The approach taken by ICRP on the protection against exposure caused by NORM industries – i.e. protection according to the provisions for existing exposure situations, which is first formulated in ICRP 103 and is elaborated in this document - is fundamentally different from the approach of international organisations such as the IAEA and the European Commission (EC), who regard NORM industries as being subject to the provisions of planned exposure situations. ICRP states in para 10 that there is a ‘need for international consensus on NORM exposure management and that industries involving NORM have been regulated variably with regard to radiological protection, because the radiological protection system has been introduced after the start of operation’, but this document will not contribute to this consensus. Rather than striving to international consensus, ICRP causes confusion by its position, without a proper explanation and - in my view - also without any advantage above the position taken by IAEA and EC. It is very likely that the international community will ignore the standpoint of ICRP, because the Member States of IAEA and those of the EU have adopted their approach in the Safety Requirements, respectively the Euratom Directive. In the latter case many EU Member States have in the meantime incorporated the Directive in their national legislation. Both international organisations therefore already reached international consensus on the approach to regulate NORM industries. ICRP has therefore been overtaken by other international organizations such as IAEA and the European Commission (EC) in addressing NORM in their publications.
The only paragraph where ICRP is addressing this issue is para 58, stating that 'specifying a limit for regulatory purposes is not meant to imply that the situation has been, or needs to be, transformed into a planned exposure situation. In the vast majority of industries involving NORM, the application of ‘limits’ expressed in terms of dose provides no real additional protection for workers, and may entail administrative burdens that are not in keeping with efficient and effective use of resources'. This standpoint is very debatable. The use of a graded approach is crucial for regulating NORM industries. This can be done without problems by applying the provisions of a planned exposure situation, as has been proven by many Member States in the meantime.
The argument for considering the exposure by NORM industries as an existing exposure situation, namely that ‘the radiological protection system has been introduced after the start of operation’ (para 10) might have been valid about, say, 4 decades ago. In the meantime there is a wealth of information about the radiological implications of NORM, which has led to a number of guidance documents from the IAEA and the EC. There may still be old on-going operations for which the above-mentioned statement is valid, but it certainly does not justify the existing exposure situation as the basis for protection. Nowadays, it is the deliberate choice of an operator to start, or to continue, its industrial activities knowing that his raw materials, or his processes, leads to exposure of workers, public and/or environment. It does not matter that the presence of the natural radionuclides is adventitious. It is the action of the operator that leads to a planned exposure. This is the reason why IAEA and EC has taken another position as ICRP does.
During the last decades, NORM operations have been started and also ceased. This process is still going on. Moreover, there are many examples where the processing of the raw materials is carried out at a different site than the mining. It is not logical to consider the operations at a processing site as an existing exposure situation, even when the operations started already long ago. There are also examples of NORM industries that, depending on the price on the market, produce also uranium as a by-product. In that case, the industry should be regulated as a practice, belonging to the nuclear fuel cycle (see para 33). But when the price is low, the industry may cease the by-product production and then the industry should fall again in the category of existing exposure situations, according to the draft ICRP document. This is not logic, because on the shop floor there will be not much of a difference.
I therefore advise ICRP to reconsider their choice.
In the following I add some specific comments:
Para 7: ‘This publication recommended that dose constraints and dose limits for practices may be appropriate to NORM exposure…’. ICRP 101, Part 2, already took the position of choosing a planned exposure situation as the basis for protection.
Para 12: ‘The focus is upon industrial processes such as mining and mineral extraction, or other industrial activities that may lead to exposures to NORM of geological origin, which have been identified as requiring consideration of radiological protection’. This leads, in my view, to the conclusion that a NORM operation leads to a planned exposure situation, not to an existing exposure situation as stated in the sentence before.
Para 25: ‘Until implementation of the International Basic Safety Standards for protection against ionising radiation in 1996 (IAEA, 1996) most countries had not been particularly concerned with assessing occupational exposure to natural sources of radiation’. I do not see the value of incorporating this sentence in the text. I propose to delete it.
Para 39: ‘In most cases the exposure of workers in industries involving NORM is adventitious because the presence of NORM in the material processed is a natural fact, without intentional addition for its radioactive purpose, and the workers are often not considered occupationally exposed’. Again, the NORM operation is planned and the process alters the exposure scenarios. Therefore, the exposure belongs to a planned exposure situation.
Para 66: ‘an ore or a stockpile of raw material’. Exposure to residues and waste should be added here.
Para 86: ‘As a result, there is often a complete lack of knowledge about radioactivity and radiological protection’. This is no longer the case after 40 years of building up experience.
Para 87: ‘accidental’. Delete this word.
Para 88: ‘the delineation of areas is a well-established element of the control strategy in planned exposure situations’. This is not only the case in planned exposure situations.
Para 89: ‘chronic’. Replace by ‘long-term’.
Para 105: ‘The optimisation process and the involvement of stakeholders are case specific and depend, in practice, on the operational characteristics of the NORM facility, discharge processes, radioactivity levels and estimated risk, the public groups involved, as well as societal and political aspects and public awareness’. The involvement of stakeholders should not depend on societal and political aspects.
Para 108: ‘with no further planned use’. I propose to replace this by the IAEA definition.
Para 109: ‘high levels’. Replace by ‘higher activity concentrations’.
Para 111: ‘recycled and re-used’. Replace by ‘recycled and/or reused’.
Para 111: ‘They are mainly coming from upstream of the NORM cycle (exploration, extraction of material)’. Not only upstream. PG and slag are residues.
Para 115: ‘is not’. Replace by ‘is generally not’.
Para 116: ‘less than 1’. Depends on the type of index.
Para 117: ‘with the aim to promote building materials that do not exceed the reference level. The strategy’. ICRP should avoid to promote certain types of building materials. They all have their own qualifications and purposes. I propose to delete this part of the text and replace it by ‘that’.
Para 136: ' While industries involving NORM have experience in risk management, they have generally a poor awareness of radiological protection; this can and should be developed’. This is no longer the case after 4 decades of building up experience.
Line 1521-1523: ‘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’. Delete this part of the definition.
Line 1581-1582: ‘Radioactive materials that have remained in the environment from early operations and from accidents’. This is not a correct definition of a residue.