EUREAU position on Radioactivity

EUREAU INITIAL COMMENTS

ON THE DRAFT PROPOSAL FOR A COUNCIL DIRECTIVE LAYING DOWN REQUIREMENTS FOR THE PROTECTION OF THE HEALTH OF THE GENERAL PUBLIC WITH REGARD TO RADIOACTIVE SUBSTANCES IN WATER INTENDED FOR HUMAN CONSUMPTION (27/06/2011, COM (1011) 385 FINAL)

EUREAU is of the opinionthat regulation of radioactive substances in drinking water in Europe should be the best to be done under the scope of Directive 98/83/EC. EUREAU would rather favor a proper implementation of drinking water quality requirements for radioactive substances to be included in Directive 98/83/EC rather than a new piece of the EU legislation. This could provide a single comprehensive piece of legislation for all provisions regarding drinking water at the Community level.

However as it is not the case, thus EUREAU’s position on this new EC piece of legislative proposal contains the following key points:

• the principle of subsidiarity when implementing the provisions of monitoring and surveillance of of radioactive substances in drinking water in Europe should be applied
• regulation for deciding whether or not to take steps to reduce the concentration of radon in drinking-water supplies at the European level, should be both justified and optimized and should take into account the local conditions
• Radon directive would be based on radon levels in drinking water, and it is important to reflect this uncertainty in evaluation by a higher flexibility in regulation. Therefore, at least a frame for remedial actions between 100 and 1000 Bq/l, is highly recommended.
• When exceeding a reference concentration of 0,1 Bq/l for polonoium-210 and 0,2 Bq/l for lead-210, a consideration should be given to whether remedial action is needed to protect human health.
• it should be only a footnote stating that tritium, potassium-40 and short-lived radon decay products are excluded. Further it should be explicitly indicated that the parametric value for the total indicative dose is for one year of ingestion. It is also necessary to clarify the method to be used for
• The foreseen assessment methodology differs from the assessment methodology recommended by the WHO. If the proposed Directive regarding assessment methodology will not be modified, it would force operators to make significant and unnecessary cost outlays of water quality control
• In order to have at least one piece of EU legislation for radioactive substances in water intended for human consumption, it is recommended to include Commission Recommendation of 20 December 2001 on the protection of the public against exposure to radon in drinking water supplies.
• EUREAU is concerned that there is certain bottleneck concerning the number of accredited laboratories available in the Member States, i.e. that is not enough capacity for analysis.