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Naturally Occurring Radioactive Material

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As part of the Radiation Health and Safety Advisory Council's role in advising the CEO of ARPANSA on emerging issues and issues of public concern in radiation protection and nuclear safety, Council prepared a discussion paper, Naturally-Occurring Radioactive Material in Australia: Issues for Discussion, at the request of the CEO. The discussion paper was released for a period of public comment from September to December 2004. The discussion paper described what NORM is, and examined why NORM is different from other radioactive materials, which industries produce NORM waste and how much is generated. The paper also discussed NORM in commodities, international guidelines and regulatory issues, trade issues, Australian radiation protection regulations and guidelines, and issues and options for dealing with NORM waste.

Council also arranged for Dr M.B. Cooper, EnviroRad Services Pty Ltd, to provide a consultant's report on the quantities and generation of NORM waste in Australia, to assist Council in preparing the discussion paper.

Council sought comment, in particular, on whether there is a need to:
  • Develop national guidance on exclusion, exemption and clearance for natural radioactive materials, to enable a uniform approach to establishing criteria that may be used to regulate NORM in all jurisdictions. The guidance would take the existence and variability of the natural background into consideration, and also allow for the wide range of scenarios that can lead to exposure to ionizing radiation from materials containing NORM.
  • Develop national guidance on strategies and criteria for the treatment and disposal of NORM arising from various process waste streams, including by landfill or land spreading.
  • Develop guidance for remedial action at sites contaminated by historical NORM waste generation, including reviewing the 1984 NHMRC statement "Guidelines for Remedial Action in Areas where Residues from Mineral Sand Mining and Processing have been Deposited" to ascertain whether the information is still relevant and, if necessary, re-publish up to date guidance within the Radiation Protection Series.
  • Develop a strategy for raising awareness of NORM issues, both in relevant industries and with the public generally.
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Eighteen submissions were received during the consultation period. There was further discussion of the issues raised in the discussion paper at ARPANSA's National Conference on Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing, held in April 2005. The main issues arising in the submissions were:

Comments received specific to Council's questions
  • The submissions indicated general support on the need for national guidance on NORM, particularly in relation to exemption and exclusion levels. However, some submissions indicated a concern that there would be additional regulation, and that national guidance on NORM waste management could not be undertaken until improved data was obtained and risk analysis had been carried out.
  • The need for guidance on remedial action at contaminated sites was supported, but some industries advised that were not aware of any situations requiring remedial actions, and some indicated that guidance would be premature without better data and risk analysis.
  • There was support for increased awareness, however submissions noted that awareness-raising should be done in consultation with industry and State/Territory regulators.
General comments received
  • Some submissions commented that there was a need for more data and risk analysis before considering regulatory options.
  • Criteria for regulation should not be based on activity concentration alone, but should include consideration of risk.
  • Concerns that regulatory intervention would have the potential to disadvantage some industries.
  • A view that the existing environmental regulatory framework is sufficient, with appropriate amendment for NORM. An additional layer of regulation is not appropriate, and in some industries could affect viability.
  • Several industries provided additional useful data for both the Council Discussion Paper and the Cooper Report.

It should be noted that some misconceptions regarding ARPANSA's role and intentions were also evident in submissions.

The full submissions and responses to the submissions are available via the following link:

Following consideration of the public submissions and the further input at the National Conference, Council's discussion paper and Dr Cooper's report were updated to reflect some additional data made available in submissions, and to correct factual material advised in the submissions. The final papers are available via the following links:

Council's advice on NORM was forwarded to the CEO on 28 September 2005. The CEO's response to the Council recommendations was discussed its meeting of 25 November 2005.

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As recommended by the Council, ARPANSA will work to:

'develop national guidance on NORM management, including uniform exclusion and exemption provisions, treatment and disposal of NORM arising from various waste process streams and remediation of contaminated sites.'

In doing this work, ARPANSA will observe the following principles:

  • A Safety Guide has been developed in consultation with industry and other relevant stakeholders and in consultation with the States/Territories through the Radiation Health Committee.
  • Where application of the guidance requires adoption through the National Directory for Radiation Protection (NDRP), the full consultation and agreement process for matters to be included in the NDRP will be followed. This includes preparation of and consultation on a regulatory impact statement.
  • The safety guide takes account of international guidance, especially that in the IAEA Safety Guide Application of the Concepts of Exclusion, Exemption and Clearance (RS-G-1.7) and the forthcoming Safety Guide Safe Management of Wastes Containing NORM (DS 352), together with exclusion and exemption provisions of the NDRP.
  • Assessment of the need for guidance or regulation in any industry category or specific industry example will be based upon collection of real-life data and a thorough assessment of risk (potential doses of radiation to workers and public). The degree of any regulation must be commensurate with the assessed risk and designed to bring that risk to an acceptable level.

Developments in Radiation Protection Regulation Relevant to Management of NORM

At its meeting in October 2006, the Radiation Health Committee (RHC) was asked to consider ARPANSA's proposal for the management of NORM prepared in response to Council’s recommendations. RHC reviewed the background paper and approved the document development plan proposing that a Safety Guide on the Management of NORM in Australia be developed as an ARPANSA Radiation Protection Series publication. The Safety Guide was published in August 2008.

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