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Submitted by Charles T. Simmons, Zirconium Environmental Committee
   Commenting on behalf of the organisation
Document The scope of radiological protection
The following comments are submitted on behalf of the Zirconium Environmental Committee (ZEC). The ZEC is a group of companies that are involved with the production, research and development, and use of zircon and zirconia, worldwide. Because zircon and zirconia contain the naturally occurring radioactive materials (NORM) uranium and thorium, ZEC members are directly affected by policies addressing the regulation of NORM.

1. The draft document “The Scope of Radiological Protection Regulations” sets forth welcome clarifications regarding exclusion or exemption of natural materials from the scope of radiation protection regulations. This document is an important step in reducing inconsistent regulations of NORM worldwide. However, further emphasis on certain issues, discussed below, would be very useful in reducing ambiguity and ensuring a uniform regulatory structure.

2. The following clarifications in the document are particularly important in that they may reduce regulatory disharmony that has led to inconsistent regulation of NORM-containing industrial minerals.

Paragraphs (44) through (47) explain that it is not feasible to apply a 10 ìSv/a dose criterion to situations involving exposure to naturally occurring radioactive material. This clarification is very welcome and should be preserved with emphasis in the final draft. The misapplication of 10 ìSv/a as an exemption criterion should be avoided.

Paragraph (48) states that situations where worker doses from naturally occurring radioactive materials are below 1mSv per year might be appropriate for exemption.

Zircon and zirconia are industrial minerals that are typically exclusively used in workplaces subject to international standards regarding exposure to fumes, dusts, and other inhalation hazards. Existing industrial hygiene controls, particularly with regard to inhalation exposure against non-radiological hazards, have the collateral benefit of reducing inhalation dose, which is the principal route of exposure to NORM from industrial minerals. Paragraph 48 should emphasize that industrial hygiene controls for non-radiological protection purposes should be taken into consideration in deciding whether additional regulation for radiation protection purposes is warranted.

The concepts “generic exemption” and of “graded approach” to regulating NORM industries set forth in paragraphs 92 to 95 is welcome but further elaboration may be desirable. For example, while a generic exemption might be applicable to NORM materials below 1 Bq/g as it “would be coherent with the 1 mSv in a year criterion” it should be noted that NORM minerals like zircon and zirconia in the order of 3 Bq/g also satisfy the 1 mSv/y criterion because of their chemical and physical properties and use patterns in workplaces with dust controls.

The graded approach to regulation in paragraph 92 is very appropriate for NORM. It may be desirable for the Commission to provide an example of how a graded approach would be applied to NORM regulation for practical application. Paragraph (95) explains that materials above 1 Bq/g are not automatically a candidate for regulation, and exemption is appropriate if dose is below 1 mSv/y. This is consistent with experience with zircon and zirconia.

Section 6.5 addresses “commodities” from the perspective of consumer commodities – i.e., materials that are used or consumed by the public. It is appropriate to distinguish between the consumer commodities that are the subject of Section 6.5 and industrial commodities. Consumer commodities have greater potential for public exposure and are unrestricted in use pattern. Industrial commodities, on the other hand, are used for certain specific, limited purposes, in a workplace setting. Refractories, for example, that are used in melting glass or casting steel, are industrial-use commodities with very limited public exposure potential.

In conclusion, the draft report provides a welcome and very much needed perspective on factors to be considered in exempting NORM-containing materials from the scope of regulation. Read in conjunction with international consensus documents such as IAEA’s RS-G-1.7, it is hoped that the Commission’s draft will provide improved guidance to national regulators in developing uniform NORM regulations. Going forward, it is hoped that the Commission will provide practical guidance on the graded approach to regulation, a principle that is equally well-suited to developing disposal options for NORM containing wastes.

Thank you for this opportunity to submit comments to the Commission.

Charles T. Simmons
on behalf of
The Zirconium Environmental Committee