NARM: Naturally-Occurring and Accelerator-Produced Radioactive Material

Naturally-occurring and accelerator-produced radioactive materials, or NARM, are regulated separately from low-level waste. This 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. 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 includes several key events. In 1986, DOH adopted its first regulation for 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 of 2005, DOH adopted amendments to WAC 246-249 WAC establishing the 100,000 cubic foot per calendar year site limit for diffuse NARM. Since 2005, the facility has disposed of a total of 27,639 cubic feet of diffuse NARM.

Based on records since 1992, annual NARM volumes (includes both diffuse and discrete) have ranged from a high of 77,000 cubic feet in 1995 to a low of 3,437 cubic feet in 2009. Overall, NARM has averaged about 16,000 cubic feet per year. However, since 2000, the average volume of NARM disposed at the facility has been 6,400 cubic feet per year. NARM accounts for 2% of the total volume and less than 0.01% of the activity (approximately 482 curies) disposed at the facility.