RE: CRCPD Regulations for TENORM

["Jonkers, Gert SIC-CTAN/2" <Gert.G.Jonkers@opc.shell.com>]

Group,

Al Tscheache wrote:
> However, I have one observation: Since the TENORM "problem" has been
> recognized and the doses to people who handle TENORM have been
> substantially reduced voluntarily (e.g. without any government
> regulations), why now do we need regulations?  Why can't we continue to
> do it voluntarily without government holding our hands?  Since there
> doesn't seem to be any demonstratable harm even when the doses were not
> reduced, why must we saddle the public with more costs of regulation for
> no measurable health benefit?  
> 
Clearly we are entering the 'political arena' now. Your point of view
closely matches the liberal way of thinking, but - it's a pitty to say -
industry records in the 'environmental' field have not always excellent
(even further back in time their records in field for 'occupational safety'
was also not excellent, and that improved considerably, also due to
regulations). This caused a lot mistrust of society towards industry.
Consequently, (in my opinion) society likes 'environmental' issues to be
regulated, so 'they' have to carry the burden of regulations as well. The
'environmental issue' and 'distrust in industry' culminates in Nuclear Power
Plants.

Besides, the TENORM issue has been recognised, but not yet on an
industry/world-wide scale. In this respect TENORM regulations may assist in
making, in particluar, smaller industries aware of this issue and
consequently more doses can be saved. Especially a lot of ore processing
industries are not yet aware of the presence of NORM in their intake and
TENORM in their waste. Here (in my opinion) we have to improve further on
awareness

To address the issue of awareness: some time ago we had a thread on
'radioactive doors'. This is also a typical TENORM issue. (Within Europe,
before about 1980-1985) heat insulation wool (slagwool or rockwool) is
produced from molten slag from the ore processing industry. This kind of
heat insulation material has been applied throughout the process industry
and has been also applied in fireproof (emergency) doors. As this material
will contain Naturally Occurring Radionuclides (NOR's) in concentrations up
to about 15 Bq[NOR] per gramme material, according the CRCPD proposed and
the new EU exempt limits this material should be under regulatory control.
In the thread the actual issue was: should this material be regulated or
not? and if regulated what to do with plant demolition waste (to an official
LLW site or to a municipality waste -> a typical cost/benefit ALARA
issue??). By the way, as external radiation equivalent-dose rates at the
surface of these doors is about 1 micro-sievert per hour, this TENORM issue
was 'discovered' by the installed portal monitors by scrap
brokers/processors.

I agree with Al  that there is no demonstratable (TENORM) harm done, but the
conclusion drawn is not completely mine. In my opinion regulation is needed,
but we should watch over overregulation.

Kind Regards, Gert Jonkers 
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html