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ICRP: Free the Annals!

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Submitted by Pillalamarri Jagam Ph D, The NORM Group
   Commenting on behalf of the organisation
Document Recommendations
We oppose the deregulation of low level nuclear waste on the basis of our experiences
here in Canada. The reason is primarily from the point of view of the consequences of
increasing recycling and conservation efforts dealing with the waste along with general
municipal wastes. The radioactive waste is contaminating many of the materials used
by the general public. This is not acceptable for the same reasons atmospheric weapons
testing was not acceptable and it was banned.

We have detected radioactivities in general purpose commercially available materials
whose origin is other than naturally occurring radioactive materials (NORM).

Over the last twenty five years our members have developed the detection methodologies
and technologies which are capable of detecting these low level radioactivities. These
capabilities are beyond the reach of the traditional commercial vendors who provide
commercial services for radiological screening of waste.

Exposure to anthropogenic radioactivity must not only be minimised, but it must also be
eliminated by isolation of the radioactive waste from entering recyling streams and
conservation streams. Low dose radiation research is showing the evidence which
cannot be ignored simply becasue we do not understand or project the consequences
to human health or human existence.

Please, let us talk. Don't be in a haste to deregulate low level radioacitivity waste
disposal. Cross-contamination can be eliminated by isolation. It cannot be eliminated
by dilution. This is what is taught to us in handling radioactivities. Isn't it?

Please let us talk and think of the consequences of deregulation from a larger
perspective than is being considered from the dosimetry perspective.

Submitted with utmost respect and due understanding of the consequences of
radioactive contamination.

with best regards


P. Jagam PhD
Scientific Director
The NORM Group