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12 Conclusions and Recommendations
Pages 243-248

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From page 243...
... proposed and current guidelines for TENORM and similar guidelines developed by other organizations have no scientific or technical basis. There are some differences between various federal agencies in how they perform risk assessment, but the differences in their guidelines represent differences in policies for risk management.
From page 244...
... objective is the most important factor in guiding agency actions aimed at radiation protection much more important than established regulatory limits or goals. To the extent that the ALARA objective is applied consistently to all exposure situations, all guidances and regulations would be consistent, provided that it is recognized that risks that are ALARA can vary considerably with the particular exposure situation.
From page 245...
... 3. For the purpose of developing guidelines, it is appropriate to develop stylized methods of exposure and dose or risk assessments for assumed reference conditions, provided that the assumed conditions are reasonably representative of the exposure situations of concern.
From page 246...
... For example, the soilcleanup criteria developed under the Uranium Mill Tailings Radiation Control Act have been extended to many other situations by state and federal regulatory agencies, but many sources of TENORM have mineralogic characteristics and processing histories that differ greatly from those of uranium mill tailings, and therefore have different radon-emanation coefficients, leachability, and bioavailability.
From page 247...
... However, the committee does caution that, as the regulations are developed and acted on, continued attention to the factors that affect radiation dose and risk for specific TENORM situations is crucial for consistently protective, cost-effective radiation control. In addition, further study on issues of cost-benefit and other nonscientific concerns could be important in regulating TENORM, given the magnitude and variability of natural background.
From page 248...
... The committee commends the agencies for having done so and recommends that they pursue this approach further. The committee recognizes the different objectives and histories of the two agencies, but it is good public policy to reconcile the existing differences in approaches to risk management with an eye to better, more timely, and more efficient compliance activities by the regulated community, and greater acceptance by Congress and the public.


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