Re: CRCPD Regulations for TENORM

[Al Tschaeche <antatnsu@pacbell.net>]

Mike Durham wrote:
> 
> What exactly does the proposed regulation define TENORM as?

As defined in Part N: "Technologically Enhanced Naturally Occurring
Radioactive Material (TENORM) means naturally occurring radionuclides
whose concentrations are increased by or as a result of past or present
humen practices. TENORM does not include background radiation or the
natural radioactivity of rocks or soils.  "TENORM" does not include
uranium or thorium in "source Material" as defined in the AEA and US NRC
regulations."

As I reread this again, and again, I am lead to the conclusion that,
unless concentrations are increased, just bringing radioactive material
to the surface from underground would not be included in TENORM.  So,
one could have a pipe contaminated with radium 226 at the concentrations
found deep in the earth and another pipe contaminated with radium 226
slightly concentrated because of corrosion.  The first pipe would not be
TENORM, the second, would.  Is this interpretation correct?  If so, how
does one know that the contamination on the first pipe is truly not
concentrated, and how does one know that the contamination on the second
really is concentrated, without measuring the concentrations deep in the
ground where the pipes were?  Such measurements would be expensive I
think, but must be necessary if one wants to be sure of one's ground (no
pun intended).  So, here comes a whole new business: deep underground
radionuclide measurement services.  I'm only partially tongue in cheek
here.  Al Tschaeche antatnsu@pacbell.net
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