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RE: Dilution the Solution?



Dear Radsafers,

For those interested what's going on in other places: 
The regulation 16.35 (2) of the Western Australian Mines Safety and
Inspection Regulations states that: -
>>>Each responsible person at a mine must ensure that, so far as is
practicable, radioactive waste is diluted with other mined material before
it is finally disposed of in order to ensure that in the long term the use
of the disposal site is not restricted.<<<

I was wondering if someone could tell me what the "world's best practice" on
this may be.  CRCPD in their latest Part N regs for TENORM changed the
'dilution option' a bit.  Before it was something like "purposeful dilution
to render material not classified as TENORM is not allowed"... (Something
like this - don't remember exactly).  Now it is (Rationale to N4) >>>The
CRCPD does not consider it appropriate to perform purposeful dilution of
TENORM in order to be excluded from these regulations unless otherwise
allowed by specific state regulatory actions.<<<  So, it is allowed, after
all.

So, is the dilution THE solution or not?  I personally think that it is not
applicable for all materials.  Let's say we have some monazite (not
chemically treated) and we need to dispose it off - should not be a problem
to simply mix it up with 'general' mine tails to the levels acceptable.
However, we may run into a problem if a similar process is used for disposal
of the material containing radionuclides like Ra-226 & Ra-228 in a form that
allows easy leaching into the environment (let's say - the same monazite,
only chemically treated).

I would be very interested to know what people think on this matter, as due
to legislative developments like CRCPD Part N, Euratom Directive 96/29 and
IAEA BSS 96 it's quite possible that many industries (not just mining and
mineral processing) will 'discover' that they have 'radioactive material' in
their possession and need to dispose it off somehow.

Kind regards
Nick Tsurikov
Eneabba, Western Australia
http://eneabba.net/ <http://eneabba.net/>  




		-----Original Message-----
		From:	Bud Summers [mailto:summers10@llnl.gov]
		Sent:	Thursday, 4 January 2001 7:02
		To:	Multiple recipients of list
		Subject:	Re: Dilution the Solution?

		Ken:

		I remember that they used plowing to dilute slightly
contaminated soil at
		Rocky Flats in the early "80's". This was in response to a
court case in
		progress at that time.  You might try to contact people at
the State of
		Colorado, Radiation Control Division. I am sure there is
someone there who
		would remember that situation.  Maybe talk to Rob Terry.
There are
		probably still people at Rocky Flats who are also familiar
with that case.


		Best Reqards!

		Bud Summers




		At 02:31 PM 1/3/01 -0600, you wrote:
		>According to all prior regulatory policy guidance, we have
never proposed to 
		>deep plow contaminated soil to reduce the average
contamination levels.  
		>However, recently I have heard references to situations
where the DOE and
		the 
		>NRC approved the use of deep plowing as a remedial measure.
If such 
		>situations exist, could someone provide the details as to
location, 
		>contaminant, depth of mixing, etc.?
		>
		>Ken Baker
		>ERGKBAKER@aol.com
	
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