Thompson & Pugsley, Practice Areas
NORM and TENORM
The regulation of NORM and so-called TENORM - radioactive isotopes outside the AEA jurisdiction -- is continually evolving and has important implications for industrial minerals outside the nuclear industry. U.S. regulations governing possession, use and disposal of NORM and TENORM are inconsistent, with some states moving ahead of others in developing regulations more or less borrowed from the Conference of Radiation Control Program Directors' model TENORM rules. Because of the significant differences in how NORM (or TENORM) is currently regulated by the states, EPA, DOT and international regulatory authorities, industrial minerals interests having a NORM component (e.g., titanium, zirconium, petroleum, natural, gas, copper and rare earths) face substantial uncertainty with regard to potential regulatory and civil liabilities attendant to their products, by-products and wastes. The firm has represented a broad array of clients involved in the mining, manufacturing, use and re-use of industrial minerals having a NORM or TENORM component.