Too Many Notes?

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Abstract
Orphan sources are now recognized as a radiation protection problem needing attention. Government and private sector initiatives have been mounted in response. Should more be done? There are promising possibilities. Under the ICRP 60 system of radiation protection, any use of radiation should be justified. Key NRC licensing regulations predate ICRP 60 and, consequently, if a use is authorized by license, then the use is presumed to be justified even if alternatives are available. As an example, x-ray gauges can be successfully substituted for nuclear container fill level gauges in the food and beverage industry. But this development is not widely known to potential users and regulators, and current regulatory policies do not address this. Limiting the number of radioactive devices would limit the number of potential orphan sources. From an operational radiation safety point of view, persons wanting to dispose of unneeded or unwanted radioactive sources are faced with a system loaded with disincentives, in part because disposition options are not well known and in part because options have become limited, complex, and expensive. New approaches are needed if the orphan source problem is to be effectively addressed. Paramount are the needs to (1) update U.S. regulatory policies to incorporate the ICRP principle of justification, (2) create a system that encourages prompt, safe dispositioning of unneeded and unwanted radioactive sources, and (3) make information on these points universally known to users of radioactive sources.

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