NORM Container Labels and the Gamma Spectrometry Sample

What goes on the label, and what decides where the drum goes

Two clauses of article 8 of the rules attached to Decision 45 of 2013 answer two different questions. Clause 3 says what is stuck on the container: the radiation warning signs, and a label carrying clear information about the material. Clause 5 says what decides where the container goes: a sample from every container, measured by a gamma spectrometry analyser, read against the levels in annex 1.

A term first. Gamma spectrometry is a measurement that separates the gamma rays coming out of a sample by their energy, and the energies name the radionuclides present. So the instrument in clause 5 is not a dose meter. It tells you which nuclides are there and at what activity, which is what the annex 1 rows built on named isotopes are read against. The instrument has its limits: alpha emitters are not determined by gamma spectrometry, and some nuclides show only a weak line that needs a particular geometry and calibration. So the instrument alone is not an answer for every row of the annex.

The two clauses together are the paper trail of a drum. One is what a person reads from outside it. The other is what a laboratory reads from inside it. NORM is naturally occurring radioactive material: material in which the concentration of radionuclides has risen because of human activity. Hard scale is a solid crust depositing on the inner surfaces of pipes and equipment, and sludge is a sticky mixture gathering in tanks and separator vessels; both are defined in article 1. Scrap is metal and equipment taken out of service, which article 1 does not define, so that description is ours.

The label, item by item

Clause 3 asks for two things to be stuck on the container: the radiation warning signs, and labels carrying clear information about the radioactive material. We counted the items of information named in the clause on the text we transcribed. They are seven.

What the two clauses leave open

Clause 3 does not fix the language of the label, its size, its material or its place on the container. It asks for clear information and names the items, and it stops there. An operator who prints a label in one language only has made a choice, and we do not call that choice a requirement.

Clause 5 does not name who performs the analysis, nor how often the sampling is repeated, nor the number or the weight of the samples. It names the instrument by its kind and the reference by its place in the decision. We record the silences and we ask about them.

Two provisions, one annex, two words for the outcome

Annex 1 is referred to from two places in this decision. Article 5 refers to it to say when waste is exempt from the application of the provisions of the regulations in force, and when it is not. Clause 5 of article 8 refers to it to decide where a drum goes. The reference is the same and the words of the outcome are different, and that difference is worth keeping in a record.

Article 5 says that where the level is higher than the annex levels the waste is considered radioactive contaminants, and that it must then be collected, transported, stored and disposed of under these rules. Clause 5 of article 8 says that where the sample is not within the annex levels the container is moved to the stores. One is a legal characterisation and the other is a movement instruction, and we report each in its own words.

Filling a label so that it survives an audit

The label is where an inspector starts, so the four habits below matter more than the printing. Then one worked case shows a calculation that is often made and that the clause does not ask for.

Frequently asked questions

Technical note

A label is a claim and an analysis is its evidence. The fourth item on the label is a figure of the kind the analyser produces, and the decision does not make one follow the other. We recommend, as our own advice, that a label be filled after the analysis, since a label filled before it is a claim with no evidence behind it.

Keep a level and a total in two different fields, with their units written out. The annex speaks in levels per unit of weight, and a total in a drum answers a different question.

Where DITEC stands, and what this text is

ALDuha Institute for Training and Environmental Consulting (DITEC) works in training and consulting only. Designing a label and a container register, and training the people who fill them, is training and consulting work. Gamma spectrometry on a sample is laboratory work. The Institute does not run a laboratory analysis service, does not calibrate instruments and does not test equipment, and field surveys are carried out through specialist partners. Licensed training is what the Institute offers, and nothing in a training programme or in this explanation is an undertaking that a licence will be issued or that it will be issued within any period.

A note on the authority: the text names the Ministry of Environment. Today that competence sits with the Ministry of Environment and Climate Change, Radiation Protection Department. The questions about who performs the analysis and how often a container is re-sampled are put to that department. The successor reading is ours and not the wording of the decision, and the original wording is kept inside the quotations in the Arabic text of this article.

This article is an introductory explanation of a published regulatory text and is not a legal opinion.