ICRP draft on NORM
This document has been elaborated by Cristina Nuccetelli of ISS (Italian National Health Institute) in collaboration with Rosabianca Trevisi of INAIL (National Institute for Insurance against Accidents at Work) and Flavio Trotti of ARPAV (Environmental Protection Agency of Veneto).
General Remarks
The NORM involving industries are characterized by the presence of different hazards and the ICRP properly stresses the need for the application of an integrated approach to effectively manage these industrial activities. Moreover, the ICRP draft underlines the potential radiological protective action of systems normally operating in the NORM involving industries to protect workers from other kind of hazards. This global perspective of protection could help to increase and strengthen dialogue between different regulations to get an effective management of all the hazards in the NORM related industries. Another fundamental topic opportunely highlighted in the ICRP draft is the need of the graded approach to manage the NORM involving industries.
Other important positions expressed in this ICRP draft cannot be agreed. The ICRP draft recommends to consider NORM related exposures as Existing exposure situations. This approach is coherent with ICRP Publication 103 but, from some decades a lot of work has been carried out about NORM involving industries. Indeed, the discussion among experts has brought to the production of technical reports, scientific articles, projects, etc., highlighting that NORM related exposures of workers and members of the public are manageable and controllable, regardless of the value of doses. These remarks were the basis for the new approach adopted by EU in the preparation of EU-BSS (in 2013), and by IAEA during the preparation of the international BSS (2014). Indeed, the Euratom Directive 2013/59 (EU-BSS) explicitly includes NORM involving industriesin the Planned exposures situations. It is worthy to note that the EU-BSS is already implemented in various European countries legislations. The EU regulatory approach was determined by the consideration that these industries, differently from building materials or legacy sites, determine worker and public exposures which are controllable and manageable. Therefore, they have to be classified as Planned exposure situations. Indeed, control and management of an industrial process can reduce not only conventional but also radiological hazards. Since exposure levels for workers and members of the public are generally low/moderate and without an actual risk of emergency situation rising, an integrated graded approach is necessary and mandatory. However, typical dose levels of the NORM involving industries don’t warrant putting them in the Existing exposure situations: if an industrial activity determines low doses, i.e. below the exemption/clearance dose criteria, this industry can be a planned activity exempted by further provision for the undertaking. Moreover,arguing that NORM involved industries are to be managed as Existing exposure situations because they already exist when the decisions to control the exposures are made is very weak. It is not a matter of time, it is a matter of establishing a regulatory protection system (Par. 33). The same approach of EU BSS has been followed by the recent IAEA BSS (2014). It is difficult to imagine that the ICRP approach can be integrated within such recent and wide regulations. In fact, a new ICRP document which does not account for evolution and results of a general scientific and regulatory discussion is difficult to be accepted and introduces confusion: moreover, this attitude is different from the past. On other topics (e.g. radon), new evidences coming from scientific community were soon considered by ICRP and justified the elaboration of new recommendations. In conclusion, what is proposed by the ICRP draft is in contrast with the current international approach.
Specific comments
Par. 32 (first bullet):the Existing exposure situationdefinition is different from that one reported in the ICRP Publication 103. Definition present in this draft seems to be modified to support the thesis that NORM involving industries are Existing exposure situation.
Par. 32 (second bullet). Same comment of the first bullet is applicable to the definition of the Planned exposures situations. Do these type of exposure situations concern materials that are used for their radioactive properties only?
Par. 44. Principle of Justification; identification of NORM related activities as Existing exposure situations makes Justification Principlelimited to “making the decision as whether or not to implement a protection strategy for radiation purposes”. With this approach, no justification process about the introduction of a NORM involving industry with its conventional and radiological impact should be carried out. From the radiation protection point of view this arbitrary use of the Principle of Justification seems to conflict with ethical principles. Also in this case the definition of the Principle of Justification was modified to fit the approach of this ICRP draft.
Par. 54-58. Reference Levels. As a consequence of the proposed approach to considering NORM involved industries as Existing exposure situations, dose criteria are presented in terms of Reference levels. It is worthwhile to observe that, according to Euratom 2013/59 Directive definition, the reference level is a level judged inappropriate to be exceeded by radiation exposures but it is not a limit that cannot be exceeded. The ICRP report draft goes on this approach being against the option adopted by many Authorities worldwide to set dose limits in their regulation for NORM involved industry. Use of reference levels instead of limits in such a controllable industrial activity may lead to a unjustified lower protection level of workers and members of the public.
Par. 73. What does the sentence “(73) Since the industries involving NORM are so diverse, there is no unique numerical value which is appropriate as a reference level for all of them.” mean? The base idea seems to be that the protection level of workers and eventually members of the public depends on the industrial category considered. How are the ethical principles of “fair distribution of exposures (justice) and treat people with respect (dignity)” (par. 17) applied? Moreover, information from many EU Countries does not confirm the Par. 73 assumption.
Radon exposures. The report draft, in different sections of the document, states that radon from NORM related activities for workers has not to be accounted for together with the other radiation exposures (external and internal). Radon exposure, the document says, should be managed as a whole of building/underground radon exposure, due to soil, building materials, minerals containing NORM, etc. (see for instance, 14, par. 75 …). This cannot be shared, because radon exposure is generally inherent part of workers’ exposure in a NORM related industry and depends on industrial processes and working conditions (size and ventilation of materials storage rooms, type and duration of workers operations…). For the same reason, the indication that radon control for NORM involved industry should fall under the National action plantogether with other building exposures (par. 68) cannot also be shared: the plan, in fact, should be elaborated to provide objectives, timing and implementation tools for dwellings and workplaces, not for NORM involving industries.
Radiation risk and other hazards.the document underlines, in many parts (see par. 39, 82 etc), that the radiation risk is not the only critical aspect for workers of NORM related industries, but other and sometimes more heavy hazards do exist. This is true and it is important that all relevant factors potentially affecting workers’ health have to be accounted for and properly managed. The document should be, nevertheless, more effective in proposing a way to integrate the health disciplines ruling radiation protection and other hazards (recalling international standards for occupational safety where to harmonize both requirements, etc). Moreover, the sentence in par. (39) “it is the responsibility of the operating management to integrate the radiation risk among the others hazards and to address all the hazards in accordance with the agreed standards on health and safety at work.” lets the application of the radiation protection system totally depending on a management initiative, without any control by competent authorities. This approach risks to recreate the past situations when NORM involving industry undertakings could ignore the radiation protection aspects.
Section 4.2, par. 100 - 125. Amongst the pathways that cause exposures of members of the public to NORM, Commoditiesare not cited nor described (apart from building materials). There are some NORM related industry products that contain a certain amount of natural radioactivity that cannot be disregarded: refractory products, for instance, or fertilizers, etc.
Par. 102. The reference level for the protection of the public should be less than 1 mSv per year, not ‘below a few mSv per year’. Exposures above 1 mSv per year are not justified and standards establishing reference level not above 1 mSv per year have been adopted in various regulations since many years.
Table 2.1, page 12. It is reported that the dose estimate for workers in the Manufacture of zircon/zirconia ceramicsis negligible. Data from Italian surveys indicate that is not always the case (effective dose up to 0.4 mSv per year).
Tab 2.2, page 13. Dose estimates for members of the public related to residues and wastes from tile and refractory industry are missing. In the Italian experience, following conservative approach, effective doses up to few mSv per year could result without proper residue/waste management. Doses for members of the public in Drinking water treatmentand Disposal of water treatment residue in landfillcan be much higher (in some situations) that those reported: see for instance the Estonian case.