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

[cobdw at tds.net]

Amy,
After reading the section of the regulation that you include with your question, I am in concurrence with Mr. Davis' assessment of the situation. However, I also believe that you should contact your state regualtor to confirm this. A good portion of the remediation program is maintaining that open communication with the folks who will be reviewing the final report and deciding if the area is releasable. Remember, the amounts that are listed are 5 pCi/g above background. If you have referance area samples showing both are present, then you should be able to subtract some portion from the final results for the actual survey unit.
Good luck,
Douglas Coble, RRPT

---- Mitchell Davis <mitchrn at suddenlink.net> wrote: 
> The exemption applies to both isotopes and not collectively.  If EITHER (not
> the combined total) exceed 5 pCi/gm, then the exemption is not satisfied.
> 
> Mitchell Davis, RRPT, RN
> Health Physicist
> Midland TX
> mitchrn at suddenlink.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 2:29 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
> 801-904-4000 (main)
> 801-904-4023 (direct)
> 801-913-5199 (cell)
> 801-904-4100 (fax)
> 
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