Issues in Applying Transport Exemption Levels to NORM

The International Atomic Energy Agency (IAEA) and U.S. Department of Transportation (DOT) regulations for the transport of radioactive material do not apply to “natural material and ores containing naturally occurring radionuclides” whose activity concentrations do not exceed 10 times the otherwise applicable exempt material activity concentration limits. Several issues have been noted on how to apply this exemption to various materials. Some have interpreted this to apply to all material with naturally occurring radionuclides; applying it to materials such as water from fracking operations, drilling mud, and water treatment media. However, the transport regulations do not include the terms Naturally Occurring Radioactive Material (NORM) or Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) so it is not a matter of simply applying the increased exemption levels to anything that contains natural occurring radionuclides. This paper will provide a background on the basis for the IAEA and DOT regulations on the increased exemption levels for natural material and ores containing naturally occurring radionuclides. A summary of interpretations of the applicability of the exemptions to various materials will be provided.