NORM industries are regulated in Spain under Title VII of Royal Decree 783/2001 and CSN
Safety Instruction IS-33 (issued 2011).Following IS-33, all industries included on a positive list have to register with the regional industry authority and to conduct a study on their radiological impact to workers and public.
If the results of the study show that the dose criteria (1 mSv/y2 for workers and 0.3 mSv/y for public) are exceeded, the facility has to notify it, and it will remain subject to regulatory control.
The level of control imposed varies in terms of risk and plausibility of protection measures, with additional requirements applying if doses to workers are liable to exceed 6 mSv/y.
Complementary to this legislation, Ministerial Order IET/1946/2013 regulates the control of NORM residues. Clearance levels in Radiation Protection 122 Part 2 are used as a screening tool in order to determine which residues need further consideration from the radiation
protection standpoint. For residues exceeding those levels, a case-by-case analysis needs to be performed. Conventional disposal routes are approved provided that requirements in IS-33 (including the application of the optimisation principle) are observed and that specified dose
limits are met. These are 6 mSv/y for workers, and 1 mSv/y for public. NORM residues above these limits need to be managed as radioactive waste.
While the existing regulatory framework provides an adequate basis for managing most situations in practice, a large amount of work is needed to achieve a system that works efficiently for both regulator and industries. In particular, CSN is making efforts in the following areas:
- Fostering cooperation among regulators in order to identify synergies and simplify administrative procedures
- Engaging all affected industries
- Developing industry-specific regulation, including mechanisms for exemption in terms of activity concentration and/or volume of material processed
- Consulting and engaging with stakeholders relevant to NORM residues management
- Promoting continuing education and training of the entities authorised by CSN to conduct the radiological studies