🚀 go-pugleaf

-----------------------------------------------------------------------------
PREPARED BY: FRED DAVIS CORPORATION                            508-359-3610
11/1/89                                              FOR: ENERGY FEDERATION
-----------------------------------------------------------------------------

MEMO ON RADIOACTIVE ELEMENTS FOUND IN COMPACT FLUORESCENTS

Introduction

    This memo attempts to address some questions regarding radioactive
elements in compact fluorescents. The best source to date on this subject
is
found on p.232-242 in the latest version (3/88) of The State of the Art:
Lighting, by Amory Lovins, Robert Sardinsky, et al, a part of the
Competitek
Service of Rocky Mountain Institute (RMI). The next edition of this work,
due
sometime soon, is reportedly not going to contain any update to this
section.
     Since the RMI document covers a lot of the pertinent issues, the
present
memo attempts to provide additional information. The sources consulted for
this work were top engineers at each of the major lamp manufacturers. No
independent research or analysis was performed. As cautioned in the RMI
document, the current memo should not be substituted for competent
bioradiological expertise.

Conclusion as to Health Hazard

    The basic conclusion one is left with after reading the RMI report, is
that the amounts of radioactivity in these lamps are truly insignificant.
This memo does nothing to change that basic conclusion. Furthermore, the
author knows of no party claiming anything to the contrary.

Purpose of Radioactive Element

    Compact fluorescents are a type of fluorescent known as preheat design.
This means that a "starter" is needed to generate sufficient voltage to
start
an arc flowing between cathodes. In most preheat circuits, the starter is
external to the lamp, but in the compacts, the starter is integral.
    In regular fluorescents, ionization is initiated once a sufficient
voltage exists between a cathode and a grounded conductor, which is usually
the metal body of the fixture. With compact fluorescents, the proximity of
a
metal fixture obviously cannot be relied upon. The radioactive elements
(radioisotopes) serve the function of initiating the ionization in the
lamp's
starter once there is a voltage potential (that is, once the switch is
thrown). The beta particle emitted (an electron) generates this breakdown.
    It seems that eliminating the radioactivity altogether is possible--
radiation from ambient light can provide the same condition. Manufacturers
claim they would much rather skip the radioisotopes and avoid the
significant
regulatory burdens imposed by the NRC. Relying on ambient light to start a
lamp, however, poses some obvious problems. Some claim that reliability
would
drop to an unacceptable level if the radioisotopes were not present.
     It is unclear whether Sylvania has gone this route. While since Jan.,
1987, their lamps reportedly contain no intentionally added, artificial
source of radioactivity, sources are careful to say that the company makes
no
claims that their lamps are any better than any others in this regard. They
leave open the possibility that another process is performing the same
function. Other sources suggest that, in the U.S. at least, Sylvania may be
doping the contacts with radioactive elements.

Seeming Insignificance of the Problem

    Some interesting statistics are cited by manufacturers to keep the
public
aware bf the proper insignificance of the situation. For instance: If one
million lamps were piled up and a Geiger Counter were placed in the middle
of
the pile, there would not be enough radiation to cause it to register at
all.
Another example: The cumulative radiation dose received by a worker at a
lamp
manufacturer who is handling the starter elements all the time over a year,
is less than the amount of radiation received by someone in one airplane
trip.

History of Regulation

    The history of this issue is an interesting one. A couple of years ago,
the lamp manufacturers came under the scrutiny of the Nuclear Regulatory
Commission. -The NRC regulations affected the manufacturers in two ways.
First, the vast quantities of lamps apt to be at a plant added up to a
significant quantity. That is, if hundreds of thousands of lamps were
crushed
at once, there would be a level of radioactivity that would require a
license
from the NRC. Second, the importing of any level of radioactivity fell
under
their jurisdiction. This is even though the levels at issue are below the
minimum standards adopted worldwide, including by the U.S.
    Joint meetings with lamp manufacturers and the NRC resulted in the
present regulatory situation. Each manufacturer now has an
exempt-distributor
license from the NRC. With this, the manufacturer can distribute to anyone,
regardless of the volume of product that any customer might potentially
accumulate. Also, maximum allowable levels were set, such as 25 nCi of
Kr-85,
and a notification-type of labeling of each product is mandatory. Beyond
that, there is some obvious variation among manufacturers. For instance,
Philips and Panasonic state specific amounts on each product label, Osram
does not.
    There is a possibility that the NRC may come out with Below Regulatory
Concern or BRC, a new regulation which would set standards below which the
agency would not concern itself. This may, presumably, exclude the compact
fluorescent lamps from regulation in the future.

Differences and Similarities Among Manufacturers

    Apart from the discussion above regarding Sylvania, and apart from the
fact that GE representatives could,not be reached for consultation, the
differences found in the chart below are few.
     As to why Philips uses tritium (H3) in the 10-mm quads, they simply
state that they found it to be the most reliable element for starting that
lamp type.
    The differences between the levels reported by Philips and Osram in the
twin tubes is slight, and since these two share sources of starters, it is
likely to be a reporting difference only.
    The 15-mm quads are only really made by Panasonic, and essentially
private-labelled for Philips. Similarly, GE's Compax is essentially
private-
labelled by Panasonic for them.
    When studying the chart below, it is important to remember that the
different elements will have differing potentials for biological harm,
depending on their physical and chemical form, and other factors. In order
to
judge the relative potential for impact, the reader is again referred to
the
RMI report, or some other source on the subject.


RADIATION LEVEL IN EACH COMPACT FLUORESCENT LAMP
AS REPORTED BY RMI 3/88 AND CURRENTLY
(The following information should be used only with the accompanying memo.)
Generic type:     Twin tubes     Quad tubes    Larger quads    One-piece
Tube diameter:    10-am          10-mm         15-mm           (non-

Typical wattages: 5,7,9,13       9,13          22,28           15
                  ----------     ----------    ----------      ----------

Philips
    Designation:  PL             PLC 10MM      PLC 15MM
    RMI 3/88:     1 nCi Kr-85    <500 nCi  H3
    currently:    <15 nCi Kr-85  <500 nCi  H3  330 nCi Pm-147
    orig mfr:                                  [Panasonic]

Osram
    Designation:  Dulux          Double Dulux
    RMI 3/88:     <12 nCi Kr-85
    currently:    -12 nCi Kr-85  -12 nCi Kr-85

Panasonic
    Designation:                               Quad-tube       Light
Capsule
    RMI 3/88:
    currently:                                 330 nCi Pm-147  330 nCi
Pm-147

GE
    Designation:  Biax                                         Compax
    RMI 3/88:     <250 nCi Kr-85                               330 nCi
Pm-147
    currently:    [not consulted]
    orig mfr:                                                  [Panasonic]

Sylvania
    Designation:  Twin tube      Double twin
    RMI 3/88:
    currently:
    orig mfr:     [in England]
              
 * Origin: ONE WORLD Los Angeles 310/3720987 (1:102/129.0)