Activity Report of TENORM Task Group

6. Status on the Regulatory Aspects in NORM/TENORM Activities andWastes in Malaysia
6.1

Introduction

In Malaysia, the use of radioactive materials are mostly in the industrial, medical,
research or educational applications. Inevitably the applications will generate radioactive
waste, which require proper control to prevent detrimental effects to life and the environment.
Another source of radioactive waste, which is a legacy of our history as a major tin mining
nation is the Technologically Enhanced Naturally Occurring Radioactive Materials(TENORM). This is due to the fact that the earth’s environment itself contains naturally
occurring radioactive materials (NORM).
Basically there are three sources of radioactive waste in Malaysia:a) Waste generated from usage of radioactive materials from industry, medical, researchand educational purposes;b) TENORM waste resulting from activities related to the enhancement of NORM in theenvironmentc) Spent fuel from research reactor
In Malaysia, the most common activity related to TENORM are industrial activities
related to the mining and the subsequent processing, resulting in the increase of the naturally
occurring radioactive materials. The issues related to NORM and TENORM attracted a lot of
public interest and the mass media in the late 1970s. Since Malaysia was a major tin producer
and currently active in oil and gas industry, there is growing concern related to the TENORM
wastes issues.

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Activity Report of TENORM Task Group

Table 1 Radioactive Waste Management Policy
Activities related to TENORM
Types of Waste

Solid Waste

Liquid Waste

PolicyStored by the user.

Licensingrequirement

Waste storing facility which must Waste storage tank
be comply with Atomic Energy
Licensing Board criteria.

Licenseconditions

The waste shall be stored in the Can be discharge to the environment
waste storing facility.
if the radioactivity for liquid below
the discharge limit, for example for226
Ra to thedischarge theenviron-ment is 1 Bq/l.
For disposal purpose, the licensee
are required to carry out a risk
assessment to any proposed
dis-posal site as to demonstratethat the discharge will not exceed
the limit for the member of the
public (1 mSv/y)6.2

Stored by the user

TENORM Industries in Malaysia

In Malaysia, the wastes associated with TENORM are generated mostly in the tin
mining and smelting, processing of minerals and oil and gas industry.
6.2.1

Mineral Processing and Mining Industry

Certain minerals of tin-mining byproduct, such as amang (heavy mineral sand),monazite, ilmenite, zircon or xenotime contain natural radioactive elements such as uranium,
thorium and radium co-exist with the tin ore or cassiterite in the ground. Down-stream
processing of ilmenite, zircon and monazite produces end products such as titanium oxide (aspigment in paint, paper plastics, cosmetics, etc), zirconium (used in ceramics, refractory,
catalysts, or fuel cladding and structural materials in reactors) and rare earth elements(electronics, illumination, superconductors, ceramics, etc).
In the process of the mineral extraction process, these radioactive elements become
more concentrated and need proper management. This type of waste derived from this tin
mining and mineral processing industry has a low specific activity but long-lived alphaemitters.

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Activity Report of TENORM Task Group

6.2.2

Oil and Gas Industry

Another important source of TENORM is from the oil and gas industry – in this casemostly from the oil sludge and scales from oil well production and oil refineries. The mostdominant radionuclide in oil sludge are 226Ra and 226Ra, whereas U and Th contribution isvery small compared to other minerals such as ilmenite, zircon, etc. The total specific activity
in oil sludge/scale ranged from 200 – 13, 000 Bq/kg.
In the above processes, TENORM may remain in solution, precipitate, sludge, scales
particulates or residues within the production process itself or the waste streams. The waste
associated with TENORM account for a significant number of the radioactive waste
management problem in Malaysia. TENORM wastes characteristics are the presence oflong-lived alpha radionuclides and present in very large volume compare to other types ofradioactive waste.
All these materials as mentioned above in paragraph (1) and (2) are not intended to be
recovered but since the radionuclide co-exists with other minerals, the radioactivity
enhancement is rather unintentional. This is the case of the oil and gas, tin mining and mineralprocessing industries. Since Malaysia was a major tin producer in the world and current
activities in oil production, the amount of waste generated is quite substantial.
6.3

Law and Regulations

The Atomic Energy Licensing Act 1984 (Act. 304)1) provides the regulations andcontrol of atomic energy and for all activities related to it. The main objective of the Act isto ensure safety of radiation workers, members of the public and the environment fromradiation hazards as a result of activities related to atomic energy. The regulatory body is
the Atomic Energy Licensing Board (AELB).
The Act 304 prescribed by provision of Section 12(1) b quotes:“Without prejudice to the requirements of any other law, no person shall dispose of any
radioactive material, nuclear material, prescribed substance or irradiating apparatus, unless heis the holder of a valid license issued under section 16(5) by the Board”.
With regard to discharge or release of radioactive material or waste including
TENORM into the environment, Section 51 of the Radiation Protection (Basic Safety
Standards) Regulations 1988 2) authorized the AELB in specifying the release limit, taking
into account the following considerations:Pre-operational environmental monitoring;
Determination of critical pathway;
Selection of critical group of population;
Assessment of radiation exposure to members of the public.
The licensee has the obligation in carrying out effluent monitoring and evenenvironmental monitoring if deemed necessary.

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Activity Report of TENORM Task Group

6.4

Management of TENORM

Under the present law, management or disposal of radioactive waste is specificallydealt with under Sections 26-31 of the Atomic Energy Licensing Act 1984 (or Act 304) 3),
which empower Atomic Energy Licensing Board (AELB) to ensure that the user obtainappropriate license for activities dealing (accumulate, transport or dispose) with radioactive
waste and to take appropriate actions to rectify situation which deemed unsafe.
The AELB will consider the issuance of the license after scrutinizing applicant’s
capability. In the case of TENORM, a person intending to dispose of the waste should apply
for a license under Class G, which is:a) To dispose of radioactive materials, prescribed substances or their wastes;b) To store radioactive materials, nuclear materials, prescribed substances or their wastes
prior to their disposal; orc) To decommission a milling installation, nuclear installation, waste treatment facility,
irradiating apparatus or sealed source apparatus
For any disposal activity of NORM/TENORM, the licensee is required to submit aRadiological Impact Assessment (RIA) to the Atomic Energy Licensing Board, demonstratingthat the dose limits to the workers and members of the public do not exceed those stipulated
in the Atomic Energy Licensing Board 304 and the Regulations.
On the other hand, with regard to the waste generated from the oil and gas industry,
the licensee is required to fulfill the requirement imposed by the authority.
A document was issued by the AELB in early 1996, LEM/TEK/30 SEM 1, regarding
guidelines on handling and radiological monitoring of TENORM from oil and gas industry.
This document was superceded by a revised edition, LEM/TEK/30 SEM 2 4), in September
1996. Among others, it addresses the requirement and format for radiological impact
assessment. For the management of oil sludge containing TENORM. Under the transport
regulations, NORM/TENORM is addressed under low specific activity materials (LSA) or
surface contaminated object (SCO).
6.5

Exclusion, Exemption and Clearance on NORM/TENORM Waste

Related to the NORM/TENORM waste, under the Atomic Energy Licensing Act, 1984
(Act 304), there is no provision specifically stipulated under the act that provide exclusion of
the radioactive waste especially related to NORM/TENORM waste in Malaysia but the Act
did provide the provision for the exclusion for the activity of prospecting or mining for any
radioactive materials, nuclear materials or prescribed substance. These activities shall begoverned by the relevant laws relating to mining.

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Activity Report of TENORM Task Group

Nevertheless, any person who, in carrying out either of the activities of prospecting or
mining or both, encounters, discovers or comes into possession of any radioactive materials,
nuclear materials or prescribed substance shall immediately report such fact to AELB in
writing and shall comply with all directions that the AELB may give in the matter, being
directions not inconsistent with the relevant laws related to mining.
Apart from the exclusion for activity of prospecting and mining of such radioactive
materials and nuclear materials, AELB has imposed the exclusion that do not need to be
subject to regulatory control that is by adopting the criteria recommended by the IAEA as
stipulated in the IAEA Safety Series No. 26 “Radiation Protection of workers in the Mining
and Milling of radioactive Ores” 5), which shall not exceed 0.05 weight% of the elements
uranium or thorium as a guideline to be used to exclude the radioactive materials and wastefrom NORM/TENORM activities from the regulatory control. This guideline was established
for our internal technical document known as KOD/EMT/37 Corrigendum 1 “Methods ofcalculation for Uranium and Thorium in the mineral sample” 6).
Due to the economic reasons and the price of tin and it’s by-product such as amang
and other mineral processing in the market is not viable and profitable so much so notsignificant in the business and trade industries at that particular time, the government has
decided to made-up the policy to exempt some of this materials from the regulatory control
under the Atomic Energy Licensing Atomic Energy Licensing Act, 1984.
There are two orders that has been gazette to exempt this NORM/TENORM
radioactive mineral that is:(a)

Atomic Energy Licensing Atomic Energy Licensing Act, 1984, “Atomic Energy
Licensing (Small Amang Plant) (Exemption) Order 1994 7); and(b)

Atomic Energy Licensing Atomic Energy Licensing Act, 1984, “Atomic Energy
Licensing (Ceramic Factory) Order, 1998”8), which give the exemption to any ceramic
manufacturing factory which uses zirconium silicate that contains radioactive material
as whitening or glazing material in small amount in the manufacturing process. Every
ceramic factory is exempt from the Atomic Energy Licensing Atomic Energy
Licensing Act, 1984 subject that the activity concentration of the radioactive materials
contained in zirconium silicate does not exceed the level as stated in Table 2.

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Activity Report of TENORM Task Group

Table 2

Exemption Level – Activity Concentration ofRadioactive Material in Zirconium Silicate

NuclideActivity Concentration(Bq/g)

214

Bi

10

226

Ra

10

228

Ra

10

228

Th

1

232

Th

1

238

U

10

On the other hand, with regards to the clearance levels, AELB had imposed several
requirements to the industries to be fulfilled such as imposing this clearance levels to one of
the mineral processing company (which extract rare earth from the monazite and left thousandof cubic meters of radioactive waste of thorium waste) called Asian Rare Earth Private
Limited, which in the process of decommissioning and decontamination their plant.
Only the contaminated equipment and building materials that did not exceed the levelsof 0.5 µSv/hr for fixed contamination and 0.04 Bq/cm2 for non-fixed contamination will be
exempted from the regulatory control before these equipments and materials can be disposedto the approved disposal site.
Furthermore, the acceptable radioactivity levels (clean-up criteria) for soil andpavement shall be disposed to the site is:(a)

From ground surface to a depth of 1 m.:
0.33 Bq/g for 238U (not including background)1.00 Bq/g for 232Th (not including background)<1.00 = (238U/0.33) + (232Th/1.00)(b)

From a depth of 1 m. to bedrock:
0.9 Bq/g for U-238 (not including background)1.00 Bq/g for Th-232 (not including background)<1.00 = (U-238/0.33) + (Th-232/1.00)(c)Combined Th-232 and U-238:<1.00 = (U-238/0.33) + (Th-232/1.00)- 42 -

Activity Report of TENORM Task Group

Apart from that, the clearance limit for the discharge of the effluent from the plant forthe mineral processing industry is based on the Ra-226 that is 1 Bq/l.
Every plant that operate and deal with the NORM/TENORM activities shall ensurethat the discharge limit of 1 Bq/l for Ra-226 not to be exceeded before discharge any effluent
to the environment. But in the case of more than one industries related to thisNORM/TENORM activity are operated in the same industrial park or are located just besideeach other, the AELB has imposed the constraint for the discharge limit that shall be comeinto force at least 1/3 of the normal discharge limit (i.e. 0.33 Bq/l) before any effluent can bedischarge to the environment.
6.6

Conclusions

The NORM/TENORM waste has been generated from these tin mining or oil
exploration and extraction industries over the decades, which have and playing a critical rolein spurring the economic growth of the country, are in operation, radioactive materials will
inevitably be extracted from the ground as part and parcel of tin ore and crude oil extracted.
By leaving bulk of quantities of TENORM’s waste unattended around the country is very
disturbing to the national conscience and in long-run, it will give a perception that a
Government is irresponsible for not finding a lasting solution to this problems. What is evenmore regrettable is that this problem is largely yesterday’s problem since most of the
NORM/TENORM waste extracted from the ground and often left unattended around thecountry have been accumulate over decades of mining activities.
With regards to this problems, at this point, although the government of Malaysia did
not provide any provision in the law for the exclusion of TENORM waste specifically, but the
government did imposed the criteria for exclusion of this waste by adopting the guideline
limit established by the IAEA Safety Series 26.
This is very vital to the authority to overcome the problems in managing some of thewaste related to the TENORM industries. As least, we can avoid any doubt or ambiguous to
exclude some of this waste from the regulatory control.
Furthermore, due to economic reason and the price of tin and its by-product is notviable and profitable so much so not significant in the business and trade industries, several
practices have been exempted from the regulatory control under the Atomic Energy Licensing
Act, 1984.
Apart from that, at present, one of our licensee that dealt with mineral processing
industry has no longer operated and in the process of decommissioning and decontaminationof their plant. They had decided to decommission and disposed their waste at the approved- 43 -

Activity Report of TENORM Task Group

disposal site. Some of the waste has started to be transported to the disposal site, which has
been approved by the authority in conjunction with the Perak State Government.
Several clearance levels have been set up by the authority especially for the fixed andnon-fixed contamination for equipment and building materials. Clean-up criteria ofcontaminated soil from the plant and the discharge limit for the liquid effluent from the plant
to be released to the environment.
At present, Malaysia does not have any policy yet on the management of radioactive
waste. We do hope and belief that in the near future, the government of Malaysia will comeout with a national policy for managing the radioactive waste in TENORM industries as toprotect the human health and the environment from the potential hazard and risk generated bythese waste.

References
1.

Atomic Energy Licensing Board. Atomic Energy Licensing Act, 1984 (Act 304)
(1984).

2.

Atomic Energy Licensing Board. Atomic Energy Licensing Act, 1984 (Act 304).
Radiation Protection (Basic Safety Standards) Regulation 1988 (1988).

3.

Atomic Energy Licensing Board. Atomic Energy Licensing Act, 1984 (Act 304).
Radiation Protection (Licensing) Regulation 1986 (1986).

4.

LEM/TEK/30 SEM 2, “Guidelines on handling and radiological monitoring of
TENORM from oil and gas industry” Atomic Energy Licensing Board, Kuala Lumpur(1996).
INTERNATIONAL ATOMIC ENERGY AGENCY, “Radiation Protection of workers
in the Mining and Milling of radioactive Ores”, Safety Series No. 26, IAEA, Vienna(1983)

5.

6.

KOD/EMT/37 Corrigendum 1 “Methods of calculation for Uranium and Thorium inthe mineral sample”. Atomic Energy Licensing Board, Kuala Lumpur (1995).

7.

Atomic Energy Licensing Board. Atomic Energy Licensing Act, 1984. Atomic Energy
Licensing (Small Amang Plant) (Exemption) Order, 1994 (1994).

8.

Atomic Energy Licensing Board. Atomic Energy Licensing Act, 1984. Atomic Energy
Licensing (Ceramic Factory) (Exemption) Order, 1998 (1998).

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Activity Report of TENORM Task Group

Sources of Informations
0.

Daud Mohamad, Mohd Nur Mohd Yunus, Syed Malik Syed Zain, Nik Marzuki,
November 2001. “Current practices in the management of radioactive waste”. Paper
presented at the Waste Management 2001, Asia Solid & Hazardous Waste
Management. Trade Expo and Conference, Sunway Pyramid Convention Centre,
Kuala Lumpur (2001).

1.

Hamrah M.A., “National Guideline on TENORM Disposal”, Seminar on Radiological
Safety Related to NORM/TENORM, Kuala Lumpur (1999).

2.

Mohd Yusof, M.A. and Khairuddin, K., “MINT’s experience in carrying out
Radiological Impact Assessment on NORM/TENORM”, Seminar on Radiological
Safety Related to NORM/TENORM, Kuala Lumpur (1999).

3.

Atomic Energy Licensing Board. New Atomic Energy Licensing Act, 1984 (Act 304).
Radiation Protection (Basic Safety Standards) Regulation 200. [going to be gazettesoon and will supersede the existing Basic Safety Standards Regulations 1988 –
adopted and adapt from the IAEA Basic Safety Standards Safety Series 115]

4.

INTERNATIONAL ATOMIC ENERGY AGENCY, “The Principles of Radioactive
Waste Management”, Safety Series No. 111-F, IAEA, Vienna (1995)- 45 -