ICRP Radiological Protection from Naturally Occurring Radioactive Material (NORM) in Industrial Processes
Comments by Hildegarde Vandenhove, Director Environmental Health and Safety, SCK•CEN; President European Radioecology Alliance, Board Member European NORM Association
14 January 2019
Note –below are comments only and I did not include a list of items which I find very good in the report.
Lines 47–51: Why are industries dealing with NORM considered as an existing exposure situation? Why are they not considered as a planned exposure situation since much of it is or can be planned. It creates also confusion with EU Directive 2013/59/Euratom (EU-BSS) where NORM industry is considered a planned exposure situation. It is a planned practice dealing with material containing NOR, even if NORM is used e.g. for P-production. We cannot imagine today that, in case of a new-build P-factory or zirconium plant, one would not assess the potential exposure, take measures if needed, monitor and additionally protect the personnel if dose to public of 1 mSv/a is exceeded.
Lines 5961: why not recommend 1 mSv/a as reference level, and if exceeded despite simple measures recommend the workers to be radiation workers? The unclear definition of a ‘reference level of ‘below a few mSv/y to even higher than 10 mSv/y leaves an unclear definition and too much margin.
Lines 67-68: Reference level to public below a few mSv/y à if it is a facility in operation ( a practice!) then the discharges should not result in public exposure > 1 mSv/y.
Lines 112-114: Active NORM industries (practices) should not be considered as existing exposure situations but as a planned exposure situation (cfr. EU-BSS).
Lines 213, 216: NORM à cfr. previous remarks existing/planned exposure situation.
Lines 232-243: Exposure of works and public to radon and thoron should also be included in the dose assessment of the NORM activity.
Lines 304-305Geothermal energy production and cement production are not treated in annex 1 and best should. Geothermal energy is being more and more explored and potential (radiation) hazards should be highlighted.
Lines 313-318: Categorization of exposure scenarios is quite strange: based on volume, from volatilisation? For workers scenarios could be exposure from recurrent activities or for specific actions. For public (and environment) exposure from atmospheric, liquid discharges from the facility, (actual/future) exposure from waste dumps … or any logical other categorization. I think for clarity these lines are best eliminated.
Lines 375-376: I did not dig into the literature and into the mentioned IAEA document, but I would doubt that annual effective dose to critical group (or representative person) from atmospheric and liquid discharges from industry dealing with NORM would be always < 1 mSv/a …
Lines 382-384: It is important that the environment is considered, however, when discussing about protection of the public (and workers) a graded approach is proposed whereas for the protection of the environment a case specific evaluation is required, considering all present hazards, all environmental conditions …. For EIA, also graded approach should be envisaged.
Table 2.2., line on ‘Use of metal recycling … ‘: Ra-223 not a typo?
Line 398: By-products and residues from a one industry.
Lines 430-438: Also for industries handling NORM, despite the fact that the material is not used for its radioactive properties, the use of the source is understood, and exposure can be anticipated and controlled and industries handing NORM could be considered as planned exposure situations.
Line 430: The Commission considers workers, human and environmental exposure …
Line 467: …. environmental damage and public exposure.
Lines 503-504: these activities can generate public exposure next to environmental exposure and should best be taken up also under 501-502.
Lines 505-507: Environmental exposure à also graded approach (EIA not always needed à delete … ‘staring with … presence of NORM’.
Line 572: Also for environmental exposure graded approach and including radiation in EIA not always needed.
Lines 606-615: Cfr. remarks 59-61 (related to 47-51).
Lines 619-623 and 672-674: Individual control (and dose limits) may be warranted and this should be highlighted; collective measures may not always adequately protect individual workers and individual protection may be needed.
Lines 676-681: See previous comments cfr. 313-318.
Lines 732-735: cfr 59-61.
Line 778: and possibly ingestion.
Line 788: However for some industries/processes it may be good to obtain an idea of the radiation doses if OHS are not followed.
Line 812: ILO – Perhaps I missed it but is this abbreviation explained in the text?
Line 814: Is selection of alternative feed material the first and most straightforward way to reduce the dose? It may not be so easy to alter the process. Suggested to better us another (first) example for initial actions to prevent hazard …
Lines 869-871: Not often occurring and better explain what is specifically meant.
Lines 915 -916: The selection of the reference for public exposure from discharges from the industry dealing with NORM should not depend on the characterisation of the exposure situation. This should be defined in the national regulation beforehand. Actual releases from industries dealing with NORM can be perfectly assessed and planned and should adhere to the same reference levels as for planned exposure situation.
Lines 1050-1052: Odd sentence and not correctly phrased.
Lines 1081-1088 and following: Odd to read a detailed description of all the environmental processes occurring and the need to consider or evaluate them for biota impact assessment and not for human impact assessment where the same processes prevail that rule the dispersion of the discharged radioactivity and subsequent exposure. For the environment no more detailed assessment should be needed compared to the human impact assessment. For environment also graded approach.
Lines 1091-1092: mechanisms to control releases can and should also be informed by public exposure.
Lines 1103-1105: Not always EIA considering radiation impact à application of graded approach.
Lines 1121-1127: Again much more detailed and explicit than what is thought needed for human impact assessment.
Line 1183: Involvement of relevant stakeholders.
Annex A: Add geothermal energy and cement production consistent with lines 304-305 and with importance/occurrence of NORM in geothermal energy.
Lines 1519-1532: As definition presented it is not definition of NORM but of TeNORM; NORM also encompasses the natural, extracted material (not transformed) with the original unaltered concentration.
Lines 1535-1539: Also for industries dealing with NORM, the source is understood and exposure can be estimated.
Lines 1581-1582: Incomprehensive sentence!
Line 1582: Residues