The NORM Transport Factor and Warning Labels in Qatar

The short answer: one number chooses the label

Each drum of NORM waste gets a number before it travels, and that number is what chooses the warning label stuck on it, on a scheme we do not find in what we have read of the decision, as this page goes on to explain. NORM waste is waste of naturally occurring radioactive material, and its material is described in the rules as material in which the concentration of radionuclides is increased as a result of human activity. Clause 7 of article 9 of the rules attached to Decision 45 of 2013 says how the number is worked out: measure the dose equivalent in microsieverts per hour at one metre from the drum surface, and divide by ten. The microsievert is a unit of dose, so microsieverts per hour is a dose rate.

The clause also asks for a second measurement, at the drum surface directly, and it names the purpose of the pair: choosing the suitable warning label that is stuck on the drum. So one drum, two readings, and a label chosen from them.

A note on the name of this number, because the decision carries two Arabic names for it. Clause 7's term is the one we render as the transport factor. The definitions article defines a second term, which we render as the transport guide, in substantially the same way: a number that provides control over radiation exposure, with a value in the range 0 to 10, showing the maximum dose equivalent rate at one metre from the package surface. The second name appears in clause 11 as well. Clause 7 gives a method of calculation rather than a description. We record that the two Arabic names differ and treat them as one quantity, and that treatment is our reading.

This page is for whoever labels the drums and writes the paper that travels with them: a radiation protection officer, a warehouse keeper, or the shipping clerk who fills the statement.

The two readings, and what each one is for

The first reading is taken at one metre from the drum surface. It is a dose equivalent rate, in microsieverts per hour. Dividing it by ten gives the factor. Nothing else is divided, and the division belongs to this reading alone.

The second reading is taken at the surface directly, with no division. On a real drum it is the higher of the two, because a dose rate falls as you move away from the source. If your record shows a surface reading lower than the one metre reading on the same face, the pair is not accepted as it stands: a dose rate does not rise with distance from the source. Re-measure, look for a neighbouring source adding to the one metre reading, and make sure you are not comparing a contact reading on one face with the one metre maximum on another. No record is signed before the pair is explained.

The clause names the purpose of both readings as choosing the suitable label. It does not give a table matching ranges of the factor to particular labels, and we do not supply one from elsewhere and present it as the decision's. The clause is silent on this, and it is taken up in the questions below.

Where the number is displayed is in the definitions article: the transport guide is placed on the warning sign. So the number is not kept in a file only. It is read off the load by anyone who approaches it.

The clause sets the determination for every drum, one by one. So a shipment of eight drums carries eight determinations, not one average for the lot. A single figure written once for a mixed load hides the drum that matters.

What travels with the load besides the label

Clause 11 is the paperwork clause, and it begins with the vessel. It asks that the vessel be provided with the warning signs for radioactive materials, the transport guide, and the other labels particular to transport. We note that the clause names the vessel, which the definitions article defines as a means of sea transport or a ship for inland waterways, while the vehicle is a separate defined word covering the means of land transport. We do not read one of them in place of the other.

Then it asks for a statement of the transported materials, and the statement has five items. A description of the natural radioactive materials, with contaminated equipment, solid scale deposits, sludge, residues and others named inside the description. The size or quantity of the transported radioactive materials. The method of transport. The destination. And the facility from which the radioactive waste was collected.

The description item ends with an open phrase, and others. So the four named kinds are examples, not a closed list, and a material that is none of the four still needs describing. We keep the phrase rather than drop it and turn the item into a menu of four.

What the clause does not say is who keeps the statement after the trip, for how long, and in which language. In what we have read of this decision there is no answer to that, and we say so rather than invent a retention period.

One drum, two readings, one number

The table separates the two measurements so that the division by ten stays attached to the reading it belongs to. That single confusion is the most common error we see in survey sheets.

A drum that passes one line and fails another

A drum of scale is ready for dispatch. The dose rate meter reads 40 microsieverts per hour in contact with the surface, and 12 microsieverts per hour at one metre. Contact is the higher reading, as it must be. A contact reading at this level carries protection duties that the surface contamination limits page sets out: the shortest time, a personal dosimeter worn, and an extremity dosimeter on the hand.

The factor comes from the one metre reading: 12 divided by 10, which is 1.2. That value sits inside the range the definitions article gives for the number, between 0 and 10, and it is the number that goes on the warning sign.

Then take the surface reading to the other article. Clause 1 asks that the radiation level at the package surface not exceed 5 microsieverts per hour. A package, in the rules, is the radioactive material together with the packaging for the purpose of preparation for transport. We read the drum surface of clause 7 and the package surface of clause 1 as one thing in practice, and that reading is ours, not the decision's. On that reading the surface here is at 40 microsieverts per hour. So this drum has a sound factor and a label chosen on the carrier's and the regulator's scheme, and still does not meet the requirement of clause 1. It is not ready to travel. Clause 1 says nothing about what is done with a package that fails, so holding it until it is dealt with is our measure and not a ruling in the clause.

Restricting approach is the next step, and this drum's own two readings are the measure: 40 microsieverts per hour in contact and 12 microsieverts per hour at one metre. Dose falls steeply with distance, and the dose a person takes is the dose rate where they stand multiplied by the time they stand there. So keep it away from places where people stand for long, do any work near it at the shortest time and the greatest distance the work allows, and enter the location in the monitoring record. The figure that fixes how far the restriction reaches belongs to the operator's radiation protection programme and its licence conditions, not to this page. The figures of article 10 govern stores and we do not carry them over to this door.

This is the point of working the case through. A label chosen correctly from a correct factor says nothing about whether the surface level is within the figure of clause 1. The two questions are asked of the same drum and answered from different clauses, and a form that only has a box for the factor will pass this drum.

A word on rounding, since 1.2 came out of a division. The clause does not say how to round the result, how often to repeat the determination, or what to do if a value comes out above the upper end of the range. We leave those as open points rather than pick a convention and present it as the decision's.

As for who does this, the survey, the arithmetic, the label and the statement entry fall to the operator's people and its contractors. So the person taking the readings writes both of them, the distance of each, the instrument used and the date. We train on that survey sheet and are consulted about it, and we do not take the readings.

Label and statement questions we are asked

Notes for the person holding the dose rate meter

Fix the geometry before the number. One metre from the drum surface is not one metre from the drum centre, and on a standard drum the difference between the two is large enough to move the factor. Measure from the surface, and write down which surface and at what height.

Find the maximum, do not take the first reading. The definitions article describes the number as showing the maximum value of the dose equivalent rate at one metre. A single point on one side of the drum is not the maximum. Walk the drum at that distance and keep the highest figure.

Background matters at these levels. A one metre reading of a few microsieverts per hour sits close to the ambient level in some yards, and a loaded drum nearby adds to it. Take a background reading away from the load and record it beside the result. If neighbouring drums add to the reading, take the one metre maximum on the side away from them, or measure in a bay cleared beforehand. Do not move other drums for the sake of a reading: the handling itself is dose and a risk of splitting.

Label the drum, not the pallet. The clause has the label stuck on the drum, and the factor set for each drum. A shrink-wrapped pallet with one label on the outside hides the identity of each drum inside it, and whoever opens it next has no number for what is in their hands.

Write the statement from the drums, not from memory of the job. Its five items include the facility the waste was collected from and the quantity, and those are answered by the yard records, not by the driver at the gate.

So the geometry, the maximum and the label on the right object are the whole of this page. The arithmetic itself is one division, and it is the easiest part to get right.

How DITEC helps, and where its work stops

On this page the question we are asked is almost always how to turn the two readings into a label. We train on taking the one metre maximum and the surface reading as two separate records, and we are consulted on the survey sheet that keeps them apart.

ALDuha Institute for Training and Environmental Consulting (DITEC) works in training and consulting. The Institute does not run a laboratory analysis service, does not calibrate instruments, and does not test equipment. Field survey work is arranged through specialist partners.

Our training is licensed. Nothing here is an undertaking that a licence will be issued, and nothing here promises how long any application takes. The decision rests with the Ministry of Environment and Climate Change, Radiation Protection Department.

Reference: DITEC Experts and the Radiation Protection team. This page is an introductory explanation of a published decision and is not a legal opinion.