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

Lines 47–51

 NORM associated with industrial processes is an existing exposure situation, except when NORM is used for its radioactive properties which should be addressed on the basis of the principles of justification (of the actions taken) and optimisation of the protection above or below appropriate reference levels. Radon and thoron exposures should be managed as recommended in Publication 126.

Why are active 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 112-114:

Active NORM industries (practices) should not be considered as existing exposure situations but as a planned exposure situation (cfr. EU-BSS).

Line 112:

The restriction of NORM to existing situations would mean that NORM is not considered in the context of planned exposure situations. However, the use, handling or disposal of NORM is often very well plannable. see also comments on Lines 1500 and 1535 below.

Line 227

(13) Some mining facilities, however, have been established for the expressed purpose of extracting materials such as uranium and thorium from ore to be used for their radioactive, fissile or fertile properties. These industries are considered planned exposure situations under the current system of radiological protection as outlined by the Commission in ICRP, 230 2007 and are not the subject of this publication.

It is confusing if industries that have the highest activity concentrations and exposures are put under a special (normal) regime and all other industries / mining is considered as an existing situation. This generates confusion and is not helpful for the practice

Line 418-422

Existing exposure situations are exposure situations resulting from a source that already exists, with no intention to use the source for its radioactive properties, before a decision to control the resulting exposure is taken. Decisions on the need to control the exposure may be necessary but not urgent. Characterisation of exposures is a prerequisite for their control;

Here ICRP gives a significant new definition of existing exposure situations. In ICRP 103 (para 176) was written: “Existing exposure situations are exposure situations that already exist when a decision on control has to be taken, including prolonged exposure situations after emergencies.”

There is no sufficient justification in the draft as to why the addition with regard to “intention to use the source for its radioactive properties” is necessary. It seems that this addition is completely arbitrary and academically. 

Lines 423,
(1500 and 1535)

These definitions are different from the corresponding definitions of planned and existing exposure situations in IAEA BSS, e.g., "An existing exposure situation is a situation of exposure that already exists when a decision on the need for control needs to be taken." Using the proposed definitions, NORM would never be associated with planned exposure situations, but only with existing situations. This would be strange, since the use, handling or disposal of NORM is often very well plannable.

Line 431

"The source ... already exists in material used in the process or industry, and any protection decisions to control the exposure are made in that context."

The word “already [exists]” is misplaced. First, NORM may arise in industrial processes due to concentration, accumulation, and redistribution of certain radionuclides. Second, NORM may be deliberately introduced into industrial processes, not because it is radioactive but because of its chemical or other properties.

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 handling NORM could be considered as planned exposure situations.

Line 1500 – 1503

Existing exposure situations

An exposure situation resulting from a source that already exists, with no intention to use the source for its radioactive properties, before a decision to control the resulting exposure is taken. Decisions on the need to control the exposure may be necessary but not urgent.

Cf. comment ref. Line 418 – 423

Lines 1535-1539:

 Planned exposure situations

An exposure situation resulting from the deliberate introduction and operation of radiation sources, used for their radioactive properties. For this type of situation, the use of the source is understood, and as such the exposures can be anticipated and controlled from the beginning.

Also for industries dealing with NORM, the source is understood and exposure can be estimated.

By this definition, ICRP modifies its former recommendation 103 in a significant manner.

ICRP 103 defined: “Planned exposure situations: Everyday situations involving the planned operation of sources including decommissioning, disposal of radioactive waste and rehabilitation of the previously occupied land. Practices in operation are planned exposure situations.”

This will have much more influence on the RP system and will create much new inconsistencies and confusion.

A well-justified reason that makes this fundamental change necessary is not recognizable.

Lines 382-384:

It is important that the environment is considered, however, when discussing 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.

Lines 383 -384

See generic remark on Protection of the environment – add e.g. “taking into account graded-approach in the evaluation process”

Lines 505-507:

Environmental exposure à also graded approach (EIA not always needed à delete … ‘staring with … presence of NORM’.

Line 506-507

See generic remark about EIA – delete “starting with an EIA considering the presence of NORM”

Line 519

a possible exception is the incorporation of NORM in some consumer goods.

Line 572

See generic remark –  to integrate radiological impact in EIA is not always relevant

Line 572:

Also for environmental exposure graded approach and including radiation in EIA not always needed.

Line 1008 - 1010

(129) The EIA should consider the total impact of NORM activity, which for the specific purpose of protecting the environment from the harmful effects of radiation entails:

Generally, radioactivity has to be included in EIA of facilities that process or otherwise contain NORM. The German Commission on Radiological Protection (SSK) has stated and recommended

“The radioactive contamination of material assets can, independent of the radiological effects on humans or (e.g. in the event of soil contamination) on non-human species, restrict the usability of these material assets and lead to significant disadvantages for the respective owners. According to the SSK, it is necessary to consider such contamination when planning for emergency exposure situations. Furthermore, contamination within the economic cycle should, based on a more extensive analysis of radioactivity in environmental assessments, be identified directly at its place of origin to avoid uncontrolled input into the material flows of the economy.

The SSK therefore recommends:

Recommendation 14: Radionuclides in or on material assets may negatively impact technical usability or lead to substantial disadvantages with respect to economic use up to and including disposal. They should, therefore, be identified and accounted for during environmental assessments.

Even plants where no practices requiring licensing occur may be the source of radionuclides having a negative economic impact on material assets and particularly on waste. Therefore, the respective plant types should be identified e. g. by analysing incident reports regarding radiation alarms at disposal companies.

Recommendation 15:    Suitable provisions should be defined for the handling, decontamination, reuse or disposal of material assets, whose radionuclide concentration has been increased as the result of existing or emergency exposure situations.” 

These aspects should be considered by ICRP in their recommendations.

Line 45

 However, the accidental release of large volumes of NORM may result in detrimental effects on the environment, including of radiological nature.

remove the word “accidental” – not only accidental but also routine releases which are not appropriately controlled may result in detrimental effects

Lines 59-61

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

 The reference level for the protection of the public should be selected below a few mSv per year.”

“

Reference level to the 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.

Does this mean “below one mSv/a”? Or does it mean “it may be a few mSv/a”? Because “below a few mSv/a” may still be a few mSv/a.

To mention “reference levels” only (and not also dose limits) seems to indicate that dealing with NORM is considered a planned exposure situation. This view is confirmed by the Glossary section (starting with line 1455) and is commented on below.

Line 130

use 232Th instead of Thorium-232

Line 132

The other primordial radionuclides are of much lower abundance.

The sentence is not true. Rb-87 occurs in the continental crust with an abundance of about 20 – 30 ppm. But its radiological significance is much lower than that of the U-238 and Th-232 series

Line 138-140

For example, certain minerals (e.g. zirconium, monazite), including some that are commercially exploited, may contain potassium and/or thorium and/or uranium progeny at significant concentrations.

Zirconium and monazite do not contain potassium at significant concentrations. Add another example or omit potassium

Line 152-153

The discovery of radioactive scales from natural sources in British and American oil production facilities was first mentioned in the 1950’s (Schmidt, 2000)

The history of radioactive scales in oil production facilities is much longer. ICRP should describe the facts in a comprehensive way or should do without it.

Line 192 - 193

Exposures from natural sources are considered to be existing exposure situations.

This sentence is referred to ICRP 103 – and is not written there in this clear form. Unproven statements should be avoided by the ICRP.

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 304-305:

Geothermal 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 addressed.

Line 313-318

(23) The range of process broadly leads to three scenarios for radiation exposure:

 From large quantities of material as an ore or a stockpile of raw material;

 From small quantities of material with concentrated radionuclides such as mineral concentrates, scales and sludge;

 From material that has been volatilised in high-temperature processes, like slags, precipitator dust and furnace fume.  

(§23): this categorization of “scenarios” for radiation exposure is odd and confusing. It is not clear what is meant here. There is indeed a distinction to be made between large quantities of material (not only ore or raw material stockpile but mainly heap of large amounts of NORM residues, such as tailings disposal sites or phosphogypsum stacks) and moderate/small amount of material with a relatively higher activity concentrations (scales,...). But the “volatised” material is just a particular case and is not really a category of exposure scenario as such: these materials may also be in small quantities (such as deposit within a coal-fired power plant) or in large quantities (heap of slags or fly ashes). A distinction between patterns of exposure could rather be made within the respective sections on workers exposure (e.g. routine processing of NORM material and exposure during maintenance operations) and on public exposure (e.g. scenario related to liquid or atmospheric discharges, to public use of legacy site, to the incorporation of NORM in consumer products such as building materials).

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.

Line 348-358

Table 2.1. Examples of dose assessments for workers (external and internal from dust, excluding exposure to radon)

It is not clear how the doses have been calculated. In particular, it is not clear whether the dose calculations include mitigation or protection measures (such as respiratory protection/face pieces to protect workers from dust) or if the doses refer to a situation in which no protection measures are applied.

The doses given do not cover the full range known to occur. For example, the minerals sands mine QMM in Madagascar, producing TiO2 and zircon, exhibits individual workers’ doses exceeding 20 mSv a year, largely due to external exposures from the high thorium content of some mineral concentrates.

When indicating ranges of possible doses, it seems exaggerated to supply up to 3 significant figures. If exact figures are given, references for these should be given. Also, minimum doses do not really make sense in this context, as this is dependent upon the dose assessment strategy (including which persons are considered to be occupationally exposed).

Line 371-372

 In Table 2.2 the annual effective dose from NORM to public is 371 estimated to be far below 1 mSv per year, except in the situation of wide use of 372 phosphogypsum in building material.

To single out phosphogypsum as the only example of public dose higher than 1 mSv is not correct. For instance, Table 34 of (IAEA 2011[1]) provides an estimation of public exposure related to heavy-mineral sand mining in India: they range between 3 and 17 mSv/a. In the same report, reference is made to the uncontrolled use of such type of sand as building material leading to a gamma dose of 16 mSv. Use of other building materials such as e.g. alum-shale may also lead to dose above 1 mSv.
The example cited about phosphogypsum is a theoretical estimation and the statement gives a misleading idea that use of phosphogypsum as building material is systematically a source of significant public exposure (while in practice activity concentration in phosphogypsum covers a significant range and does not necessarily imply an increased risk of exposure compared to other building material (see IAEA 2013[2]).

Table 2.2 (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 a critical group (or representative person) from atmospheric and liquid discharges from industry dealing with NORM would be always < 1 mSv/a …

line on ‘Use of metal recycling … ‘:  Ra-223 not a typo?

Line 398:

 (30) By-products and residues from a one industry ….

Edit: “a one industry”

Line 430:

The Commission considers workers, human and environmental exposure …

Line 467

“releases and discharges may result in environmental damage and public exposure”

Line 496

- correct punctuation. This sentence is not clear.  

Lines 503-504:

(43)  Industries involving NORM generate environmental exposure through extraction, transportation, storage, processing, effluents, discharges and also from accidental releases.

  these activities can generate public exposure next to environmental exposure and should best be taken up also under 501-502.

Line 528 - 530

However, input to the justification decision may include many aspects that could be informed by the industry involving NORM, workers, the public and organisations other than the government or national authority.

The use of the term “justification” in the context of regulation is questionably. If people need to be protected, why is the additional step of “justification” required? At the very least, this is difficult to explain to ordinary HSE people.

Lines 606-615:

Cfr. remarks L 59-61 (related to 47-51).

Lines 619-623
and 672-674:

(57) The principle of individual dose limits applies only in planned exposure situations (ICRP, 2007a, Para. 203). In the case for NORM exposure, following characterisation of the situation, and optimisation of protection with reference levels, the protection program becomes established, with controls that are effective. The magnitude of exposures will often be relatively low, reflecting the optimisation of protection with reference levels.

 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

(66) Three main exposure scenarios have been identified:

 Exposure to large quantities of material as an ore or a stockpile of raw material;

 Exposure to small quantities of material with concentrated radionuclides such as mineral concentrates, scales and sludge;

 Exposure to material that has been volatilised in high temperature processes, like slag, 680 precipitator dust and furnace fume.

See previous comments cfr. 313-318.

Lines 732-735:

 cfr comment of Line 59-61.

line 763-764:

the statement is correct if it refers to dosimetric follow-up, monitoring of dose at the workplace is in most cases sufficient (if at all necessary) and individual dosimetric follow-up is only rarely needed. But regarding protection equipment, PPEs are generally not more costly than collective protective equipment.

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.

Lines 787-788

 the statement is correct to assess actual exposure and define the need for any additional protective measures. But a worst-case assessment without taking into account existing OHS provisions may be useful in a regulatory process as it gives an idea of the possible dose in case of failure of OHS control (for instance, in some circumstances, a worker may not wear his/her PPEs for personal convenience – even if it is required by OHS provisions). Such a worst-case assessment may provide useful information to define e.g. the stringency of the enforcement policy regarding OHS (especially taking into account the fact that OHS regulator is not necessarily the same as the radiation protection regulator).

Line 812:

 ILO – Perhaps I missed it but is this abbreviation explained in the text?

Line 814

: Is the 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 …

Line 814-817

as mentioned in the text, replacing the raw material by an alternative material with a lower activity concentration is often not possible as the choice of raw material depends on many other factors than radiation protection. One should also be cautious when promoting the use of material with a lower activity concentration: such a choice should be dependent of an analysis of the integrated impact of the alternative material. An alternative material may have lower activity concentration but may present other hazards, e.g. it may be more dusty and imply a higher exposure to fine dust. Here also the search of alternative material should be based on the principle of “doing more good than harm”.

Lines 869-871:

 Not often occurring and better explain what is specifically meant.

Line 870-871

 it is not clear what is meant here: how PPE could lead to an increase of the exposure ? See also remark 9.

14. Section 4.2 “Protection of the public” : As for workers exposure, an integrated hazard management could be recommended. The assessment of a need of a protection strategy may take into account the control measures already implemented for the control or monitoring of non radiological hazards.

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.

Line 1052-1053

“Technologies and methods already exist and should be implemented in order to avoid legacy sites”. This statement is quite vague and its meaning unclear. This implementation can only be done during operations. The statement rather pertains to the section on workers, public and environment exposure: assessment of the risk of exposure needs also a consideration of the scenario related to the dismantling of the NORM facility or the post-closure phase of a disposal site. But this must be part of the risk-assessment of an existing facility; when it is already a legacy, it is too late to implement prevention measures.

Line 1072

 “The challenge may also be due to a lack of societal acceptance”. The meaning of this statement is unclear: acceptance of what ? Of the legacy itself ? Of the remedial actions proposed ?

Line 1075

 (§124): This is not consistent with §99. In remediation as well, the risk of exposure of the workers needs to be assessed but they need to be considered as occupationally exposed only if – as said in §99 - “despite all reasonable efforts to reduce exposure, elevated individual doses persist…”

18. §130 – see generic comment on Section 4.3 – there is a need to take into account variability and diversity of situations. This § should best be removed.

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 the environment also graded approach should applied.

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 1144

 “When dealing with NORM discharges and disposal …”

Line 1160

Industries involving NORM are generally licenced, although in most cases not for radiological purposes, and these industries are used to managing risks.

“The term “licensed” is very broad and can cover everything from a commercial licence to environmental licensing. I guess what is meant here is that most industries are subject to some sort of health, safety and/or environmental regulation, which set certain standards that also reduce radiation risks (e.g., respiratory equipment). This should be made clearer.

Line 1160-1163

Industries involving NORM are generally licenced, although in most cases not for radiological purposes, and these industries are used to managing risks. ... experience shows that the system of radiological protection is very specific and perceived to be difficult to include in the management of other hazards.

The term “licensing” is very broad. The paragraph in its generality is obsolete, or should be rephrased to be more specific. It is not true either that “experience shows that the system of radiological protection is difficult to include in the management of other hazards”. Rather to the contrary, experience shows that if other HSE risks are properly managed in an operation, radiation protection is usually taken care of very well.

In many cases in industry measures already taken for other reasons, already cover the measures one should apply when radiation protection is considered. Often, when all kinds of workers and public protection measures are already existing before the radiation issue is addressed, radiation protection merely enhance all kinds of administrative obligations

Line 1183:

 Involvement of relevant stakeholders.

Line 1381-1382

“32000 tons of uranium and 80000 tons of thorium can be considered as being extracted as well”: this statement is quite naïve and misleading. One can say the same for any raw material (sand, limestone, clay …) or soil extracted in massive quantities. Uranium and thorium “extracted” with coal or any other raw material are not available as such for processing.

Line 1400

in some cases, the concentration of uranium in ion-exchange resins may be considerably higher.

Line 1519-1523

 NORM (naturally occurring radioactive material)

Material containing no significant amounts of radionuclides other than naturally occurring radionuclides, in which the activity concentrations of the naturally occurring radionuclides have been changed by some process and giving rise to enhanced exposure to human and non-human species

why is this definition different from the one of IAEA Safety Glossary? Especially, the sentence “… in which the activity concentrations of the naturally occurring radionuclides have been changed by some process…” is confusing. This definition of NORM is restricted to what was formerly designated as TeNORM – while the draft recommendations also refer to undisturbed material such as ore.

As definition presented it is not the definition of NORM but of TeNORM; NORM also encompasses the natural, extracted material (not transformed) with the original unaltered concentration.

Additional discussion and proposals see below.

Line 1580-1583

Residue

Radioactive materials that have remained in the environment from early operations and from accidents. Residue from one industry may be used as feedstock in another industry, and as such are not classified as waste.

 (definition of residue) – here also it would be clearer if a consistent terminology with IAEA Safety Glossary would be followed (i.e. NORM residue = material that remains from a process and comprises or is contaminated by NORM). Residue is what is left from a process: it may be reused or recycled and not necessarily “remain in the environment”.

Line 1581-1582

Incomprehensive sentence!

Line 1582

Write: Residues

Annex A:

Add geothermal energy and cement production consistent with lines 304-305 and with importance/occurrence of NORM in geothermal energy.