Is there a major error in the NSW regs review?

Greetings!
I finally managed to read the 'Review of NSW RC Act 1990' document and have a very strong suspicion that a major error may have been made - which throws most arguments about what's radioactive and what's not into total disarray:
The value in NSW (100 Bq/g) is compared directly with 1 Bq/g from NDRP and, of course, it looks completely deadly - 100-times decrease!
Illustration 1:
100 Bq/g was calculated for ‘total activity’: Th ppm × 4.1 × 10 (to account for all 10 radioisotopes in the chain)
1 Bq/g is for the ‘parent radioisotope' only: Th ppm × 4.1
Illustration 2:
Example of calculation for typical zircon sand (220 ppm Th + 250 ppm U):
Specific activity calculated as per NDRP (and almost elsewhere in the world):
[220 × 4.1 + 250 × 12.5] / 1000 = 4 Bq/g
Specific activity calculated as per NSW:
[220 × 4.1 × 10 + 250 × 12.5 × 14] / 1000 = 53 Bq/g
Then some proposals are made about having the materials 'up to 30 times of NDRP levels' not regulated, or something like that... Based on what way of calculating it...? There is no specification in the document at all.
There are some other points in the document, but the time for comments has expired in late February. Could someone from NSW please let me know what is happening and if I am correct in my comment above?
Any additional information will be very much appreciated.
nick
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Clearly, there is some sort of issue in how the 100 Bq/g and 1 Bq/g figures have been interpreted and compared. However, the situation isn't even as simple as making a comparison between the old level and the new level. In general, the BSS offers a range of different exempt levels depending on the radionuclide involved. A specific activity of 1 Bq/g is only relevant to materials containing uranium and thorium. As the review paper correct notes, this is going to involve NORM bearing materials. Mostly ores or ore concentrates either being mined or processed. The NSW legislation does not apply the 100 Bq/g ecut off for these materials. Instead, it applies concentrations of 200 ppm and 500 ppm for uranium and thorium respectively. These levels are approximately equivalent to 35 Bq/g total activity. Moving to a concentration of 1 Bq/g for the parent radionuclide is not as great a reduction as that suggested by the review paper. Another question that needs to be asked is whether NSW intends to remove the exclusion of the NSW Act from applying to a radioactive ore while it is being mined or is subject of treatment (section 5). While this exclusion remains there will be no issues under the NSW legislation regarding application of the 1 Bq/g to NORM materials.
I had a read of the relevant section of the document and page 34 certainly makes reference to the point you are making Nick.
...There is some indication that the next published version of the National Directory may regulate radionuclides to the activity concentration level of 1 Bq/g; this is in contrast with the 100 Bq/g of the NSW Regulation.
The error you point out is common place in WA too. Under the WA Mines Safety and Inspect Regulations we often use the BSS-115 1 Bq/g level for waste containing Uranium and Thorium (nat) as the determination point of radioactivity (not including daughters). Under the WA Radiation Safety (General) Regulations the radioactivity determining point is 30 Bq/g but this also includes all daughters. It is not uncommon for radiation professionals in WA to get confused by this subtle difference unless they are made aware of it.