Problems faced by a National Authority to improve NORM regulation

1. Problems faced by a National Authority to improve NORM regulation Vincent Delporte, French Nuclear Safety Authority 1

2. The Nuclear Safety Authority (ASN) is the French Authority in charge of Nuclear Safety and Radiation Protection Concerning Radiation Protection, the ASN : • Delivers authorisation for radioactive sources • Implements the regulations on public exposure • Contributes to the implementation the regulations on occupational exposures Implementation of the Title VII of the 96/29 Euratom Directive 2

3. 3 Steps : • Identification of NORM industries • Stakeholders involvement • Links with other regulations 3

4. Identification of NORM industries (1) Large consensus that NORM could be a problem Lack of data on : • Type of industries that are concerned • How many they are and how many people are concerned • The real impact • How to determine which industries have to be investigated and controlled ? • Is there a need for regulation ? • What has to be regulated ? 4

5. Identification of NORM industries (2) All plants are different : case by case studies are needed New regulation in France : some identified NORM industries have to study their radiological impact • How not to over regulate ? 5

6. Stakeholders involvement (1) • Stakeholders involvement is decisive • Employers involvement : • 3 letters sent to the employers concerned • almost no answer • Fear of being associated with radioactivity ? • Radiation protection is too technical ? 6

7. Stakeholders involvement (2) • Employers involvement : • How to involve NORM industries ? • How to communicate with stakeholders without being too technical ? 7

8. Stakeholders involvement (3) Trade union and environmental protection association involvement : • NORM are « natural raw materials »/ Traditional activities; • Communicating on radioactivity in consumer goods can create social fear and public banning • How to make people aware of the risks without creating a social fear ? 8

9. Links with other regulation (1) Links with « Non nuclear » regulations (chemical or physical ones) • NORM industries are regulated for environmental and occupational impact • Regulated by different departments • How to find a common approach between radiation protection government department and the other ones ? 9

10. Links with other regulation (2) • Already subject to a lot of regulations • How to create homogeneity between radiation protection and industrial hygiene regulation ? • Is it possible to create a synergy between the different protection measures ? 10

11. Links with other regulation (3) Links with regulation on nuclear facilities • Homogeneity of the dose limits • How to create such an homogeneity ? • What dose limit should wechose for radiation protection in NORM industries ? 11

12. Links with other regulation (4) Links with the regulation on radon • What limit for radon in NORM industries ? • Do we have to include radon in dose calculation ? 12

13. Links with other regulation (5) Links with the regulation on waste • Are NORM waste radioactive ? how to explain it ? Links with international concepts • How to apply Clearance/ Exemption/Exclusion on NORM ? • NORM industries : practice or intervention ? 13

14. A lot of questions to answer… 14