Radiological Protection from Naturally Occurring Radioactive Material (NORM) in Industrial Processes

Comments on the Draft ICRP NORM Report

The ICRP draft report ‘Radiation Protection from Naturally Occurring Radioactive Material (NORM) in Industrial Process’ (the ‘draft report’) is beneficial in several aspects:

• Highlights the importance of radiological protection in industries where NORM is present
• Emphasises using a graded approach to management
• Recommends integrating management of radiation in with the other non-radiological hazards that are present

However, there are also a number of fundamental flaws which reduce the usefulness of the draft report that are listed below and then discussed in further detail:

• Most industries where NORM is present should be classified as planned exposure situations, not existing
• Radon exposure is often the dominant exposure pathway so should not be excluded from proper discussion in the draft report
• The draft report does not provide clear enough guidance to operators on implementation of radiological protection systems

Existing vs planned exposure situations

We disagree with the interpretation that most industries where NORM is present should be classified as existing exposure situations. Practices or facilities should not be classified as planned vs existing situations based on whether the purpose is to extract a radioactive material for use of their radioactive properties. For example, two neighbouring mines should not have different radiation safety requirements depending on whether uranium is part of their product versus part of their waste stream. Intent of later use does not change the level of radiological hazard present.

If exposure pathways are introduced or exposures increased above what exist naturally because of planned work that disturbs that area or material (eg, ground disturbing exploration, mining (including of non-radioactive ores), and materials production or processing both in mining and other industries) this would be a more appropriate criteria of what should count as a planned exposure situation.

Radon

Radon exposure is often the dominant exposure pathway, so should not be excluded from proper discussion in the draft report. Always referring to ICRP publication 126 rather than discussing radon fully in the draft document, and excluding radon or thoron exposures from the discussion of reference levels gives an inappropriate impression that radon is not significant. It is also a poor approach to separate out one exposure pathway instead of managing the total dose from all pathways.

Guidance on implementation

While the draft report does discuss implementation of a system of radiological protection and emphasises the importance of optimisation and using a graded approach, it does not provide clear enough guidance to industry operators on what this may actually entail.

Using reference levels instead of limits is confusing, and the advised range of appropriate reference levels being between “below a few mSv” to “very rarely exceeding 10 mSv” per year (excluding radon and thoron exposures) does not add any clarity, and at the upper end seems to imply that annual doses that would be unacceptably high in other radiation practices are suitable when dealing with NORM.

In addition, the draft report seems to imply that as exposure to NORM presents no real prospect of a radiological emergency leading to tissue reactions or immediate danger for life, the only remaining impact is the potential for environmental damage due to accidental release of large volumes of NORM. Failing to mention the risks of stochastic effects due to chronic exposure, particularly if uncontrolled, does not seem consistent with the emphasis on optimisation throughout the draft report.