Submitted by Stelian Ghelberg, Noise Abatement and Radiation Safety Dept., Ministry of Environmental Protection Commenting on behalf of the organisation
It is need for an explanation why industrial residues with significant enhanced and totally unnatural activity concentrations of NORM have a different status compared to artificially produced radionuclides.
Justification, optimization and limitation of any additional radiation exposure are a must, regardless of its source or the material’s intended future use. Defining a control regime on the basis of intended future use is not practical. For example, the use of a nuclear fuel pellet as a chain key is dealing with NORM and the use of the same pellet for its intended use is dealing with an artificial source.
NORM management in industrial processes is considered in your draft as an existing exposure situation whiles the IAEA's International Basic Safety Standards and the European Council Directive consider industrial processes of NORM as planned exposure situations.
If the new definition of NORM is practically the definition of TENORM, why not called it as such.
It is totally unclear how a future and deliberate introduction of some industrial residues with significant enhanced activity concentrations into consumer products, such as building materials, can be seen as an existing situation. In this case the full control of the source, of the exposure pathway and of the magnitude of exposure implied a planned exposure situation.
According to IAEA, for radionuclides of natural origin, exemption of bulk amounts of material is necessarily considered on a case by case basis by using a dose criterion of the order of 1 mSv per year, commensurate with typical doses due to natural background levels of radiation. There is not such an approach in the ICRP's draft. There are countries with low natural background and for example introducing to building materials industrial residues with significant enhanced activity concentrations of NORM can dramatically change the indoor exposure to gamma radiation.
I suggest including in the draft some practical examples of how the graded approach has to be applied and which NORM situations require control and how to adapt the level of NORM control to natural background levels of radiation.