[ RadSafe ] EU NORM Question

Thu Oct 17 09:41:34 CDT 2013

Dear Robert and Nick –

Actually, the 1 Bq/g exemption value pre-dates Directive 96/29 in the 1993 Rad
Pro 65, a guidance drafted with the apparent intent of defining exemption values
(concentration and quantity) “below which reporting is not required in the
European Directive.”  RP 65 derived an activity concentration value of 1.0 Bq/g
for natural uranium in equilibrium and 1.0 Bq/g for  natural thorium in
equilibrium.  The derived values applied a target annual effective dose of 10
microSieverts per year to a variety of (conservative) modeling scenarios
intended to represent “normal” and “pessimistic” conditions.  The 1.0 Bq/g value
was adopted in Annex I of Directive 96/29 as values below which no reporting is
necessary (applicable to “practices” per Art. 3, para. 2 of Directive 96/29).

Why is this important in current European national regulations based on 96/29?

Because national authorities were afforded the discretion to include NORM
activities that “lead to a significant increase” in worker and public exposure
“that cannot be disregarded from the radiation protection point of view” within
the scope of the Directive [Art. 2, para. 2], national authorities in many
European countries have adopted, through Order, Decree, or other prescriptive
mandate, a reporting requirement for NORM having 1 Bq/g (any combination of
U-nat plus Th-nat).

While the 1.0 Bq/g exemption value seems to resonate in subsequent guidance
documents coming from the EC and IAEA (RS-G-1.7 in particular), some European
countries have adopted an exemption value of 0.5 Bq/g which is apparently
derived from RP 122, Part 2.

Of course – and I’ve heard it before on Radsafe – “it’s all about dose!”  And
industrial minerals having 1.0 – 3.0 Bq/g can, under a variety of conservative
modeling scenarios limited only by the imagination of the modeler, yield
significant annual doses in the tens of mSv or more.  However, there are plenty
of high quality dose assessments done in mineral processing, ceramic, and other
NORM industries that show occupational doses from NORM are a few uSv/y, and
virtually always the result of existing industrial hygiene measures taken to
protect workers against inhalation hazards of crystalline silica, metals, etc.

On October 17, 2013 at 9:23 AM Nick Tsurikov <nick.tsurikov at gmail.com> wrote:
> Dear Robert,
> In my recollection, there were many relevant EC publications following the
> EURATOM Directive 96/29. If I'm not mistaken, the value of 1 Bq/g first
> appeared in EU RadPro-95. Then I am not 100% sure (do not have the time at
> the moment), but something along the same lines was in EU RadPro-122 and
> RadPro-135.
> Most importantly, I would like to draw your attention to parts 3.6 and 4.3
> of the relatively recent (2010) EU RadPro-157, "Comparative Study of EC and
> IAEA Guidance on Exemption and Clearance Levels", it all in there I think.
> Sure, the Directive itself does not say it, but there are plenty of EC
> documents on the interpretation of the Directive...
> Kind regards
> Nick Tsurikov
>
>
> On Thu, Oct 17, 2013 at 7:39 PM, Robert Atkinson
> <robert8rpi at yahoo.co.uk>wrote:
>
> > Hi Charlie,
> > Where do you get 1Bq/g and notification requirements from? Title VII just
> > refers to "Significant Increase in Exposure". The only level mentioned is
> > >1mSv/year for aircrew. there is no mention of concentrations,
> > reporting, nor is it specic to U or Th, all natural gamma radiation, plus
> > Radon, Thoron and their daughters are addressed. The flight crew exposure
> > is cosmic, not NORM.
> >
> > Regards,
> > Robert Atkinson.
> >
> >
> > ________________________________
> > From: "csimmons at csimmonslaw.com" <csimmons at csimmonslaw.com>
> > To: 'The International Radiation Protection (Health Physics) Mailing List'
> > <radsafe at health.phys.iit.edu>
> > Sent: Wednesday, 16 October 2013, 15:17
> > Subject: [ RadSafe ] EU NORM Question
> >
> >
> > Hello, Radsafe -
> >
> > I have a question regarding current regulation of NORM materials in
> > European
> > Countries:
> >
> > In accordance with Title VII of EC Directive 96/29 as transposed into
> > national
> > law of the Member States, is it obligatory for a company using a NORM -
> > containing material having 1 Bq/g or more U and Th to "notify" the relevant
> > authority? [My specific reference material is a zirconia ceramic at 2 Bq/g
> > U+Th]
> >
> > Alternatively, if a company using such material has performed occupational
> > and
> > public dose assessments confirming worker and public dose is
> > indistinguishable
> > from background, is the company exempt from further NORM regulatory
> > requirements?
> >
> > Any information regarding NORM regulation in the EU is greatly appreciated.
> > Thank you.
> >
> > Charlie Simmons
> > _______________________________________________
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