General comment: The draft is useful in providing relevant information (to be checked by others if this information is still valid), and illustrates well the particularities of NORM materials: no emergency situations, little impact of radiation protection on the justification of NORM practices, the difficulties arising from the fact that such industries may be in operation for a very long time already, the fact that most industries and workers are currently unaware of having a radiation protection issue. However, it fails to understand why nevertheless in the international standards (IAEA safety standard and Euratom Directive) these industries are nevertheless regulated in the same way as in a planned exposure situation, and dose limits are applied. The arguments for sticking with the orthodox ICRP view are very meagre and may be cause of confusion. It should be pointed out that while the Euratom Directive is referred to merely as a source of information, the international standards are not even mentioned (the IAEA 2015 reference is a different document)! Below the criticism is spelled out along the incriminated lines of text:
112 .Situations involving Naturally Occurring Radioactive Material (NORM) are
113 existing exposure situations except when NORM is used for its radioactive
114 properties.
This statement is not in line with international standards: neither that a priori NORM industries are an existing situation, nor that the exception is based only on whether the radioactive properties of the material are used or not.
133 (2) For most human activities involving minerals and raw materials, the level of
134 exposure due to primordial radionuclides decay series is not a concern for radiological
135 protection. However, there are a number of circumstances in which materials containing
136 natural radionuclides are recovered, processed, used, or moved such that enhanced radiation
137 exposures may result.
(13) Some mining facilities, however, have been established for the expressed purpose of
228 extracting materials such as uranium and thorium from ore to be used for their radioactive,
229 fissile or fertile properties. These industries are considered as planned exposure situations
230 under the current system of radiological protection as outlined by the Commission in ICRP,
231 2007 and are not the subject of this publication.
As mentioned before, the alternative definition in the international standards make this distinction superfluous.
263 (18) While ionising radiation may be a consideration in terms of the protection of people
264 and the environment from NORM, it is generally neither the only hazard nor the most
265 dominant hazard. Indeed, many NORM residue and waste may contain toxic non-radiological
266 constituents that may be harmful to human health and/or the environment (e.g. heavy metals).
398 (30) By-products and residues from a one industry involving NORM can be used as
399 feedstock by other industry involving NORM and/or in common practices (e.g. building materials).
985 (111) Residues are materials which can be recycled and re-used.
418 Existing exposure situations are exposure situations resulting from a source that already
419 exists, with no intention to use the source for its radioactive properties, before a decision
420 to control the resulting exposure is taken.
This statement is presented as if it was a quote from Publication 103; actually it isn’t.
442 … . In existing exposure situations, because the source already
443 exists when decisions on control are taken, the principle of application of dose limits is, a
444 priori, not relevant.
479 (39) In most cases the exposure of workers in industries involving NORM is adventitious
480 because the presence of NORM in the material processed is a natural fact, without intentional
481 addition for its radioactive purpose, and the workers are often not considered occupationally
482 exposed.
483 … workers who are not regarded as being occupationally exposed to radiation are usually
484 treated in the same way as members of the public.
543 (48) For industries involving NORM in the national list, when a new process using
544 NORM is to be implemented, the principle of justification should be applied in the same way
545 as for on-going processes, i.e. primarily when making the decision as to whether or not to
546 implement a protection strategy for radiation exposures. Industrial processes will usually
547 produce such significant economic and social benefits, and the radiological risks involved is
548 unlikely to result in a decision that the NORM process, as a whole, would need to be
549 considered unjustified. Exceptions can be dealt with on a case by case basis.
It cannot be stated in general that NORM industries have significant benefits; from an environmental point of view many NORM industries may be very questionable. It is still true that in general the fact that a NORM industry in addition is a cause of exposure may be a factor, but most often one of minor importance, in the justification process. This may not be the case if the NORM industry actually produces radioactive waste, however.
624 (58) The Commission recognises that some authorities have already specified the
625 application of dose limits for some industries involving NORM. Such use is understandable,
626 as a limit is frequently used as one regulatory mechanism to judge the acceptability of a
627 radiation control program. Such a use is not unacceptable in circumstances when the source is
628 well characterised, and the control programs have been established.
It is very kind to “accept” that authorities do what they need to do, i.e. regulate exposure situations that are of concern. The application of dose limits is part of this control scheme.
629 However, specifying a limit for regulatory purposes is not meant to imply that the situation has been, or needs to be,
630 transformed into a planned exposure situation.
It is hard to understand that dose limits can be applied it the situation is managed as an existing one. Anyway, if the above statement is mad, then one should rather say in general terms: “there are existing exposure situations that may warrant the application of dose limits”.
630 ….. In the vast majority of industries involving
631 NORM, the application of ‘limits’ expressed in terms of dose provides no real additional
632 protection for workers, and may entail administrative burdens that are not in keeping with
633 efficient and effective use of resources.