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NORM REGS AND CRCPD
From: IN%"oracle@ionet.net" 19-AUG-1996 20:00:49.41
To: IN%"radsafe@romulus.ehs.uiuc.edu"
CC: IN%"gooden@VMS.OCOM.OKSTATE.EDU"
Subj: NORM REGS AND CRCPD
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Date: Mon, 19 Aug 1996 17:45:10 -0700
From: "Dwight A. Vance, R.Ph." <oracle@ionet.net>
Subject: NORM REGS AND CRCPD
To: radsafe@romulus.ehs.uiuc.edu
Cc: gooden@VMS.OCOM.OKSTATE.EDU
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I attempted to post this to RadSafe on Monday. My computer was down so I
used another station in the hospital. I don't think the listserver
recognized the "signature" of the person who owns the computer I used. I
don't think the message was posted. Since I think the naturally occurring
radioactive material (NORM) issue is so important, I am posting it again.
David S. Gooden
-------------
On Friday, August 16, Mr. Carey Johnston (US EPA Rad Prot
Div), asked about reports and information on "Discrete NARM"
(which Mr. Johnston properly pointed out includes NORM). I do not
have specific reports to recommend, but I hope Mr. Johnston will not
mind if I use his inquiry to introduce an important subject to
RADSAFE: the regulation of NORM.
Mr. Johnston used an "arbitrary definition" of discrete NARM
[NORM] waste as those wastes having greater than 2 nanocuries per
gram of Radium-226. This definition may work within the specific
context of Friday's inquiry regarding "source capsules of
decommissioned accelerators," but there are many areas where it
does not work well. In my experience, this would not be a good
definition for those of us who work with state and federal agencies
and industry in addressing technologically enhanced (TE) NORM
waste streams resulting from many industrial activities. These waste
streams create "diffuse NORM," not discrete NORM. Though most
diffuse TE NORM in these streams is well below 2000 picocuries per
gram, some may be at or above these levels.
Properly addressing TE NORM ranks among our most
important issues today. We must address the health and safety
needs of our people. However, we must not unnecessarily burden
our important industries unless there is an identifiable and
corresponding health and safety benefit. In our society, the well-
being of our people depends on the well-being of our country's
industries.
In just a few weeks committees for the CRCPD will meet in an
effort to forge a reasonable standard for the regulation of NORM
(Part N). Many important issues will be discussed. Definitions will
be included in the discussions.
RadSafers may have input that could be important to the
CRCPD process. For example, what should be the limits for release
of land impacted with TE NORM for unrestricted use. Several oil
producing states use a value of 30 picocuries per gram (0.000030
microCi per gram) if there is a low radon emanation factor. A
common release limit for the release of equipment and pipe
impacted with TE NORM is 50 microroentgens per hour (including
background) in contact with any accessible point. Should the
CRCPD also consider a "tier" for restricted uses but not unrestricted
use? Such a tier might allow, for example, pipe that exceeded the
level for unrestricted use to be released for uses as cattle guards,
fence posts, and concrete reinforcement in places other than
residences or public places. What should be the limit for these
restricted uses?
Should the CRCPD pay attention to the recommendations of
the ICRP and the NCRP regarding NORM? The ICRP has
emphasized adaptive approaches to remediation. The ICRP refused
to set a dose limit on remediation. Instead they say, "The need for
and the extent of remedial action has to be judged by comparing the
benefit to the reduction in dose with the detriment of the remedial
work, including that due to the doses incurred in the remedial work"
(ICRP Publication 60 @ 51).
Some may find the NCRP's position on this subject surprising,
but I think reflection on the NCRP's position will show it to be well
thought out. The NCRP sets a remedial action level of 5 mSv/yr
(500 mrem/yr) continuous exposure from TE NORM, excluding radon
(NCRP Report 116 @ 50).
What disposal methods should be allowed? Is land farming,
which is a viable option for the disposal of many petroleum waste
products, proper for some NORM waste? For example, on-site land
farming may be an appropriate method of disposal if NORM levels
are not too high. The real and measurable dangers of death or
injury due to the operation of heavy earth moving equipment and
highway trucks could be avoided by allowing land farming in certain
situations.
Are some landfills appropriate for TE NORM disposal under
certain situations? The EPA has recommendations for addressing
TE NORM in drinking water treatment waste that includes disposal
in some Subtitle D waste facilities for levels up to 50 picocuries per
gram. Similar disposals may be appropriate for TE NORM
generated by other industrial activities.
All of these are significant questions. The development of
standard approaches to NORM regulation is an important activity.
I hope those with thoughts on this matter will provide input. Thank
you for letting me use Mr. Johnston's inquiry to introduce this
important issue to RadSafe.
David S. Gooden
Director, Biomedical Physics
Saint Francis Hospital
Tulsa, Oklahoma 74136
phone: (918) 494-1444
FAX: (918) 494-1452
gooden@vms.ocom.okstate.edu