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Naturally-Occurring and Accelerator-Produced Radioactive Materials (NARM) Naturally-occurring and accelerator-produced radioactive materials (NARM) are regulated separate from low-level waste. NARM is primarily radium contaminated waste that includes medical and industrial radium sources, soils with natural radium, and deposits made by oil and gas inside refinery pipes and well casings. NARM is defined as either diffuse or discrete. Diffuse NARM includes wastes such as pipe scale from routine maintenance on oil and gas pipelines, soils from the cleanup of mineral processing sites, and laboratory trash from the production of accelerator produced pharmaceuticals. Almost all discrete NARM comes from measuring devices, gauges, and radium needles used in medical procedures. Both types of NARM are disposed at the commercial LLRW site. The commercial LLRW facility accepts NARM waste from throughout the country, and in one case, has accepted NARM from a foreign country. NARM wastes are not regulated by any federal agency. NARM is not subject to the Low-Level Radioactive Waste Policy Amendments Act and therefore disposal is not restricted to states in the Northwest and Rocky Mountain Compacts. The history of NARM regulation in Washington State includes several key events. In 1986, DOH adopted its first regulation with regard to NARM disposal. In July 1995, DOH adopted amendments to WAC 246-249-080 that limited individual generators of diffuse NARM to 1,000 cubic feet per year and created a site limit of 8,600 cubic feet per year. In September 1995, US Ecology filed a civil suit against DOH contesting the 8,600 cubic foot limit. On May 15, 1996, DOH entered into a settlement agreement with US Ecology whereby DOH agreed to initiate rulemaking to consider a 100,000 cubic foot disposal limit for diffuse NARM with no individual generator limit. The court entered an order staying the 1995 amendments and requiring DOH to initiate rulemaking to adopt the 100,000 cubic foot limit. DOH issued an Environmental Impact Statement (EIS) in 2004 that supported an annual NARM limit of 100,000 cubic feet per year. In December 2005, DOH adopted amendments to WAC 246-249 establishing the 100,000 cubic foot limit for NARM. The effective date of the rule was postponed until August 15, 2006 pending a court decision on the recently adopted Cleanup Protection Act which may affect the commercial site. The 100,000 cubic foot limit established in the 1996 settlement agreement will remain in effect until the effective date of the rule. Based on the past ten years of records, annual NARM volumes have ranged from a high of 77,000 cubic feet to a low of 3,815 cubic feet. Overall, NARM has averaged less than 30,000 cubic feet per year. NARM accounts for 2% of the total volume and less than 0.01% of the activity (approximately 255 curies) disposed at the facility. |
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