In 1946, the Parliament of Canada passed the Atomic Energy Control Act and established the Atomic Energy Control Board (AECB), providing it with the power to regulate all nuclear activities related to the development and use of atomic energy in Canada. In May 2000, the Nuclear Safety and Control Act (NSCA) came into effect and established the CNSC as the successor to the AECB, with responsibilities and authorities to regulate an industry that spans all segments of the nuclear fuel cycle and a wide range of industrial, medical and academic uses for nuclear substances.
At this time Naturally Occurring Radioactive Materials – NORM were specifically excluded from the CNSC regulatory control with the exception of import/export of NORM and transport if activity concentrations exceeded 70 Bq/g. As such, each Canadian Province or Territory has regulatory control in its jurisdiction over NORM. In order to assist provincial regulators and industry to properly manage NORM, Health Canada, developed the Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials – NORM (Canadian NORM Guidelines).
Canada’s radiation protection standards, including the Canadian NORM Guidelines, are benchmarked against international standards. To do this, Canada relies on the work of international organizations such as the International Atomic Energy Agency (IAEA) and the International Commission on Radiological Protection (ICRP). These organizations are composed of leading experts in the management of radioactive materials. With the cooperation of its member states (Canada included), the IAEA publishes a number of international standards, including the international Basic Safety Standard – “Radiation Protection and Safety of Radioactive Sources. This standard provides the basic principles and practices to ensure protection for workers and members of the public from radioactive materials. Exposure limits recommended by these organizations have been adopted by regulators (including the Canadian Nuclear Safety Commission and Health Canada), and form the basis of Canada’s regulations.
CANADIAN NORM GUIDELINES
The Federal Provincial Territorial Radiation Protection Committee (FPTRPC), a Canadian intergovernmental committee established to support federal, provincial and territorial radiation protection agencies in carrying out their respective man dates, recognizes that the potential To that end, the Canadian NORM Working Group has, on behalf of the Federal Provincial Territorial Radiation Protection Committee, produced the Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM). These NORM Guidelines are an extension of the work done by the Western Canadian Committee on Naturally Occurring Radioactive Materials (NORM) published in August 1995 as the Guidelines for the Handling of Naturally Occurring Radioactive Materials (NORM) in Western Canada. The differences between the Canadian Guide lines and the Western Canadian Guide lines reflect changes in national and international radiation protection practices and consensus on standards for NORM classification and management since 1995. The Canadian NORM Guidelines set out principles and procedures for the detection, classification, handling and material management of NORM in Canada. These Guidelines provide the framework for the development of more de tailed NORM management practices and guide lines by regulatory authorities and affected industries.
OCCUPATIONAL HEALTH AND SAFETY REGULATIONS
Detailed Radiation Protection regulations for NORM have not been developed and as such worker protection falls under provincial Occupational Health and Safety Regulations. Although each provincial OH&S regulation wordings differ slightly the basic concept is the same. If an employer subjects a worker to a potential hazardous material including NORM they must ensure the following:
- Develop and implement an exposure control plan or safe work practices and procedures that are to be implemented when workers deal with or approach a radiation source. These procedures must be in writing and outline who is in charge of radiation safety and how exposures will be controlled in the workplace. In radiation terms, these procedures are typically referred to as a Radiation Safety Program.
- Advise workers of the potential hazards of ionizing radiation and the measures to mitigate exposures. Depending on the task this may be a 15 minute tailgate meeting or an in-depth review of radiation health hazards consistent with a course that certifies radiation safety officers.
- Monitor the workplace to ensure compliance with the regulations and maintain records for review. Internal exposure monitoring includes contamination surveys, swipe tests, Low Level Radioactive Dusts (LLRD) monitoring and Radon Gas monitoring. external gamma ray exposures as well internal contamination surveys.
- Maintain exposures As Low AS Reasonable Achievable (ALARA). The CNSC, Health Canada’s Canadian NORM Guidelines and OH&S Regulations all require radiation exposures be maintained in compliance with the principle of ALARA.
PRINCIPLE OF ALARA
Any exposure to radioactive materials is considered potentially hazardous. However, we live in a world where radiation forms part of our environment (Natural Background) and as such exposures to NORM cannot be eliminated. Where many hazardous substances can be immediately hazardous to health such as H2S gas exposure, NORM is typically considered a chronic exposure hazard. The effects from NORM may not be noticed for several years and is typically the result of repetitive exposures and not from a single NORM source. The principle of ALARA states it is not simply justifiable to maintain an exposure below a regulatory limit but rather all exposures must be maintain as low as reasonable achievable. The regulatory limit is a value that should not be exceeded. Radiation Safety Programs outline how worker exposures will be maintained within the principle of ALARA during day to day operations. An on-site Radiation Safety Officer should be used during maintenance activities that do not occur on a regular basis to ensure compliance with this principle.
WASTE CONTROL REGULATIONS
Industries that produce our natural resources and operate under provincial jurisdiction typically produce NORM in the form of waste. If an industry produces our natural resource for the radioactive properties within the natural resource, they fall under CNSC control. Waste within Canada is classified as Hazardous, Non-Hazardous or Radioactive. All waste has some degree of radioactivity and as such waste with activity concentration greater than those specified in the Canadian NORM Guidelines are considered radioactive waste. Waste control regulation have only been developed for hazardous and non-hazardous waste and as such generators of NORM waste can obtain an approval for disposal from their provincial regulator or dispose of the waste at a facility already provincially approved for NORM waste.
Service providers to NORM generating companies typically require approval from their respective provincial regulator. Companies wanting to manage NORM waste at their own facilities will need to provide regulators with the appropriate information outlining services provided and methods for worker, public and environmental protection. In many cases NORM waste may also contain other hazardous substances and an approval for the hazardous substance would also be required. These companies should contact their appropriate provincial regulator for approval.