Chapter 3: Methodology
3.2 Research design and data collection
H.B. OKYAR
International Atomic Energy Agency, Vienna
Email: [email protected] Abstract
The paper highlights some of the key features of the IAEA’s work programme that has been initiated to assist Member States in the implementation of the latest safety requirements for NORM industries, as set out in the IAEA International Basic Safety Standards. The characteristics of industrial processes and exposure situations involving NORM are in many cases quite different from those associated with other activities involving radioactivity. Examples given in the paper refer to the wide diversity of industrial processes and process materials, the generally very low (but sometimes unpredictable) exposure levels, the presence of non-radiological hazards that may well be of greater concern than radioactivity, and the involvement of several different regulatory bodies.
This situation gives rise to various challenges for operators and regulatory bodies alike. For instance, guidance on radiation protection and NORM residue management has to be tailored to specific NORM industries and/or industrial processes and has to address the management of extremely large amounts of NORM residues (including the use or recycling of residues where possible) and the remediation of contaminated legacy sites. Reference is also made to the general lack of radiological knowledge and radiation safety culture, as well as the need for engagement with all the various stakeholders.
1. WORK PROGRAMME
The latest version of the IAEA’s International Basic Safety Standards — IAEA Safety Standards Series No. GSR Part 3, published in 2014 (the “BSS”)5 — establishes requirements for NORM industries in planned and existing exposure situations. These requirements create new challenges for regulatory bodies and operators because the activities concerned cover broad industrial sectors with highly diversified characteristics and because, in the past, many such activities have not been regulated in terms of radiation safety. In the application of the BSS to NORM activities, consideration needs to be given to radiation protection of workers, the public and the environment for a wide range of NORM industries on a global basis. The IAEA has initiated many activities, including the development of safety guides and safety reports, for assisting Member States in implementing the relevant requirements of the BSS.
In managing NORM residues (including those to be disposed of as NORM waste), radiation protection of the public and environment need to be addressed. This includes the control of NORM discharges, the use and recycling of residues and the application of the concepts of exemption and clearance. The long term safety of NORM waste is a particular challenge, requiring appropriate control of the disposal of such waste in, for instance, conventional landfill facilities and the decommissioning and remediation of relevant facilities and sites. Various options should be considered, understood, applied and assessed as to whether
5 EUROPEAN ATOMIC ENERGY COMMUNITY, FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS, INTERNATIONAL ATOMIC ENERGY AGENCY, INTERNATIONAL LABOUR ORGANIZATION, OECD NUCLEAR ENERGY AGENCY, PAN AMERICAN HEALTH ORGANIZATION, UNITED NATIONS ENVIRONMENT PROGRAMME, WORLD HEALTH ORGANIZATION, Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA, Vienna (2014).
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radionuclides and other potentially hazardous materials are appropriately isolated from the human environment.
While the radiological aspects of NORM industries can be characterized in a general way, radiation protection needs to be managed in a site specific and practice specific manner. Thus, radiation protection addressing public health concerns associated with releases of radionuclides to the environment, the incorporation of process residues into building materials, and the safe long term management of NORM residues (including NORM waste) requires tailored and graded approaches and an understanding of consequence management. This in turn requires consultation and engagement with the various stakeholders.
The IAEA work programme on NORM focuses heavily on the application of the graded approach, one of the key concepts in the BSS. The programme includes the development of industry specific guidelines for radiation protection and management of NORM residues, long term management of bulk NORM residues and remediation of legacy sites contaminated with NORM. The work programme also addresses the need for enhanced and improved levels of knowledge, understanding and communication.
2. OPPORTUNITIES AND CHALLENGES
NORM is a crosscutting activity within the IAEA and the intention is to extend the IAEA’s library of NORM standards with direct and clear messages to Member States. One of the pillars of such a work programme is worker protection in different NORM industries, which generally needs to deal with multi-hazard situations where the radiological risk is generally not the dominant risk. Referring to the various safety reports published by the IAEA in this technical area, the overarching issues common to all industry sectors are the following:
– Doses received by workers are always expected to be below thresholds for deterministic effects — indeed, doses are less than 1 mSv/a in most workplaces of NORM industries with only a few exceptions in cases such as the production of uranium, thorium and rare earth elements;
– It is not always possible to predict doses;
– There is a lack of radiation protection culture in NORM industries and it is difficult to achieve the same level of culture as that existing within the nuclear industry.
The safety reports on NORM published by the IAEA address the key question: “at what level does it become necessary to regulate?” They also address the principle of the graded approach to regulation, one of the key principles on which the BSS is based. A graded approach to the radiation protection of workers is a critical component of the regulatory regime. It has a direct influence on operations and on the need to ensure that appropriate monitoring and control mechanisms are in place.
In June 2016, the Radiation Safety Standards and Waste Safety Standards Committees of the IAEA met in Vienna. A topical session on challenges in regulating NORM industries was organized, with the following objectives:
– To present the key safety issues in terms of policy, regulatory and operational aspects of NORM industries;
– To identify and prioritize areas where safety and optimization of protection is challenging;
– To suggest areas where the Secretariat could work further to enhance the internationally harmonized system.
It was generally observed that:
21 (a) While the need for appropriate control of NORM is widely recognized, the development
of a framework for control is not emphasized as much as it should be.
(b) NORM industries cover a large variety of practices, processes and circumstances and involve multiple regulatory bodies.
(c) Occupational exposures of mine workers can be significant under certain circumstances.
(d) NORM residues cover a wide range of physical, chemical and radiological characteristics.
Many have the dual characteristics of long-lived radionuclide content and the existence of bulk amounts, of the order of millions of tonnes, creating challenges for management and subsequent remediation.
(e) Many of the industry sectors concerned have limited levels of awareness, resources and experience on issues of radiation protection and the management of NORM residues (including NORM waste).
(f) There is a need for a consistent, graded and integrated approach in dealing with NORM.
There are many challenges in establishing control over NORM, of which the following should be given priority:
(1) The development of standards and guidelines for NORM that are appropriate and capable of dealing with the complexities that arise from the nature of NORM industries and from the involvement of multiple regulators and a broad range of stakeholders.
(2) The adoption of a graded approach to the regulation of NORM industries and the residues therefrom, based on good knowledge and understanding of the diverse industrial sectors involved.
(3) Synergies and system optimization with integrated consideration of radiological and non-radiological hazards.
(4) The limited experience in radiation protection that exists in many industry sectors other than uranium production.
(5) The siting and long term management of bulk amounts of NORM residues, including consideration of institutional control and financial aspects.
(6) The remediation of legacy sites and any ongoing monitoring and control of these areas after remediation.
(7) The use and recycling of NORM residues to avoid the need for long term management and eventual disposal.
(8) The engendering of stakeholder trust that enables the development of a common language for engaging stakeholders in open and transparent dialogue.
It should be noted that over the last 15 years the IAEA has developed numerous publications related to NORM industries and that the drafting of these publications has been performed with the involvement of both operators and regulatory bodies. The publications in the IAEA Safety Reports Series and TECDOC Series are geared to providing both operators and regulatory bodies (including staff at junior levels) with the necessary information for ensuring ‘good practice’ in operation and regulation.
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Invited Paper