RE: Ignored consumer goods with Ra-226.

["Tsurikov, Nick" <nick.tsurikov@iluka.com>]

Dear Jetty,

It looks that you are right, but I will need at least a month to read the
report.

The question you posted was also asked in my 'TENORM Legislation' report to
the TENR Conference in Rio last September:
"...The third example of 'legislative inconsistency' is the reluctance of
appropriate authorities to apply the same limits for the industry and for
the general public... another case is an application of relevant regulations
for consumer products."  Following this, a detailed example is given,
describing how one particular material may be classified as 'radioactive'
and 'non-radioactive' by simply moving between different jurisdictions.  The
full text of the report is available on the web site http://eneabba.net/
<http://eneabba.net/>  and 'matters of interest' are discussed on pages
36-37.

All these 'regulatory' matters and an artificial difference
"natural-nuclear" are leading to the conclusion that 'nuclear' radiation is
very dangerous, but the 'natural' one (including consumer products) is kinda
not that bad, and can be generally ignored.  This puts unfounded pressure on
the 'nuclear' industry and drives the statutory limits for it lower and
lower.  But these limits, in one way or another, are 'returning back' to
many industries where traces of natural radioisotopes are present as an
unwanted impurity.  This is a labyrinth with no exit and, sooner or later,
it has to be realised that one cannot possibly regulate each and every human
activity from the 'radiation protection' point of view.  
A line has to be drawn at a level where not only radiological but also
economic factors are taken into account.  Should we stop processing many
minerals which are essential for our economy and shut down plants, which are
providing employment to thousands of people?  The processing then will be
carried out in countries where 'radiation' standards are not so stringent.
But what will happen to many people who would lose their jobs, just because
there is a HYPOTHETICAL risk of exposure to low-level radiation?	
...just my opinion.

>>>>>>>>>>>>>>>
If there is no reference for radium in NUREG-1717, it is likely because this
element has already been captured in CRCPD regs. 
Please see the Conference of Radiation Control Program Directors (CRCPD)
Suggested State Regulations, Part N - Technologically Enhanced Naturally
Occurring Radioactive Materials - TENORM (should be available from the CRCPD
web site - http://www.crcpd.org/) :

Exemption limit for TENORM is 5 pCi/g (0.185 Bq/g)  for Ra-226 and Ra-228.  
Paragraph N.4.a. specifies that this limit does not apply to consumer
products, "which are discussed in N.22.c and N.23."
Now, if we will have a look on the paragraph N.22.c:
"An application for a specific license to transfer materials or manufacture
or distribute products containing TENORM to persons exempted from these
regulations... will be approved if:
i.	The applicant satisfies the general requirements specifies in
N.22.a, <that he operates the facility properly, complying with all
conditions, etc.>
ii.	The TENORM is not contained in any food, beverage, cosmetic, drug,
or other commodity designed for ingestion or inhalation by, or application
to, a human being <I don't know - probably FDA 'field'>
iii.	The applicant submit sufficient information relating to the design,
manufacture.......and disposal of TENORM material... to demonstrate that the
material will meet the safety criteria... in N.23. <then there are 16 points
'for compliance'>
N.23 specifies the maximum doses due to the process in N.22: 0.05 mSv for
'whole body', 0.75 mSv to 'hands, feet, localised areas of skin not more
that 1 cm2' etc, and 0.15 mSv for 'other organs'.

The application of the Part N to consumer products is still uncertain.  Some
explanations may appear in the Part N 'Implementation Guidance', which, in
accordance with CRCPD Newsbrief (December 1999) "has been sent to the state
radiation control programs for peer review so that it can be published as a
CRCPD document".
<<<<<<<<<<<<<<

Please let me know if you have any other queries.

Kind regards
Nick Tsurikov
Eneabba, Western Australia
Nick.tsurikov@iluka.com <mailto:Nick.tsurikov@iluka.com> 
1000+1 radiation links:
http://eneabba.net/ <http://eneabba.net/> 

		-----Original Message-----
		From:	SBD [mailto:sbd@co.disp.mindef.nl]
		Sent:	Friday, 4 February 2000 0:03
		To:	Multiple recipients of list
		Subject:	Re: Ignored consumer goods with Ra-226.

		Dear Nick,

		My question on ignoring consumer goods containing radium was
a result of a quick
		scan of exactly this new NUREG-1717.  I also had this
enormously large document
		printed, and the only reference to radium that I was able to
find was on smoke
		detectors (page 2-217), where it is said that the
manufacture of smoke detectors
		containing radium sources ceased following the development
of americium sources.
		I assure you that although manufacture no longer takes
place, radium smoke
		detectors still are around! In all the rest of this
enourmous report I could not
		find any more references to radium. I do hope you are a
better reader than I am.
		If you too are not able to find more, I fear my question (as
stated below) still
		stands.

		With kind regards,

		ing. Jetty Middelkoop
		Radiological protection Service
		Netherlands Ministry of Defence
	
-------------------------------------------------------------------------
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html