The Minerals Council of Australia (MCA) welcomes the opportunity to provide comment to the International Commission on Radiological Protection (ICRP) on the draft document ‘Radiation Protection from Naturally Occurring Radioactive Material (NORM) in Industrial Processes’.
The MCA is the peak industry organisation representing Australia’s exploration, mining and minerals processing industry, nationally and internationally in their contribution to sustainable development and society.
MCA member companies represent more than 85 per cent of Australia’s annual minerals industry production and a higher share of minerals exports.
The ICRP draft document ‘Radiation Protection from Naturally Occurring Radioactive Material (NORM) in Industrial Process’ (the ‘draft document’), highlights the importance of radiological protection associated with NORM, particularly to the resource development industry. As such, it is of high importance to Australia’s mining industry.
Although some aspects are welcomed by the Australian mining industry, several fundamental flaws in the draft document have a high probability of delivering negative effects on radiation protection in NORM regulation and industries.
On the positive side, the focus of the ICRP on NORM is in itself a step forward and addresses a pressing need for industries and regulators.
However, given the importance of such a document to the resource development industry, we would recommend a high level of discussion with the industry. The MCA would be available to participate in any such dialogue the ICRP may desire.
The importance of exposure to NORM is very significant and it has been previously identified that industries where NORMs are present are responsible for the majority of occupational exposure taking into account all exposure pathways. Despite this importance, there is significant confusion on the identification and regulation of NORM.
The draft document’s emphasis on a graded approach is welcomed with the need to balance the potential for radiological impact against the cost of implementing protective practices and regulation. We would recommend that a higher emphasis on the practical implementation of the graded approach be presented. We welcome the inclusion of the link between radiological and non-radiological hazards and the need to balance the potential risks from both types of hazards.
Overall however, the draft document is a lost opportunity to provide clear leadership and direction on how NORM should be managed. There remains significant uncertainty on how NORM should be treated by regulators and industry, and therefore there is a need for ICRP to provide considered direction.
We are concerned that the approach to classify operations with NORM as ‘existing’ exposure situations in the document is confusing and contradictory. It appears that industries already uncertain of their radiation protection status will have an even more uncertain regulatory status. Current regulatory practices are heavily dependent on the regulation of planned activities and if industries associated with NORM are considered ‘existing’, there is a strong potential for non-optimal radiological protection.
It also creates the perception that exposures in the nuclear industry are ‘more harmful’ than those occurring in operations with NORM and requires additional regulatory emphasis. This acts to undermine the practical implementation of the ICRP’s system of radiation protection.
Another key concern for the Australian minerals industry is the exclusion of radon as this fragments the approach to protecting the individual as a whole. At the very least, there needs to be significant cross referencing to both the dose potential from radon and the need for a coordinated approach to radiation protection. This is considered to be a fatal flaw with the draft document.
In summary, the Australian minerals industry recommends that:
These adjustments will give the draft document more practical implication and provide consistent guidance for regulators, industry and communities and also provide the public confidence that a consistent approach to radiation protection exists.
Please find additional information as follows.
The ICRP approach to planned and existing exposures has significant impacts on the regulation and implication of radiation protection in industries associated with NORM.
Such industries generally consider radiation to be one of a number of hazards. However, by considering radiation exposure as ‘existing’, there is a temptation for it to be viewed cursorily. By making radiation exposure a ‘planned’ exposure, there will need to be an assessment and a more formal approach.
There is a need for a consistent system which can be applied to all industries associated with NORM. 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.
An issue for industry is that the viability and competiveness of a particular operation may be compromised by ill-considered regulation. 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.
Usually, uranium mines are considered as planned exposures. This includes an ISR uranium mine, even if the exposure is lower than a non-uranium mine such as a mineral sands mine. However, the non-uranium mine is considered to be an existing exposure. This is an inconsistent application of the system of radiological protection.
Classifying exposure to NORM as an ‘existing exposure situation’ is confusing. From a practical perspective, managing additional radiation exposure is important, regardless of its source. In most cases in practice, facilities with NORM are regulated as per a planned exposure situation (once identified). The practical rules for planned exposure situation are clear and are more readily able to be factored into facility safety and environment management systems.
The MCA recommends ICRP review its approach to NORM in the document to provide a more structured framework, and reframes all NORM activities as planned exposures.
The exclusion of the radiological impacts of radon from the ICRP approach to NORM is a significant practical 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. It should not have separate approaches dependent on the exposure situation.
It is only relatively recently that the radiological significance of NORM exposure, both public and occupational, has been identified. Generally, the exposure is dominated by radon and the doses. In fact, doses from NORM exceed any of the non-emergency doses from all facets of the nuclear fuel cycle. This has been published by UNSCEAR and highlights how exposure to NORM, particularly 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 (e.g. Table 2.1, multiple areas in the text) which is not correct or appropriate. The total dose from NORM is important and to artificially separate one exposure pathway diminishes the system of radiological protection.
From a practical perspective, radon and its decay products need to be considered in every underground mine situation or in surface facilities treating NORM with low ventilation rates.
The MCA recommends ICRP revisit the treatment of radon in the draft and ensure it is appropriately addressed.
The flaws in the draft document significantly reduce its potential usefulness and may cause more harm than good.
The flaws create uncertainty about how to practically apply radiation protection to NORM industries and are not consistent with current regulatory approaches.
The MCA recommends the incorporation of radon and basing the protection approach on total dose. We believe that this would dramatically improve the draft document.
In addition, consideration of NORM industries as ‘planned exposure situations’ where appropriate will assist in providing a consistent and appropriate system for radiological protection for NORM industries.