solidsurfacealliance.org Blog

We received an email recently from the federal Argonne Lab. A lady there is an expert in NORM, Normally Occurring Radioactive Material. She looked over our info and said some of her colleagues might be interested in researching the health risk aspects of granite countertops and Radiation. She said she has to procure the funding, but had several sources she used frequently. I am assuming the DOE or NASA, perhaps the NRC.

Here is the entire email.

Dear Ms. Weigel,

My apologies for being so slow in responding to you. I have been out of the office a great deal and have fallen behind on correspondence. Your questions and data about granite countertops as potential sources of radiation exposure took me by surprise initially, but makes a lot of sense. You have certainly amassed a lot of data.

Regarding your specific questions about regulations: A number of states regulate NORM through various types of legislation. A number of years ago, we developed a website for tracking NORM regulations: http://norm.iogcc.state.ok.us/index.cfm. It’s called the NORM Technology Connection website because it also provides access to information about companies providing NORM management and disposal services. From the “State Regulations and Guidelines” link, you can get information about how each state regulates NORM, along with links to agency websites and regulations. In Oklahoma , for example, there are no specific regulations for NORM and, therefore, NORM would be subject to the State’s general radiation control regulations. In many states, the general radiation control regulations are focused heavily of the medical industry (X-Ray machine operators, etc.) or on radiation waste site management (in states with big radiation site clean-ups). In such cases, there usually are surface contamination level limits that would apply to NORM as well as some general disposal requirements. It was this general lack of specificity relevant to NORM that caused many of the oil and gas producing states to write NORM regulations specific to the petroleum industry (Oklahoma drafted some at one time but never promulgated them). In addition, the Conference of Radiation Control Program Directors (CRCPD), a consortium of state radiation regulatory agencies, developed a template set of NORM regulations that could be adopted by each state. These regulations are referred to as Part N (http://www.crcpd.org/SSRCRs/N_04-04-print.pdf) and they have been adopted with some modifications by several states.

To complicate matters further, the CRCPD and others have adopted the terminology Technologically Enhanced NORM or TENORM to refer to NORM-bearing materials in which some human activity has increased concentrations [as in oil and gas operations]. They don’t intend to regulate the “…natural radioactivity of rocks…” Others argue that any material in which human activity causes increased potential for human exposure should be regulated. As such, it is unclear whether granite countertops would be regulated by different states’ regulations. You need to examine the definitions for “regulated material” to determine whether your operations and materials are subject to license requirements and other elements of the regulations.

If your operations are exclusively in Oklahoma , you might want to revisit the issue with your regulators (the DEQ Radiation Management Section – see link on the NORM Technology Connection); you might also want to get their decisions or directions to you in writing. If you work in areas outside of Oklahoma , you probably should become conversant on how each of those states regulation NORM.

From an occupational health risk perspective, you should look at the Occupational Safety and Health Administration (OSHA) regulations on Ionizing Radiation: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10098. If this is an area that is too far beyond your realm of experience, you could consider hiring a consultant that specializes in health physics. The NORM Technology Connection database of service providers is one place to start to find such a consultant (from the home page, click on the link “Search for Services.” Then, select your search criteria (e.g., Radiation Safety Training, Health and Safety Plans).

I am not aware of any regulations in the U.S. specific to radioactivity in building materials – although there certainly could be some or individual states could consider their rules to cover building materials. The National Council on Radiation Protection & Measurements (NCRP) addresses this issue in its Report 50, “Radiation Exposure of the U.S. Population from Consumer Products and Miscellaneous Sources,” (http://www.ncrponline.org/Publications/95press.html). I am not familiar with this area of research so cannot do more than point you in this direction.

My husband, a geologist, found the following article on the Internet that might interest you if you have not already seen it: http://wjllope.rice.edu/SaxumSubluceo/LLOPE_StoneRadRn.pdf.

In general terms, the two U.S. agencies that should be interested in potential health risks associated with occupational or consumer radiation exposure from granite countertops include the EPA and OSHA. Because NORM falls to state-level regulation, however, it is possible the EPA will defer entirely to those agencies. Nonetheless, I have a contact at the EPA who might have some insights into the agency’s perspective on this issue and will try to call him in the next few days. If I learn anything useful, I will share it with you. It also seems the CRCPD should take an interest in this issue given its mission is to inform state-level regulatory development. I don’t have a contact there but might be able to track one down.

Regarding how Argonne National Laboratory might be able to support research into this issue, I am certain a number of our staff would be interested, particularly with respect to potential health risk issues. Unfortunately, we would need to identify a specific funding source for such research as we currently do not have funds to work in this area. I will pursue funding opportunities through a number of contacts – if we could get funding, we would be quite interested.

Again, my apologies for being slow in responding. That doesn’t reflect a lack of interest on my part. I hope some of the information above is of use to you – please let me know if you have questions. I will continue to look into this issue as time allows.

Best regards,

Karen

Karen P. Smith

Argonne National Laboratory

200 Union Blvd., Ste. 530

Lakewood, CO 80228