Differences in Provisions between Dangerous Goods Regulations and Radiation Protection Regulations for the Transportation of NORM and TENORM in Germany

The transportation of Naturally Occurring Radioactive Materials (NORM) and Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) is often performed in an area of uncertainty where differing definitions contained in Dangerous Goods and Radiation Protection Regulations lead to different interpretations regarding whether this material has to be classified as radioactive material or not. For example, filter residues from public water purification systems may contain an amount of natural radionuclides exceeding concentration limits according to European dangerous goods regulations (ADR), meaning that they have to be transported within the framework of a “Class 7” road transport for radioactive material. But according to the German Atomic Energy Act, this material is sometimes not classified as radioactive. In this field of law a natural radioactive material only has to be considered as radioactive if the material is explicitly listed in the German Radiation Protection Ordinance as a residuum requiring supervision. In cases where it is likely that the disposal or the recycling of the material leads to an annual effective dose above 1 mSv for a member of the public, the competent authority can also enact special measures for the handling of any material. This situation usually confuses the operators of waste depositories or hazardous waste sites. Generally, they have provisions of acceptance which do not allow the dumping of radioactive material. In addition they do not want trucks labelled as radioactive transport entering their terrain for political reasons. On the other hand, it is not appropriate and generally too expensive to store such a material in a repository for radioactive waste. As a consequence of this, there is often no possibility to dispose of this type of material. Although the transport of such materials can be performed without obstacles, the need to classify it as a radioactive transport causes problems of acceptance. Several approaches to solving this problem are conceivable.