Re: Upcoming State Senate Hearing in Los Angeles

[BLHamrick@AOL.COM]

In a message dated 2/21/2003 2:06:45 AM Pacific Standard Time, eic@shaw.ca writes:


> What does the legislation say about disposing things such as thoriated TIG welding electrodes? Up to 4% thoriated tungsten is exempt from federal licensing, but it is still quite radioactive.
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> What about kitty litter? It is not that radioactive, but it is certainly above background. (I use a bottle filled with the stuff as a radon/thoron check source for my instruments. Works great!) I would expect that vast quantities of that is currently going to landfills.



As written, the legislation acknowledges an exemption for "Radioactive materials intentionally inserted into products for their radioactive purpose and that are specifically exempted by the Nuclear Regulatory Commission from Part 30 (commencing with Section 30.1) and Part 40 (commencing with Section 40.1) of Title 10 of the Code of Federal Regulations, as those regulations read on the date of

enactment of the Energy Policy Act of 1992 (P.L. 102-486)."


I do not have a copy of the regulations from 1992, but would assume that thoriated tungsten was on the list back then.  The legislation actually misinterprets NRC regulation, because they do not exempt "items," but rather exempt "persons" to the extent they possess certain items.  It's a bit of a subtlety, but has had some practical effect in the 15 or so years I've worked in this field.


As to the kitty litter (as long as we're not talking about litter from cats who have undergone iodine therapies), I believe that this could be potentially subject to control as TENORM (depending on whether or not any physical, chemical or other processing concentrated the original NORM content above the naturally-occurring concentrations in the raw material from which the litter is derived).  Under the current version of SB 13, the regulation of TENORM would fall to a different agency than that which currently regulates its use and disposal.

  The bill leaves it to that agency to decide what limits are acceptable.


Those are my personal readings of the bill, speaking as a private citizen.


Barbara L. Hamrick, CHP, JD