Relationship Between Terrestrial Background and Remedial Criteria for Naturally Occurring Radioactive Material in the United States
Authors: Brown Steven H. 
Published: January 2021

Abstract
In the United States (US), Federal and State agencies have established radiological public exposure limits and remedial action (“clean up”) criteria for naturally occurring radionuclides (NORM—primarily for uranium and thorium series radionuclides). Often, these criteria are intended to control human exposure to what is referred to in the US as technologically enhanced naturally occurring radioactive material (TENORM). This can be any naturally occurring radioactive material for which the potential for human exposure has been enhanced due to anthropogenic (human activities), e.g., removal from its “place in nature,” and/or processed in some way resulting in concentration. In some cases, the values of these regulatory criteria can be similar to or even less than those levels of exposure and those concentrations of NORM that exists in nature independent of any previous human activity. The potential variability of NORM radionuclides in the soil and rocks can be significant, even over relatively short distances or depths due to factors such as geology, hydrology, and geochemistry. Given this, it is important to recognize that defining “the radiation background” for purposes of establishing and/or comparing remedial action criteria and/or exposure limits requires recognition of the specificity at the location(s) of interest, not in other geological and/or mineralogical regimes several miles away. The purpose of this paper is to demonstrate this variability for comparison to exposure levels and concentrations being defined in the US as levels above which require regulatory control and / or above which are being defined as an “unacceptable risk.” The primary background exposure component of specific interest here is the annual dose contribution from terrestrial radiation exposure, i.e., from uranium and thorium series radionuclides in the ground, excluding radon inhalation. The exposure sources being controlled by some US regulatory limits are primarily associated with the primordial radionuclides in soil. The average annual terrestrial component of background can vary by upwards of a few tenths of a mSv across the US that can be several times higher than the applicable exposure limits. This can result in “unacceptable risk” or “remedial action” concentration criteria statistically equivalent to or less than the background concentrations of these same primordial nuclides. The statistical and analytical uncertainties of distinguishing naturally occurring radionuclides (i.e., NORM) from those resulting from anthropogenic (human caused) activities (i.e., TENORM) can be quite challenging and in some cases may be technically impossible. Consideration must be given to the relationship of the amount of actual total risk avoidance achieved if any, relative to the traditional health and safety risks of construction and associated construction and waste management costs for remedial activities, so that a practical and scientifically based approach for development of these criteria can be achieved.