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RE: The EC Dilemma
Dear Charles
The problem is quite interesting for me, since our mineral sands products
(like rutile, ilmenite & zircon) do contain some thorium and uranium and
we do sell them from Western Australia to Europe.
The Symposium on Radiological Problems with Natural Radioactivity in the
Non-Nuclear Industry was held at KEMA in The Netherlands in September
1997. I carried out an extensive review of the Symposium Proceedings in
November last year.
There is a lot of different issues, but I would like to provide some
comments on two first papers:
"Provisions on Natural Radiation in the new Basic Safety Standards", by
A. Janssens & M Markkanen - European Commission, DG XI, Luxembourg
"...Some generally utilised raw materials contain elevated levels of
natural radionuclides. Raw phosphates and zircon sands are good
examples. Such materials are not generally regarded as radioactive but
in some circumstances operations with them may cause significant exposure
to the workers or the members of the public...
...If the doses are less than 1 mSv per year then no special precautions
are required... If doses exceed 6 mSv then it may, in rare cases, be
appropriate to define a controlled area. If doses exceed 1 mSv but are
less than 6 mSv it would be appropriate to consider, for example, whether
doses could effectively be reduced and whether there is a possibility
that doses increase either over time or as the result of an accident..."
I don't think there is any problem about this one.
However, let's have a look on the second paper:
"Radiation Protection Policy Towards the Non-Nuclear Industry in the
Netherlands", by T Klomberg & C Zuur, - Dutch Ministry for Housing,
Spatial Planning and the Environment
"...In the Euratom Council Directive 96/29 [1] adopted 13 May 1996 the
Basic Safety Standards (BSS) for the protection of the health of the
general public and of workers against the dangers arising from ionising
radiation are laid down. It should be implemented by the Member States
in their national legislation before 13 May 2000.
...The Directive applies to:
* all practices which involve a risk from ionising radiation emanating
from an artificial source or from a natural radiation source in cases
where natural radionuclides are or have been processed in view of their
radioactive, fissile or fertile properties;
* work activities which are not covered by the above mentioned practices,
but which involve the presence of natural radiation sources and lead to a
significant increase in the exposure of workers and members of the public
which cannot be disregarded from the radiation protection point of view.
{That's where TENORM comes in}
So, in general, the Directive makes distinction between practices, which
are in principle functional applications of ionising radiation and work
activities, which are not.
...For work activities, the Directive states that the Member States
should identify work activities which lead to a significant increase in
the exposure of workers and/or members of the public. When identified,
the Member States should declare these work activities of concern and
subject of control. When a work activity is of concern, corrective
measures, if necessary, should be taken to reduce the exposure and
radiation protection measures should be imposed. The radiation
protection measures imposed on work activities of concern should be
totally or partially the same, as imposed upon practices by the
Directive."
These measures then will be:
"...the Directive has developed nuclide specific exemption criteria
levels on the basis of scenarios in which the criteria of 10 microsievert
(!!!) in one year as an individual dose and 1 mansievert in one year for
the collective dose should not be exceeded. Under these levels a
practice is exempted, ie. there is no need for notification or
authorisation... ...it was considered that the critical group dose from
any one exempt practice should be of the order of 10 microsievert (!!!)
per year."
Yesterday you wrote: "You mentioned shielding man-made sources to 50
microSv/yr and I could not help but wonder whether this includes
technologically enhanced radioactive material. If so, I believe you have
an impossible task." That's where the real surprise is, it will be not
50 microSv/year, but TEN!!!
OK, let's make some calculations:
Currently the dose rate on my front yard is 0.11 microGy/hour. The
driveway was recently concreted (dose rate 0.17 microGy/hour).
Therefore, my maximum possible radiation exposure because of the
concreted driveway will be: (0.17 - 0.11) microGy/hr * 8760 hr/year =
525.6 microGy/year.
Then we could apply a conversion factor between Sv and Gy, which gives my
annual dose:
525.6 * 0.7 = 367.9 microSv, or 37 times above the proposed limit.
If this limit will be applied 'as it is', it is likely that nearly ALL
human production activities will become work activities in accordance
with this Directive, starting from butter production and ending with
bricklaying. Eating bread and drinking water will be, probably,
regulated; and living in brick houses, drinking coffee and use of any
fertiliser will be outlawed soon afterwards...
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
I also would like to point out that the proposed Part N "Regulation and
Licensing of TENORM" prepared by the USA CRCPD refers to the limit of 5
pCi/g for Ra-228 or Ra-226 in a material, which potentially can lead to
the outcome similar to the one we can theoretically expect in Europe.
I am currently starting a project of creating of some sort of database,
where current limits for NORM & TENORM in different countries will be
specified. When (and if) completed, it will be placed somewhere on the
Internet for everybody to use.
Kind regards
Nick Tsurikov
Radiation Safety Officer - RGC Mineral Sands Ltd,
Eneabba, Western Australia
ph: +61 8 9956 9555
fax: +61 8 9956 9597
ntsuriko@rgc.com.au
>>>>>>>>>>>>>>>
All opinions above are strictly mine and do not reflect the position of
RGCMS Ltd.
<<<<<<<<<<<<<<<
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From: Charles Willis
Sent: Thursday, 26 March 1998 21:40
To: ntsuriko; Multiple recipients of list
Subject: Re: The EC Dilemma
ßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßßß
ßßßß
Wil,
Please inform us about the EC radiation protection dilemma. I keep
hearing
stories suggesting that the economy of the continent may be threatened by
misguided attempts to free the world of radiation.
You mentioned shielding man-made sources to 50 microSv/yr and I could not
help
but wonder whether this includes technologically enhanced radioactive
material. If
so, I believe you have an impossible task. What about fallout from
weapons
tests
and Chernobyl? This is a most interesting phenomenon.
Charlie Willis
caw@nrc.gov