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TENORM is on the Regulatory Agenda in Multiple States

Technologically enhanced naturally occurring radiological material, or TENORM, has moved onto the regulatory and legislative agendas in multiple states. TENORM is material that contains naturally occurring radioactive elements, such as uranium, thorium, or radium, that have been concentrated or brought into waste streams as a result of human activities.

Although there is no national regulatory framework for handling TENORM, piecemeal regulatory updates by individual states have recently been promulgated as states have become aware of the potential presence of TENORM in waste streams from the energy, paper and pulp, phosphate fertilizer, and sewage treatment sectors. For example, legislative bodies in Pennsylvania and North Dakota have enacted new regulations pertaining to levels of radioactivity for the handling and disposal of certain TENORM wastes. Other states, such as Colorado, Kentucky, Montana, and West Virginia, are either in the process of gathering information or developing new regulations. The evolving regulatory landscape surrounding TENORM could potentially affect multiple stakeholders in various industrial sectors.

Evaluating the impacts of new or proposed regulations requires an understanding of the factors that generate TENORM in different types of waste as well as background levels of radioactivity. TENORM content can vary considerably depending on the waste source (e.g., pipe/tank scale, waste phosphogypsum, or combustion residuals). Moreover, consideration of local background radioactivity levels can be important for interpreting TENORM concentrations in those wastes at specific sites. Gradient has experience providing scientific comments on proposed regulations, evaluating the TENORM content of wastes, assessing radiological risks, and evaluating appropriate remediation alternatives. If you would like to discuss these issues further, please contact one of our scientific experts listed below.

Andrew B. Bittner, M.Eng., P.E.
Principal Scientist
abittner@gradientcorp.com

Thomas Lewandowski, Ph.D., DABT, ERT, ATS
Principal
tlewandowski@gradientcorp.com

Samuel A. Flewelling, Ph.D.
Principal Scientist
sflewelling@gradientcorp.com

Christopher M. Long, Sc.D., DABT
Principal Scientist
clong@gradientcorp.com

Kurt Herman, M.Eng., P.G.
Principal
kherman@gradientcorp.com

Matt Tymchak, M.S.
Senior Hydrologist
mtymchak@gradientcorp.com

  Peter A. Valberg, Ph.D., ATS
Principal
pvalberg@gradientcorp.com

Gradient is an environmental and risk sciences consulting firm renowned for our specialties in Toxicology, Epidemiology, Risk Assessment, Product Safety, Contaminant Fate and Transport, Industrial Hygiene, Geographic Information Systems, and Environmental/Forensic Chemistry. We employ sound science to assist national and global clients in resolving their complex problems relating to chemicals in the environment, in the workplace, and in consumer products.