[ RadSafe ] Question on the exemption of material as NORMinMississippi.

[Earley, Jack N]

Valid point, Walter, but Amy's approach is likely to get her faster
results. If she hands the regulators a well-reasoned or consensus
answer, it's easier to get agreement than to just walk in w/ a question.
It's better to recommend a solution rather than just identify a
problem--I've even worked with people who don't want to hear about a
problem unless there's a reasonable solution to go with it.

 
Jack Earley
Health Physicist
509.372.9532

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Walter Cofer
Sent: Wednesday, May 30, 2007 2:49 PM
To: Amy_Jones at URSCorp.com
Cc: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Question on the exemption of material as
NORMinMississippi. 

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
http://www.rad-control.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
inMississippi. 



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?

   Thanks



 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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