PEP-2B.
Revisiting and Redefining TENORM for the 21st Century PV Egidi*, U.S. EPA
Abstract: This PEP will cover the evolution of the definitions and regulation of naturally occurring radiation and radioactivity. The various definitions of NORM (naturally occurring radioactive material) and TENORM (technologically enhanced NORM) have not evolved with current polices and science. A revised and expanded definition of TENORM is presented with suggested justification for going forward with the changes. The legal framework for controlling radioactivity based on the Atomic Energy Act (AEA) is a Cold War relic; it is suggested that it should be revisited, since the AEA only addresses the nuclear fuel cycle. Publications and policies recommended by ICRP and NCRP over the recent past have added NORM/TENORM to the scope of radiation protection. ICRP recommends NORM should be regulated using a graded approach. Current IAEA recommendations call for member states to identify industries impacted by NORM, and conduct inventories of volumes and concentrations generated, along with exposure data for workers, none of which are federally required at this time; unlike radioactivity and radiation regulated under the Atomic Energy Act. The IAEA looks through the lens of the United Nations Sustainable Development Goals with respect to reuse and remining of tailings, which can have a radiological component. The U.S. is also revisiting it’s policies with respect to critical minerals. States have the major responsibility to protect public health but are not funded enough and do not have the bandwidth to take on legal challenges from multiple industries; therefore, the aspirational suggestion here is that EPA take the lead and federally regulate the management (including reuse) and disposal of TENORM, perhaps in the solid waste regulations. Those programs can then be delegated to the states along with appropriations to stand up the programs.
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