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

Comments on the ICRP Draft

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

Frank Harris

Chief Advisor Radiation Governance and Product Stewardship

Rio Tinto

Background of Rio Tinto

Rio Tinto is a leading international mining group, combining Rio Tinto plc, a London listed public company headquartered in the UK, and Rio Tinto Limited, which is listed on the Australian Stock Exchange. The two companies are joined in a dual listed company structure as a single economic entity called the Rio Tinto Group.

Our interests are diverse both in geography and product. Most of our assets are in Australia and North America. We also operate in Europe, Asia and Africa. Our businesses include open pit and underground mines, mills, refineries and smelters as well as exploration, technology and service facilities.

Rio Tinto’s products help fulfil vital consumer needs and improve living standards. We operate and close our operations safely, responsibly and sustainably. We take a long-term approach to our business. This means developing first-class orebodies into large, long-life and efficient operations and developing and applying new technology at our mines, refineries and smelters.

As a result, our operations are capable of sustaining competitive advantage through business cycles. We pursue opportunities for productivity improvements, cost reductions and prudent growth. Our values of safety, teamwork, respect, integrity and excellence are expressed through our business principles, policies and standards. We set these out in our global code of business conduct, The way we work. Our values underpin the way we manage the economic, social and environmental effects of our operations, and how we govern our business.

Scope

The following is a high level review of the ICRP draft “Radiological Protection from Naturally Occurring Radioactive Materials (NORM) in Industrial Processes”. The basis of this review is not to perform a line by line review but rather examine the critical statements and guidance in the document which have the potential for major impacts on radiological protection or industry.

Overall Finding

The ICRP draft highlights the important of radiological protection associated with NORM and as such is of high importance to industry. Although some aspects are welcomed by industry there are some fundamental flaws in the ICRP draft approach which have a high probability of having a negative impacts on radiation protection in NORM regulation and industries. The positive aspects are covered first and then the fundamental flaws in the draft ICRP approach are examined utilising practical examples.

Positive Aspects of the ICRP Draft

The focus of the ICRP on NORM is in itself a major positive and addresses a pressing need for industries and regulators. The importance of exposure to NORM is very significant and it has been previously identified that NORM industries are responsible for the majority of occupational exposure (by a large margin re UNSCEAR) taking into account all exposure pathways. There is significant confusion on the identification and regulation of NORM and ICRP attention to this area is justified and welcomed.

The emphasis on a graded approach is also welcomed with the need to balance the potential for harm against the cost of implementing protective practices and regulation. Although it would have been useful to more fully explore how the graded could be practically implemented, the graded approach is of high importance. Associated with this it is welcomed that the link between radiological and non-radiological hazards is included and the need to balance the potential costs and benefits.

Fundamental Flaws of the ICRP Draft

From the practical standpoint there are three fundamental flaws in the ICRP draft on NORM. These flaws are likely to adversely impact on radiation protection and as such they have been explored in more detail. It appears that the flaws relate for the need for ICRP consistency with previous documents rather than addressing the specific needs associate with NORM. In fact, the approach to NORM identifies some critical issues with previous publications and these should be an impetus for the ICRP to re-examine their approach rather than trying to “fit” NORM into the ICRP scheme of things.

• The Exclusion of Radon: The exclusion of the radiological impacts of radon from the ICRP approach to NORM is probably the biggest single flaw with the document. It appears that this is an attempt to keep the document consistent with ICRP126 but by doing this it both distorts the fundamentals of assessing and managing radiation exposure and also greatly diminishes the perceived importance radiation exposure from NORM. Radiation protection should be based on the total risk and not have separate approaches dependent on pathway. It is only relatively recently that the importance of NORM exposure, both public and occupational, has been given a higher priority in radiation protection systems. This exposure is dominated by radon and the doses associated with NORM far exceed any of the non-emergency doses from all other facets of the nuclear fuel cycle. This has been published by UNSCEAR and highlights how exposure to NORM in underground mines can be a major source of exposure. However, review of the draft document strongly implies that the exposure to NORM is of low exposure significance (eg Table 2.1, multiple areas in the text) which is not correct or appropriate. It is the total dose which results from NORM which is important and to artificially separate off one pathway to be treated in a different manner diminishes the system of radiological protection. If addition of all pathways is the approach in all other aspects of the ICRP approach than this artificial separation is not justified and counterproductive to radiological protection
• The Division between Planned and Existing Exposure: The ICRP approach to planned and existing exposures has some significant impacts on the regulation and implication of radiation protection in NORM industries. NORM industries already have difficulties being incorporated into mainstream radiation protection systems and this single occupational hazard causes more concern and confusion than any other hazard. There is a pressing need for a consistent system which can be applied to all industries associated with NORM. Separation based on end use of the radionuclides is not a good justification for transition to planned exposures as radiological protection should be dose related not end use related. The draft ICRP document states that NORM is to be administered as an existing exposure situation but the practical regulation of any significant exposures will require an approach consistent with planned exposures. However, this inconsistent approach for planned and existing exposure will lead to significant issues in both how industries manage radiation protection. Also, the existing regulatory processes are not compatible with providing regulation to existing situations. There is also the issues that the viability and competiveness of an industry could be significantly affected by how the ICRP recommendations are applied. For example, in the same regulatory domain two similar mines could be subject to different regulatory limits and processes depending on the future use of the products. This is despite them having equivalent radiological risks and the same protective arrangements. Operations could also potentially move regulatory arrangements based on changing their production away or to the removal of radionuclides. The artificial separation of planned vs existing exposures, based purely on whether the operation is being performed for recovery of radionuclides, is damaging to the process of radiological protection in NORM industries. It means that two NORM industries, with exactly the same radiological risks, could have two different approached to radiation protection.
• Reduced Regulator and Industry Clarity: The above fundamental flaws significantly reduce the potential usefulness of the ICRP draft and may cause more harm than good. It causes uncertainty about how to practically apply radiation protection to NORM industries and is not consistent with current regulatory approaches. The incorporation of the radon pathway and have the protection approach based on total dose and hence risk would be an improvement. Similarly, a more consistent approach between planned and existing exposures or consideration of NORM industries as planned where appropriate may assist in providing a consistent and appropriate system for radiological protection for NORM industries. Although there are concerns about the entire existing vs planned division, a potential “quick fix” would be to consider operations or facilities where there is potential for significant exposure AND where active radiological protection controls are in place to be considered as PLANNED exposures. However, there is still a high potential for confusion on the use of existing exposure, particularly in developing countries where radiological protection regulations and process are still developing and existing exposures are not even considered.

Conclusions

The ICRP Draft Radiological Protection from Naturally Occurring Radioactive Materials (NORM) in Industrial Processes has some fundamental flaws which serious detract from their potential for practical implementation and may cause more harm than good for radiological protection. The three major flaws relate to the separation of the radon pathway, the classification of NORM practices as existing exposure situations, and the reduction in clarity which the draft fosters upon radiological protection in the NORM industries. Should ICRP wish to improve their advice on radiological protection in NORM industries it would be beneficial if ICRP sought input from practitioners from NORM industries (ideally from outside of the nuclear fuel cycle).