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Re: OMINOUS EVIDENCE



At 05:01 PM 10/15/99 -0500, Al Tschaeche wrote:
> We have radium problems because the NRC doesn't regulate naturally
>occurring radioactive material.  We have NORM and TENORM problems for the
>same reason.  No one regulates "background" so the airlines have problems
>with aircrew exposures.  Etc., etc.  
> Does anyone know if the IAEA charter permits it to regulate all forms of
>radiation and radioactive material, including natural?  Is there any
country >in the world that has a system that does that?  


I can't comment  your statement about NRC regulation or activities, but I
can comment about International  Recommendation, specially ICRP and IAEA,
and you already mentioned the IAEA. (By the way I am not a staff member of
the IAEA) 

The  available  quantitative recommendations of the ICRP for protection
against exposure to natural sources were confined to radon. Therefore,  the
IAEA  Basic Safety Standards decided that the General Obligations for
practices concerning protection against natural sources, which is normally a
chronic exposure situation, should be object to intervention and the
requirements for practice should be generally limited to exposure to radon.
The exposure to other natural sources being expected to be dealt with  by
exclusion or exemption of the source or otherwise  at the discretion of the
Regulatory Authority.

I would also like to comment some aspects on this subject:
 
1)There are many examples and papers presented  of residual radioactive from
past practices, and their consequent chronic exposure situation. The
majority of cases are connected to military activities. 

2) There are also cases of old  consumer products not more in the market,
but time to time  bring problems to Regulatory Authority. Many of these
products are completely out of control, abandoned or even destroyed. The
most concern radionuclide in such consumer products was Ra-226, and some are:

Product                  activity of Ra-226      
Timepieces               up to 200 kBq 
Compasses                up to 200 kBq
Lightning conductor      up to 40 MBq 
Ionization chamber
smoke detector           up to 550 kBq


3) The first principle of the System of Protection  is  justification of the
practice. The justification of a practice delivering prolonged exposure
requires  that all relevant long-terms  factors should be considered prior
to the adoption of the practice. There are some human activities, as
mentioned, for which it is difficult to decide whether they should be
considered as practices or not. How can one justify the use, for  instance,
of coal fly ash as building material? The disposal of fly ash by using it as
building material clearly has economic benefit for the producers of fly ash
but  does not confer  any particular benefit on members of the public
occupying the houses, considering that there are other equally good
materials for use in housing construction.  However we know that there are
many countries using coal fly ash as building materials, so the exposures
of members of the public occupying the houses, delivered from   the fly
ashes, should be controlled in the same  manner   as exposures from practices? 
Nevertheless there is no "justification" for use of coal fly ash in building
materials, I know countries are using extensivelly. I do believe these
countries adopted action levels, and derived  upper limits for activity
concentrations of specific radionuclides in such materials.

Another example is the sale of seafood containing radionuclides from routine
authorized  discharges. Even considering an economic  benefit to the vendor
and also to the consumer, we can not characterize the sale of such seafood
as practice. The system of Protection for practice should be applied at the
source of the radionuclide released.


J. J. Rozental
josrozen@netmedia.net.il
Israel



jjrozental

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