The Materials Management and Hazardous Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate the opportunity to jointly provide comments on the U.S. Nuclear Regulatory Commission’s (NRC’s) Proposed Interpretive Rule, Transfer of Very Low-Level Waste to Exempt Persons for Disposal NRC-2020-0065, published in the Federal Register on March 6, 2020 (85 FR 45). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial radiological, solid waste, and hazardous waste programs may also provide comments based on their own perspectives and experiences.
The ASTSWMO Radiation Task Force presented a webinar on February 14, 2019 that highlighted their 2018 guidance document, “Waste Generation and Disposal: Awareness, Management, and Disposal Guidance for Solid Waste Containing Technologically Enhanced Naturally Occurring Radioactive Material (TENORM).” Presentations addressed the following pertinent components of the document: practical tools available for solid waste disposal facilities accepting TENORM waste; radiation basics; common sources of radioactive materials; regulatory complexities associated with TENORM; and a case study on Montana’s TENORM regulations.
Radioactive material is found naturally in water, soils and rock. When this type of radioactive material is found in its original location and in its natural concentration distributions (including ore bodies) it is referred to as Naturally Occurring Radioactive Material (NORM). Many industrial processes use or come in contact with natural raw materials that contain NORM such as ore, water, soil, rock, oil and natural gas. When industrial processes separate or concentrate the NORM found in these raw materials and expel this radioactive material in their waste streams, the resulting concentrated NORM is referred to as Technologically Enhanced Naturally Occurring Radioactive Material (TENORM). The intent of this guidance document is to increase awareness regarding TENORM waste generation, as well as the regulatory and radiological complexities surrounding appropriate and protective TENORM waste management methods.
This document was originally posted December 18, 2017 but has since been updated as of February 15, 2018.
Between 2011 and 2012, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO’s) Radiation Focus Group developed three reference documents on naturally-occurring, radioactive materials (NORM). The first, Incidental TENORM: A Guidance for State Solid Waste Managers (April 2011), provides information to inform solid waste managers about technologicallyenhanced, naturally-occurring, radioactive materials (TENORM), including an introduction to these materials, toxicity, waste generation, and disposal. This guidance document was followed up by the release of two fact sheets: TENORM Associated with Drinking Water Treatment (May 2011) and TENORM Associated with Shale Gas Operations (July 2012).