[ RadSafe ] EU NORM Question
gert.jonkers at shell.com
gert.jonkers at shell.com
Mon Oct 21 06:15:50 CDT 2013
Charlie,
In your original mail you were wondering "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?" IMHO you have to look for approval of your documented dose assessment by your national competent authority, before company activities may be exempted from further national NORM regulatory requirements. This may require some cogency towards the national competent authorities.
Based on the outcomes of national implementations of Title VII of EC Directive 96/29 the EU has come up with a "list of industrial sectors involving NORM as referred to in article 24". Zircon and zirconium industry (incl. research and relevant secondary processes) is present on this list. The list (Annex V) I am referring to is derived from the May 24, 2013 draft EU Directive intended to replace EC Directive 96/29 within in the near future.
As you probably know the Directive you are referring is more or less ready for update and soon will be replaced by a new Directive.
From the (draft) new Directive Annex VI "exemption and clearance criteria as referred to in articles 25a, 25c and 29" Table A, part 2 applies to all Naturally Occurring Radionuclide's (NOR's) "in the decay chain of U-238 and Th-232, but for segments of the decay chain, which are not in equilibrium with the parent radionuclide, higher values may be applied".
Table A, part 2 reads:
"values for exemption or clearance for NOR's in solid materials in secular equilibrium with their progeny"
NOR's from the U-238 series 1 kBq/kg
NOR's from the Th-232 series 1 kBq/kg
K-40 10 kBq/kg
Next to this there is a Table B that lists "total activity values for exemption and exemption values for the activity concentration in moderate amounts of any type of material". Here for the relevant NOR's this table provides
NOR sub-series NOR's
U-238 DECAY SERIES
U-238(eq) Th-234 & Pa-234m 10 kBq/kg 10,000 Bq
Th-234(eq) Pa-234m 1,000 kBq/kg 100,000 Bq
U-234 10 kBq/kg 10,000 Bq
Th-230 1 kBq/kg 10,000 Bq
Ra-226(eq) Rn-222 u/u Po-210 10 kBq/kg 10,000 Bq
Pb-210(eq) Bi-210 & Po-210 10 kBq/kg 10,000 Bq
Bi-210(eq) Po-210 1,000 kBq/kg 1,000,000 Bq
Po-210 10 kBq/kg 10,000 Bq
Th-232 DECAY SERIES
Th-232 not listed
Ra-228(eq) Ac-228 10 kBq/kg 100,000 Bq
Ac-228 10 kBq/kg 1,000,000 Bq
Th-228(eq) Ra-224 u/u Tl-208/Po-212 1 kBq/kg 10,000 Bq
Ra-224(eq) Rn-220 u/u Tl-208/Po-212 10 kBq/kg 100,000 Bq
Pb-212(eq) Bi-212 u/u Tl-208/Po-212 10 kBq/kg 100,000 Bq
Bi-212(eq) Tl-208/Po-212 10 kBq/kg 100,000 Bq
Comment: during Oil & Gas Production (also listed in Annex V), mainly Ra NOR's are leached and transported with the aqueous stream to the surface. For Ra-228 this implies, that we are only dealing with Ra-228(eq), but guess what happens if this NOR's deposits in a scale wit the approximate exempt concentrations (so 10 kBq/kg) and the scale resides for say 2 years in operational installations. Roughly speaking Th-228(eq) concentrations grow in from 0 kBq/kg (exempt) to about 8 kBq/kg (non-exempt). This issue was already more or less flagged in the EU Directive 96/29, but still not taken care of in the new draft.
K-40 100 kBq/kg 1,000,000 Bq
Potassium salts in quantities < 1,000 kg are exempted
Hope this helps to settle your query,
Kind regards,
Gert Jonkers
-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu [mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of csimmons at csimmonslaw.com
Sent: Thursday, October 17, 2013 4:42 PM
To: The International Radiation Protection (Health Physics) Mailing List; Nick Tsurikov; Robert Atkinson
Subject: Re: [ RadSafe ] EU NORM Question
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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