RE: CRCPD Regulations for TENORM

["Tsurikov, Nick" <ntsuriko@rgc.com.au>]

Hello from Western Australia, dear Al

My personal understanding is that these regulations are required for the
following reason:

As everybody knows, there are numerous materials and practices which are
not associated with nuclear industry but do give rise to radiation
exposure.  Let's discuss an example:

Let's say, a small enterprise in a country town in course of its
activity could potentially expose employees up to 200-300 mrem.  Due to
the waste disposal from this enterprise doses to members of the public
could be about 50 mrem.  The exposures are mainly due to inhalation of
dust containing uranium, thorium and their daughters contained in the
material used by an enterprise.
Due to the fact that in accordance with US EPA FGR-13 and recently
released NCRP Report 1-6 "LNT dose response model is to be obeyed at all
times" (please correct me if I am wrong here), the question is: should
we have a closer look into the practices of this particular small
enterprise?  LNT says: "thou shalt, or other..."
So we are doing this and discovering that the exposures associated with
this enterprise are comparable with those encountered in the nuclear
industry.  Therefore, the answer is simple - this place is to be
regulated somehow.
The question is: how..?
Should we go and classify the material used by this enterprise as a
"source material" (as per 10 CFR Part 40 and, subsequently, subject to
the NRC jurisdiction)?  If we do that, there is a possibility that the
local paper will have 5'x5' letters on the front page in a couple of
days - something about 'nuclear waste' and 'deadly radiation in our
town'.  Every reasonable person (I mean proprietor of this enterprise)
will realise this beforehand and simply shut the doors and will open a
bakery or something.
And right here a friendly State Radiation Control Bureau comes to help
with CRCPD Part N adopted into State regs, LOCAL inspectors and limits
for Ra-226 and Ra-228, thus AVOIDING any association with 'nuclear
activities'.  
Therefore, it is possible for the enterprise to continue its activities,
provided that the doses will be kept as low as practicable.  

The most important thing, I think, is that naturally occurring
radioactive materials (even with technically enhanced concentrations of
radium) are treated FOR WHAT THEY ARE and the clear line is drawn
between nuclear and non-nuclear activities.  This is what Europeans
missed in their Euratom Directive 96/29 which, from my point of view,
does not have such a clear 'cut' and, therefore, could potentially
threaten small and medium size businesses there (the example above) from
13 May 2000, when it will be adopted into every Member State
legislation.

Please let me know if I am missing something here or if you require any
additional information.

Kind regards
-----
Nick Tsurikov
Radiation Safety Officer
RGC Mineral Sands Limited
Eneabba, Western Australia
e-mail: ntsuriko@rgc.com.au
World Collection of Radiation Links:
http://www.cynet7.com/Walkabout/
-----
>>>>>>>>>>>>>>>>>>>>>>>>
The text of this message was not reviewed or approved by RGC Mineral
Sands Limited and represents the views of the author only.
>>>>>>>>>>>>>>>>>>>>>>>>
----------
From:  Al Tschaeche[SMTP:antatnsu@pacbell.net]
Sent:  Wednesday, 2 December 1998 7:46
To:  Multiple recipients of list
Subject:  CRCPD Regulations for TENORM

I just finished reading Part N, Regulation and Licensing of Technically
Enhanced Naturally Occurring Radioactive Materials (TENORM) and the
Rationale for that regulation.  In neither of those documents do I find
any discussion of why such regulation is needed.  There are no data that
I know of that show humans are harmed by current practices vis-a-vis
TENORM.  Does anyone out there know of documentation demonstrating that
such regulations are needed to improve radiation health and that actual
harm has been done to humans because there have been no such
regulations?  If so, would you be so kind as to point me to those
documents (hopefully on the web so I can download them)?  Thanks.  Al
Tschaeche antatnsu@pacbell.net
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