RE: European regulation of NORM as an minor component of other ma

["Jonkers, Gert SIC-CTAN/2" <Gert.G.Jonkers@opc.shell.com>]

Richard,

The information wrt the Dutch legislation given by Nick Tsurikov is correct.


Just some additional information: 
there is no dedicated NORM regulation in the Netherlands. The regulations
with respect to the Naturally Occurring Radionuclides (NOR's) are fully
implemented into the Dutch 'Nuclear Energy Act' (Kernenergiewet or Kew) with
amendments. The Kew states a limit of 500 Bq[total]/g for 'solid natural
radioactive substances' (my translation). 

As according to Kew Upholding and Inspection this was a vague and
stretchable definition, they exploit more or less the following
interpretation: the substance should be in its 'natural matrix' in order to
apply the 500 Bq[total]/g limit (according to Kew Upholding and Inspection
an indication of 'natural matrix' is the measure in which secular
equilibrium is achieved in these materials). According to upholding and
inspection for e.g. mineral sands (separated in their constituting
components - rutile, zircon, ilmenite, monazite, etc. - on the basis of
their physical properties) the 500 Bq[total]/g is not applicable and 100
Bq[total]/g should be used. The same is true for e.g. rock wool, in the
older days spun from molten slag (ex ore processing), 100 Bq[total]/g is
applied (FYI general concentrations in rock wool are about 200 Bq[total]/g
thereby classifying the material as 'radioactive').

For the computation of the total activity the following 'conservative' rules
applies, if e.g. a material contains 5 Bq[U-238], 5 Bq[Th-232] and 5
Bq[K-40] per gram, its total activity concentration would be
5 times 14 (# of member of U-238 series) + 5 times 10 (# members of Th-232
series) + 5 = 125 Bq[total]/g = 'radioactive'
if no secular equilibrium exists e.g. a material contains 0.5 Bq[U-238], 5
Bq[Ra-226], 10 Bq[Pb-210], 0.5 Bq[Th-232], 5 Bq[Ra-228], 3 Bq[Th-228] and 5
Bq[K-40] per gram its total activity concentration would be
0.5 times 5 (U-238 till Th-230) + 5 times 6 (Ra-226 - no emanation - till
Po-214) + 10 times 3 (Pb-210 till Po-210) + 0.5 (Th-232) + 5 times 2 (Ra-228
& Ac-228) + 3 times 7 (Th-228 till Tl-208/Po-212) + 5 (K-40) = 99
Bq[total]/g = 'non-radioactive'

In Germany, only the 500 Bq[total] per gram applies. Besides, the definition
of 'total activity' and 'gram' is somewhat stretched towards the industry.
If a piece of equipment is surface contaminated with a scale deposits of say
60 Bq[Ra-226]/g and 40 Bq[Ra-228]/g, 1) the total activity concentration of
the scale would be 60 + 40 = 100 Bq[total]/g, and 2) the weight of the total
piece of equipment may be taken into account thereby reducing the activity
concentration considerably. You can imagine what happens if such an object
crosses the Dutch/German border.

Hopefully this kind of 'confusion' will disappear with the implementation of
the EU directive 96/29/Euratom into the respective national legislations.

Kind Regards, Gert Jonkers 
CTAN - Analytical - Nuclear Measurement Techniques
http://sww.ksla.shell.nl/analytical/skills/nuclearmea/1.html
   Radiotracer applications, 
   Gamma-transmission and Neutron BackScatter (NBS) measurements
   Naturally Occurring Radioactive Materials (NORM)
   Radiological Protection Advice
Shell Research and Technology Centre, Amsterdam (SRTCA), 
http://www.srtca.shell.nl/welcome.html
PO Box 38000, NL-1030 BN Amsterdam, the Netherlands
tel.        +31 - 20 - 630 3424
fax        +31 - 20 - 630 2911
e-mail   Gert.G.Jonkers@OPC.Shell.COM

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