (Ra-228) discharges (in MBq) between 2004 and 2008
Discharged in
(reported in )
Discharges to Atlantic Ocean
(Region 1)
Total
20041
(2005)
2005
(2006)
2006
(2007)
2007
(2008)
2008
(2009)
0.78
0.64
0.60
0.59
0.90
0.78
0.64
0.60
0.59
0.90
1
The data for 2004 only cover the period from July to Dec 2004 (6 months). This was an initial OSPAR 'trial
run' of the reporting procedure. The 2004 figures quoted here have been scaled up accordingly (i.e.
multiplied by 2).
6. ENVIRONMENTAL MONITORING
34.
The RPII carries out a radioactivity monitoring programme to measure the levels of radioactivity in
the Irish marine environment. Both coastline and offshore sampling locations of this monitoring programme
are shown on the maps below. Monitoring results are published regularly and are available on the RPII web
site (www.rpii.ie).
The primary objective of the current marine monitoring programme is to assess the exposure of the Irish
population to radioactivity resulting from radioactive contamination of the Irish marine environment and to
estimate the associated risks to health. In addition, the programme aims to assess the distribution of
contaminating radionuclides and to identify long-term trends. The programme involves the routine sampling
of and testing for radioactivity in fish, shellfish, seaweed, sediments and seawater.
In recent decades Irish coastal waters have been influenced by a number of artificial sources. These include
discharges from nuclear installations, fall-out from the Chernobyl accident in 1986, atmospheric nuclear
weapons testing during the 1950s and 1960s and discharges to sewage from some hospitals of
radionuclides used for medical purposes. The most significant of these sources is the discharge of low-level
radioactive waste from the nuclear fuel reprocessing plant situated at Sellafield in the north-west of England.
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Environmental Monitoring Locations
Coastline sampling locations
Offshore sampling locations (N1 to N6 points)
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35.
Iodine-131 is the only radionuclide arising from discharges from Irish hospitals and other Irish
facilities that has been detected in Irish coastal waters. The monitoring of this radionuclide has been focused
on the Dublin area where two of the three hospitals providing ablation treatments are located. Activity
concentrations of iodine-131 in seaweed in the Dublin Bay area have been found to vary greatly depending
on the timing of sampling in relation to administration of large doses of I-131 to patients at local hospitals.
Concentrations between 5 Bq/kg (dry) and 278 Bq/kg (dry) were observed in seaweed collected at a
sampling location in Dublin Bay, however given the short half-life of iodine-131, peaks in concentration levels
are short-lived and do not persist into the Irish Sea. These data are available for use in setting baselines and
Ireland will be guided in this matter by the Radioactive Substances Committee of OSPAR.
Review of Marine Monitoring Arrangements
36.
The RPII’s marine monitoring programme is reviewed on an annual basis and changes are made to
reflect geographical and temporal trends in radioactivity in seawater, sediment and biota. These changes
take into account Ireland’s monitoring commitments to the OSPAR strategy to ensure they continue to be
fulfilled.
37.
The results of the monitoring programme and associated research studies have shown that the
levels of I-131 were low and of no concern from a radiological point of view. Monitoring of I-131 was
discontinued in 2005.
38.
This radionuclide along with other radionuclides discharged into the OSPAR marine environment
from Irish facilities are kept under review.
39.
An extensive review of the marine monitoring programme took place in 2008, following a habits
survey carried out on behalf of the RPII 7. This review determined that the marine monitoring programme was
fit for purpose and only minor changes were made to the monitoring programme, none of which impacted on
Ireland’s OSPAR commitments.
40.
The marine monitoring programme will continue to be reviewed into the future. Further changes to
the programme are expected to be made in 2010 arising from a peer review of the RPII overall
environmental monitoring programme8 and also from a Tc-99 modelling project that may impact on the
sampling frequency and locations for Tc-99 monitoring.
41.
The monitoring data arising from the Irish monitoring programme that are currently reported to
OSPAR are outlined in the table below.
7
F.J. Clyne, C.J. Garrod, T.M. Jeffs and S.B. Jenkinson (2008) An assessment of aquatic radiation pathways in Ireland.
Environment Report RL 16/08, CEFAS contract report C3030.
8
P. Mitchell, J. Hunt, K. Ledgerwood, S. Nielsen and C. O’Donnell (2009) A peer review of the RPII environmental
monitoring programme.
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Irish Monitoring Data submitted to OSPAR
Cs-137/ Cs-134
Tc-99
One location
monthly
One location
monthly
Thirteen locations
quarterly to every 2
years
Thirteen stations
quarterly to every
2 years
Seaweed
Three locations
quarterly to
annually
One location
quarterly
Sediment
Three grab
samples
Fish9
Four areas
quarterly to
annually
Seawater
Shellfish
Four locations
quarterly to
annually
Tritium
Gammaemitters
Others
Pu-isotopes /
Am-241
Began monthly
sampling in
2008
Samples
analysed by
gammaspectrometry
K-40 in all
the samples
3 grab samples
Two locations
annually
Pu(α)10
Two locations
annually
Four locations
(one monthly,
two quarterly,
one every 6
months)
7. FORECAST TO THE YEAR 2020
42.
The tight controls exercised by the RPII on the use of radionuclides in the medical, education and
research sectors minimise the risk of unauthorised discharges occurring. All uses of radioactive substances
must be justified and optimised in terms of radiation protection and application of best available technique.
Current discharges have been examined by the RPII and downward pressure has and will continue to be
exerted on these discharges where appropriate.
Medical sector
43.
It is anticipated that over the next five to ten years, there will be a 50% increase in the demand for
iodine ablation treatments in Ireland 11. The graph below shows the I-131 discharges as reported to OSPAR
between 2004 and 2008 together with the level of discharges forecasted to occur by the period 2015-2020.
9
Fish includes cod, plaice, herring, mackerel, ray.
10
Pu isotopes measured in composite samples of whiting, cod, and plaice from two locations.
11
Enviros Consulting Ltd. (2008) Review of best practice in relation to iodine-131 ablation discharges to sewer. Final
Report Version 3.1, modified by the RPII in Feb. 2009.
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Education and research sector
44.
The use of radioisotopes by the education and research sector for tracer studies can fluctuate
considerably from year to year. This is a reflection of changing research priorities within this sector and is
significantly influenced by the availability of research grants /funds etc. This makes predicting future trends in
discharges almost impossible for this sector. However, based on current and historical discharge data for the
sector no difficulties in meeting future OSPAR commitments are anticipated.
Oil and gas sector
45.
The natural gas extracting industry is the only sector currently operating in Ireland discharging
natural radionuclides into the OSPAR maritime area. These natural radionuclides are extracted from the well
with the natural gas and are discharged to the sea in produced water following gas processing. The amount
of produced water currently discharged by Ireland is very low due to the fact that the gas extracted is nearly
pure methane with very low content of water. Despite the fact that this volume is expected to double from
current levels once the Corrib gas field commences production (current estimate 2012), the amount of
natural radioactivity discharged will remain below 10 MBq per marker radionuclide.
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8. REVIEW OF THE INTERMEDIATE GOALS SET IN THE FIRST (2002) NATIONAL
PLAN
Intermediate Goals for Implementing the Strategy (taken from the 2002 National
Plan)
Step
1
2
3
4
5
6
7
8
9
10
11
12
13
Intermediate Goals
Complete review of waste management policies
Establish best estimate of discharge profiles for all
facilities licensed to hold unsealed sources in Ireland
Update marine monitoring arrangements following
review
Amend licence conditions of all users of unsealed
sources to include a discharge limit
Establish accurate discharge profiles for the principal
facilities licensed to hold unsealed sources in Ireland
Implement more stringent discharge reporting criteria
Complete environmental impact assessments for
marine discharge sites including doses
Take a decision on the installation of holding tanks to
facilitate the decay of iodine-131 in new hospitals
Take a decision on the back fitting of holding tanks to
existing facilities
Establish a baseline for concentrations in the marine
environment, discharges and doses arising from
discharges from Irish facilities in line with deliberations
from OSPAR RSC
Provide an assessment of the impact on future
discharges of the Irish Government’s health strategy
Instruct licensees to provide an assessment of the use
of best available technology (BAT) with respect to
discharges
Awareness campaign amongst licensees of the OSPAR
requirements
Target Delivery
Date
June 2002
June 2002
End 2003
Mid 2003
Mid 2004
Mid 2004
End 2004
End 2005
End 2005
(2003) *
(2003)*
(2005) *
On-going
* - Dates in brackets were provisional dependent on the outcome of other initiatives
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1. Complete review of waste management policies
46.
In preparation for Ireland’s report to the IAEA Joint Convention on the Safety of Spent Fuel
Management and on the Safety of Radioactive Waste Management in May 2006, the RPII undertook to
review the current inventory of radioactive sources, both sealed and unsealed, that are no longer in use, and
to provide the updated information to the Government for their ongoing deliberations. This review sets out:
o
o
o
o
o
o
o
the legislative context within which radioactive sources are controlled including the
legislation that deals with their disposal,
the type of ‘take back’ arrangements that are in place for sources and the weaknesses in the
current system,
the current provisions on the security of sources and how these arrangements may need to
be strengthened,
the types of sources that do and can contribute to the waste/disused source inventory and
the status of the current inventory,
the case for the establishment of a central radioactive waste storage facility for the interim
storage of disused sources including the observations of various international agencies,
the practical measures that could be taken to minimise the numbers of sources that would
require storage in a central facility,
the issues that need to be included in the development of a national policy on the
management of all type of radioactive waste.
47.
In 2009, the report of the inventory of radioactive waste in Ireland, prepared in 2006, was updated in
preparation for the 3rd Review Meeting of the Joint Convention on the Safety of Spent Fuel Management and
on the Safety of Radioactive Waste Management.
48.
A high level inter-departmental Working Group, Chaired by the Department of the Environment,
Heritage and Local Government, was established in September 2008 to consider and advise Government on
best policy and practice for the safe long-term management of Ireland's radioactive waste materials.
49.
The report of this Group is expected to be presented to the Irish Government by the Minister for
Environment Heritage and Local Government in 2010, to advise Government on the best policy for Ireland in
the management or radioactive waste material and sources. This report is expected to cover issues such as
the need for a central storage facility and it will also identify the key elements of an integrated radioactive
waste management strategy for Ireland.
2. Establish best estimate of discharge profiles for all facilities licensed to hold
unsealed sources in Ireland AND 5. Establish accurate discharge profiles for the
principal facilities licensed to hold unsealed sources in Ireland
50.
See section ‘Trends in Irish radioactive discharges between 2004 and 2008’ page 9.
3. Update marine monitoring arrangements following review
51.
The Irish marine monitoring programme is reviewed regularly and, since 2002, a number of revisions
to the programme took place to reflect the observed geographical and temporal trends in radioactivity in
seawater, sediment and biota. These updates take into account Ireland’s monitoring commitments to the
OSPAR strategy to ensure they continue to be fulfilled.
52.
As a part of a review in 2002, it was recommended that a research project should be undertaken to
specifically monitor I-131 discharges to the main sewage treatment facility in Dublin, and from there to the
Dublin Bay area. This was in addition to routine monitoring being undertaken of I-131 levels in seaweed from
Dublin Bay.
53.
The monitoring and research data collected were used to establish baselines for I-131 in seaweed.
Both the monitoring and research project showed that I-131 concentrations were low when compared to the
quantities being discharged by the hospitals and of no risk to members of the general public from a
radiological point of view (i.e. negligible doses). Based upon these findings, the I-131 monitoring programme
was discontinued from 2005. This radionuclide along with other radionuclides discharged into the OSPAR
marine environment from Irish facilities are kept under review. The need to monitor this and other
radionuclides in the future will be based on levels of discharges or forecast concentrations in the marine
environment.
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54.
Another extensive review of the marine monitoring programme took place in 2008, following a habits
survey carried out on behalf of the RPII12 to provide an assessment of aquatic radiation exposure pathways
in Ireland relating to anthropogenic radioactivity in the Irish Sea. This review concluded that the sample types
and the sampling frequency as specified in the monitoring programme were satisfactory to determine the
doses received by the Irish population from anthropogenic radioactivity in the Irish Sea, and recommended
that only minor changes were made to the monitoring programme to further improve it, none of which
impacted on Ireland’s OSPAR commitments.
55.
The marine monitoring programme will continue to be kept under review into the future. Further
changes to the programme are expected to be made in 2010-11 when the recommendations from a peer
review of the RPII overall environmental monitoring programme13, carried out in 2009 are implemented.
Changes to sampling frequency and locations may also be introduced as a result of the findings of a Tc-99
modelling project undertaken by University College Galway.
4. Amend licence conditions of all users of unsealed sources to include a discharge
limit
56.
The current licence conditions relating to the disposal of unsealed radiation sources are continually
reviewed to ensure that the principle of ALARA is applied. The licence conditions include controls on the
quantities of unsealed radioactive substances that can be discharged.
57.
In response to Ireland’s commitment to OSPAR in 2002, one of the licence conditions was amended
to include a statement on the discharge of patient excreta.
6. Implement more stringent discharge reporting criteria AND 13. Awareness
campaign amongst licensees of the OSPAR requirements
58.
Prior to the adoption of the OSPAR RSS licensees were required to maintain records of all disposals
in accordance with the following licence condition, and these records would have to be made available to
inspectors on request.
“The licensee shall make and maintain records for all in-vivo activities administered and all activities
discharged to the sewer from in-vitro procedures. These records shall include, where relevant, the
administration/disposal date, type and form of radionuclide and activity for each procedure.”
59.
With the implementation of the OSPAR RSS a new licence condition was introduced for medical
licensees requiring them to submit records for I-131 and Tc-99m on an annual basis:
“The licensee shall forward to the Institute [RPII], no later than 31 st March, a summary report, for the
preceding calendar year, of the total activity discharged to the sewers in the case of iodine-131 and
the total administered activity in the case of Tc-99m”
60.
Such a condition was not implemented for educational and research or industrial licensees. Instead
the RPII writes to them on an annual basis requesting the information for a number of radionuclides.
61.
Medical licensees are reminded of the requirement to report their annual discharge figures during
routine inspections.
62.
At the 2009 RSC meeting, contracting parties agreed to remove the reporting of Tc-99m from the
overall requirement to report national discharge for isotopes in the medical sector, to relate solely to I-131
discharges (RSC 09/12/1-E para. 3.7). The RPII will continue to require all licensees in the medical sector to
report on an annual basis the activities of both Tc-99m and I-131 discharged to the sewers.
12
F.J. Clyne, C.J. Garrod, T.M. Jeffs and S.B. Jenkinson (2008) An assessment of aquatic radiation pathways in Ireland.
Environment Report RL 16/08, CEFAS contract report C3030.
13
P. Mitchell, J. Hunt, K. Ledgerwood, S. Nielsen and C. O’Donnell (2009) A peer review of the RPII environmental
monitoring programme.
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7. Complete environmental impact assessments for marine discharge sites
including doses
63.
The main source of marine discharges from Irish facilities into the OSPAR maritime area is disposal
via the sewage system of radioisotopes administered to patients in hospitals. Of all the radionuclides used,
only I-131 is found in measurable quantities in the Irish marine environment.
64.
In 2004 an environmental impact assessment was carried out on I-131 discharges into the Dublin
bay area. Samples of influent, effluent, and sludge were taken from a municipal waste water treatment works
as well as seaweed samples from Dublin bay. Sampling was timed to coincide with administrations of GBq
activities of I-131 to patients in two Dublin hospitals 14.
65.
This environmental impact assessment concluded that the impact of hospital discharges does not
have a significant impact on the environment, nor are the resulting doses to critical groups of concern from a
radiological perspective15.
8. Take a decision on the installation of holding tanks to facilitate the decay of
iodine-131 in new hospitals AND 9. Take a decision on the back fitting of holding
tanks to existing facilities
66.
A detailed study on this issue was commissioned by the RPII. Based on this study, the RPII adopted
its current regulatory position on the need for iodine holding tanks in hospitals. A national steering committee
comprising representatives from the Department of Health and Children, the Department of Communications,
Energy and Natural Resources, the Department of Education and Science, the Marine Institute and The
Environmental Protection Agency, and chaired by the Department of the Environment, Heritage and Local
Government (DEHLG) reviewed this regulatory position and agreed that the position was consistent with
Ireland’s obligations under OSPAR and the following recommendations were thus adopted by Government:

In the case of existing iodine ablation facilities, licensees will not be required to retro-fit iodine
holding tanks.

Licensees with existing ablation facilities will be required to undertake both on and off site monitoring
to validate the assumptions and calculations used in their risk assessments when first applying for a
licence for ablation therapies; and

License applications for new ablation facilities will continue to be assessed on a case by case basis
to determine whether holding tanks are required.
67.
A review of the implications that acceptance of these findings may have on Ireland’s commitments
under OSPAR concluded that Ireland’s current position with regards to iodine-131 discharges is consistent
with international recommendations and the Best Available Technique (BAT) concept under OSPAR and
thus Ireland will still meet its OSPAR commitments based on the understanding that the current and
forecasted radiological impact of iodine-131 discharges to the Irish marine environment is negligible and well
below the regulatory limits currently applied in Ireland and accepted worldwide.
10. Establish a baseline for concentrations in the marine environment, discharges
and doses arising from discharges from Irish facilities in line with deliberations
from OSPAR RSC
68.
Discharges arising from Irish facilities are reported to OSPAR on an annual basis. Of the
radionuclides discharged to the marine environment, I-131 is the only one that is present in the environment
in measurable quantities.
14
Akinmboni, McMahon, Long and Colgan (2005) Environmental impact assessment of iodine-131 discharged from
hospitals in Ireland. Proceedings of the 3rd International Environmental Radioactivity Conference, Nice, 2005.
Group most at risk (on-site hospital plumbers fixing blockages in pipes exiting the facility): 50 – 70 microSv per incident
(i.e. fixing the blockage), with a conservative likelihood of occurrence around once per year; next potentially most
exposed member of the public (sewer worker): estimated dose of less than 4 microSv/y; Doses to all other members of
the public: estimated to be less than 3 microSv/y, with doses to the fishing community of 0.4 microSv/y or below (Enviros
Consulting Ltd., 2008)
15
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69.
Activities of I-131 in seaweed arising from discharges from Irish facilities were monitored over a 20year period and in addition an environmental impact assessment was conducted during 2004 to determine
the impact arising from I-131 discharges into the Dublin Bay area on the local environment and to calculate
the doses to critical groups.
70.
This study concluded that the resulting I-131 doses to workers and members of the public were
significantly less than the annual dose limit to members of the public of 1mSv.y-1. Results of this assessment
were reported to the OSPAR RSC in 2005.
11. Provide an assessment of the impact on future discharges of the Irish
Government’s health strategy
71.
Of the radionuclides discharged to the marine environment arising from activities taking place at
licensed facilities throughout Ireland, I-131 is the only one that can be detected in measurable quantities in
the marine environment. The impact of future ablation therapy needs on potential evolution of discharges in
iodine-131 from the medical sector is discussed here.
Situation prior to 2009 (i.e. related to discharges which took place between 2004 and 2008):
-
Iodine-131 ablation therapy is carried out in three hospitals in Ireland – two located on the East Coast
and one on the South Coast.
-
Each of these hospitals operates a single ablation suite with the two East Coast hospitals discharging
waste (patient excreta) directly to the sewage system and ultimately into the marine environment.
-
The South Coast hospital uses a bespoke 1000-litre holding tank which allows for the decay of
patient excreta, containing iodine-131, prior to discharge to the sewers.
Situation since the first-half of 2009 (i.e. will relate to discharges taking place from 2009 and reported from
2010 onwards):
-
Licences have been issued to a third hospital on the East Coast for a single ablation suite and to a
previously licensed hospital, also located on the East Coast, for the introduction of a second ablation
suite.
Future needs:
-
Plans for the opening of a new single ablation suite at a hospital located on the West Coast are at an
advanced stage (RSC region 1).
-
It is also expected that the hospital on the East Coast which currently has two ablation suites will
relocate and merge with the other East Coast hospital which is currently providing ablation services
with its single suite facility. It is possible that a second suite will be used at this facility.
-
In 2006, across the three existing units 92 thyroid ablation treatments were carried out. This could
rise somewhere in the region of 150 cases within the next 5 to 10 years, in line with a 50% estimate
for increasing radiation therapy needs 16. Although the assessment is only provisional, it is likely that
150 patients from Ireland may require thyroid ablation treatment per year within the next 5 to 10
years, and this may further increase beyond that. Based on a precautionary approximate estimate of
5 GBq I-131 dosage per patient this could represent an annual ablation requirement (assuming that
all patients were treated in Southern Ireland) of 750 GBq per year (compared to 435 GBq in 2006).
12. Instruct licensees to provide an assessment of the use of Best Available
Technology (BAT) with respect to discharges
72.
Of the radionuclides discharged to the marine environment arising from activities taking place at
licensed medical facilities throughout Ireland I-131 is the only one that can be detected in measurable
quantities
-
16
Any new facility applying for a licence from the RPII for authorisation to discharge unsealed
radionuclides to the sewers must be able to demonstrate how it can meet a design dose constraint of
300 µSv/y per patient.
Enviros Consulting Ltd. (2008) Review of best practice in relation to iodine-131 ablation discharges to sewer. Final
Report Version 3.1, modified by the RPII in Feb. 2009.
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-
Where a licensee is unable to meet this design dose constraint they will be expected to implement
BAT. In the case of an application which involves the discharge of I-131 this could include
consideration of iodine holding tanks.
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9. REVIEW AND REPORTING PROCEDURES
73.
An interdepartmental steering committee chaired by the Environmental Radiation Policy and Air
Quality Section of the Department of the Environment, Heritage and Local Government and including
representatives from the Department of Health and Children, Department of Communications, Energy and
Natural Resources, Department of Education and Science, the Marine Institute, the Environmental Protection
Agency and the RPII has been established to review the implementation of the Strategy and report to the
Commission as appropriate.
10. FORWARD-LOOKING GOALS WITH REGARD TO RADIOACTIVE SUBSTANCES

Update the marine monitoring arrangements following peer-review process of monitoring programme
(expected for 2010) while ensuring Ireland’s monitoring commitments under the OSPAR Radioactive
Substances Strategy continue to be fulfilled;

If relevant, incorporate the results of the collaborative modelling project on Tc-99 currently led by the
Marine Modelling Group (MMG, National University of Ireland, Galway) and the RPII environmental
monitoring section. The objective of this project is to numerically simulate the transport and
dispersion of Tc-99 discharges from the Sellafield reprocessing plant using a hydrodynamic model of
the Irish Sea developed by MMG. The project outcomes will assist the RPII’s environmental
monitoring section to examine the adequacy and effectiveness of the RPII monitoring methodology
in terms of optimum sampling frequencies and densities of data collection;

Continue to prevent or minimise the non-essential uses of radioactive substances to the levels
required for the intended purposes through the application of justification and optimisation principles
(in terms of radiation protection) and Best Available Technology;

Where appropriate, continue to exert downward pressure on discharges by maintaining tight controls
on the quantities of radioactive wastes that are discharged to the environment and by monitoring the
conditions attached to the licenses permitting the use and discharge of liquid radioactive waste;

Review the amount of iodine-131 discharged and compare with the forecasted figures;

Ensure the highest possible standards in the area of natural radioactivity discharges are maintained
and dealt with in accordance with best international practice.
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