1. Are the administrative release levels contained within the TENORM policy above background?
2. How does the department employ the 40 pCi/g gross alpha limit mentioned in Section 12 of the Solid waste regulations?
Section 12.2.1 of the regulations requires that if the total alpha activity of the sludge exceeds 40 picocuries per gram of dry sludge, the sludge generator shall contact the Department's Radiation Control Division for further disposal guidance.
The radioactive materials unit will then likely require that the generator have the materials analyzed for specific radioactive isotopes such as radium, uranium or thorium.
Once a waste stream has been shown to exceed, or have the potential to exceed, the administrative release levels the waste stream must be analyzed for specific radioactive isotopes in lieu of the gross alpha analysis for future volumes of the material. If an adequate amount of data collected over time demonstrates that there is no potential to exceed the administrative release levels, the department may approve a return to the gross alpha analysis.
3. The November 7th and 14th, 2017 Department letters regarding management and disposal of TENORM wastes stated that, "E&P waste streams with the potential for high concentrations of TENORM are prohibited from disposal in all landfills in Colorado not specifically approved and designated to take them unless and until each waste is sampled and tested on a per shipment basis or in a representative and statistically-valid manner..."
Does this allow for only one sample to be taken of each waste shipment to establish proper characterization when wastes are being characterized on a per shipment basis?
No. Regardless of whether or not you have a static or dynamic type waste stream the materials need to be characterized in a statistically defensible manner. In other words, a statistically significant number of samples (as per SW-846) are used to characterize the waste regardless of whether they have to be characterized each and every load (for dynamic type wastes) or if there is an initial characterization and subsequent sampling to verify the consistency of the waste stream (for static type wastes).