[ RadSafe ] Question on the exemption of material as NORM inMississippi.

Walter Cofer radcontrol at earthlink.net
Wed May 30 16:48:36 CDT 2007

Amy -

Your best bet is to simply contact the MS regulators and get your answer
straight from the horse's mouth, because it doesn't really matter what
anyone else thinks.  You should send them an email, because when they reply,
it's an official correspondence, and if anyone ever challenges you, you can
show them the state's position, in writing.  If the email doesn't get a
response, repeat via snail mail.  You may also want to send it using
certified mail; that tends to get regulators' attention.

Walt Cofer
Radiation Control, Inc.
Tallahassee, FL
Tel:  (850) 668-8559
Cell: (850) 519-5351
Fax: (850) 893-2566
radcontrol at earthlink.net

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Amy_Jones at URSCorp.com
Sent: Wednesday, May 30, 2007 3:29 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] Question on the exemption of material as NORM

In doing NORM survey work we have encountered material that contains both
Radium 226 and Radium 228.   The Exemption section of the Mississippi
regulations on NORM (excerpted below) states material is exempt if it
contains less than 5 pCi/g of Ra-226 or Ra-228.    The question has come up
do we compare the isotopes individually to the 5 pCi/g concentration, or do
we sum the two concentrations and then compare it to the criteria.  We have
looked at this both ways and have yet to come to a satisfactory conclusion.
Has anyone else encountered this question?


 Title 15, Part III, Subpart 78 Chapter 01Regulations for Control of
Radiation in Mississippi,
1100 Licensing of Naturally Occurring Radioactive Materials (NORM )

1100.04 Exemptions.
1. Persons who receive, possess, use, process, transfer, transport, store,
distribute, and dispose of NORM are exempt from the requirements of
these regulations if:
a. The materials contain, or are contaminated at, concentrations less than
5 picocuries per gram of radium - 226 or radium - 228 above
background; or, concentrations less than 30 picocuries per gram (1.11
kBq/kg) of technologically enhanced radium-226 or radium-228,
averaged over any 100 square meters, provided the radon emanation
rate does not exceed 20 picocuries (740 mBq) per square meter per
second, or 150 picocuries per gram (5.55 kBq/kg) of any other
NORM radionuclide, provided that these concentrations are not
exceeded at any time; or

Amy Jones, RRPT
URS Corporation
756 East Winchester Street Suite 400
Salt Lake City UT  84107

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