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OSWER 9200.5-144
EPA 540-R-94-038
PB94-963414
October 1996
Buperfjnd
wEPA
Removal Response to Radiation
Sites: Reference Document
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Publication 9200.5-144
EPA-540/R-94/038
PB94-963414
October 1996
Removal Response to Radiation Sites
Reference Document
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
United States Environmental Protection Agency
Office of Solid Waste and Emergency Response
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Table of Contents
1.0 Introduction
1.1 Purpose of the Document 1
1.2 Should the EPA Respond? 1
1.3 What is Different About a Radiation Response? 2
1.4 The Regional Radiation Program 3
2.0 Radiation Releases and Superfund Response
2.1 Radioactive Materials and Wastes 4
2.2 CERCLA and Radiological Releases 4
2.3 Radioactive Materials at Superfund Sites 5
2.4 Radon and Other Naturally Occurring Materials 7
2.5 Catastrophic Disasters 7
3.0 Worker Safety Issues
3.1 Radiation Hazard Assessment 9
3.2 Special Precautions and Procedures for Site Entry 9
3.3 Personal Protection 10
3.4 EPA Radiation Safety and Health Program 10
3.5 Training 10
3.6 Reference 11
4.0 Conducting Removals at Radiation Sites
4.1 Site Evaluation Issues 13
4.2 Site Surveying and Sampling 14
4.2.1 General Area Survey 14
4.2.2 Detailed Contamination Survey and Sampling for Contamination 15
4.2.3 Instrumentation for Surveying and Sampling 16
4.3 Decontamination 17
4.4 Cleanup and Treatment Issues 17
4.4.1 Mixed Waste 18
4.4.2 Cleanup Levels 18
4.5 Waste Transportation and Disposal 19
4.5.1 Transportation Issues 19
4.5.2 Radioactive Waste Disposal Issues 19
4.5.3 References 19
5.0 Available Assistance
5.1 Regional Radiation Programs 21
5.2 Environmental Response Team 21
5.3 Headquarters Office of Radiation and Indoor Air 21
5.4 EPA Radiological Monitoring Laboratories 22
5.5 Additional Assistance 23
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Table of Contents (cont'd)
Figures
Figure 1: Categories of AEA Wastes 6
Figure 2: Limits of OSC Authority 8
Figure 3: Sources of Assistance 23
Tables
Table 1: Regional Radiation Program Offices 22
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1.0 INTRODUCTION
1.1 Purpose of the Document
Currently, only a small proportion of Superfund removal sites contain radioactive materials.
However, the number of these sites has been steadily increasing and will probably continue to rise.
This will present On-Scene Coordinators (OSCs) with unique challenges and considerations. This
guide provides OSCs and site managers with sources of information and guidance to address
radioactive materials incidents.
It is not possible to write a comprehensive radiation removal reference document which covers all
site eventualities and obviates the need for expert assistance. Since radionuclides are not encountered
very frequently and since site conditions can vary considerably, each radiation contamination site
must be dealt with on a case-by-case basis.
Therefore, this document does not provide the OSC with specific procedures for identifying, treating,
and removing radionuclides. The expertise of a radiation specialist is highly recommended1 when
initiating action at a site where radioactive materials are believed to be present. Necessary
emergency actions, of course, should always be performed as quickly and safely as possible.
The purpose of this document is to provide references and a planning guide for removal actions
involving radioactive materials. This document includes:
• Information on the differences between a radiation site and a hazardous waste site without
radioactive contamination;
• A statement of the relevant issues for responding to a radiation release, and references to
detailed technical information;
• A guide to the response planning process as it relates to radiation;
• Assistance available to OSCs and site managers in dealing with radiation sites; and
• Information about radiation-related training.
1.2 Should the EPA respond?
Before commencing incident/site response, the OSC must determine if a Superfund response is
appropriate or authorized. Generally, radioactive materials are considered "hazardous substances"
under CERCLA and as such, qualify for Superfund cleanup. However, certain radioactive materials
are specifically excluded from CERCLA, or in some cases authority to respond may have been
delegated to an agency other than EPA. Situations involving these materials are to be handled under
the Federal Radiological Emergency Response Plan.2
Specific exclusions and situations are discussed in chapter 2, but, as a general rule, an OSC should
check further if either of the following general conditions apply to the site or incident:
1 See chapter 5 for sources of radiation expertise.
2 See sections 2.2 and 2.4 of this document.
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1. The facility is (or was) licensed by the Nuclear Regulatory Commission (NRC) or an NRC
Agreement State, is (was) regulated by the Department of Energy, or is (was) regulated by
an NRC Agreement State.3
2. The materials are high-level or transuranic wastes,4 or wastes from energy production or
weapons production.
Under CERCLA, EPA has the authority to respond if the release meets the legal definition [of a
release]; even though the site may meet either of the above conditions. However, depending on the
nature of the release, there may be other agencies that are better suited to respond. The OSC should
contact the National Response Center at 800-424-8802 or (DC) 202-267-2675 for appropriate
information on which agency to contact for assistance.
1.3 What is Different About a Radiation Response?
Response to radiation contamination is, in most ways, the same as response to other hazardous
substances. Many response procedures used for chemical contaminants are also used for radioactive
contaminants (e.g., protective clothing, respiratory protection, personnel surveillance, delineation
of controlled entry areas). While the instrumentation used for radiological monitoring is different
from that used for chemical monitoring, the basic approaches of ambient monitoring, media
collecting, etc., are intrinsically similar. Laboratory analyses can be done either in the field or at
a fixed site, as with hazardous contaminants. Treatment, storage, cleanup, transportation, and
disposal options are often similar to those for chemicals.
Radiation is not necessarily more complex, difficult, or dangerous than chemical contamination. In
fact, radiation can be easier to detect, simpler to control, and less hazardous than many other
materials. Many direct-reading instruments, for example, can give instantaneous results when
monitoring for radiation. Radiation can often be detected without having to open drums or enter
confined spaces. The health effects of radioactive materials are generally better documented than
those of other hazardous substances. Acute effects are unlikely to occur with the type of radioactive
materials found on a Superfund site.
On the other hand, radiation presents threats that are intrinsically different from most chemical
hazards. The nature of contamination is different and the procedures to deal with radiation sites
(such as site evaluation, monitoring, and sampling) vary from those for most other sites. There are
special considerations for treatment, cleanup, storage, transportation, and disposal of radioactive
wastes.
This document is meant to alert the OSC to the unique problems, dangers, precautions, procedures,
and constraints posed by radioactive materials.
3 NRC has delegated regulatory authority to certain State agencies in the Agreement States.
4 Transuranic (TRU) wastes are materials contaminated with elements that have an atomic number greater than 92,
including neptunium, plutonium, americium, and curium, and that are in concentrations greater than 10 nanocuries per gram.
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1.4 The Regional Radiation Program
EPA's Regional Radiation Program is a prime resource for OSCs to obtain technical support on
issues dealing with radiation exposure and contamination. The Regional Radiation Program Manager
(RRPM) can provide advice on personal protective equipment, site safety protocols, assessment and
sampling techniques, waste treatment and disposal, and other site operations. The RRPMs are also
familiar with the staffs and procedures at the laboratories and EPA's Office of Radiation and Indoor
Air (ORIA). They can help speed the removal process and achieve the best results for the OSC.
A listing of phone numbers of RRPMs appears in chapter 5.
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2.0 RADIATION RELEASES AND SUPERFUND RESPONSE
2.1 Radioactive Materials and Wastes
Radioactive material is defined as any material that contains, is composed of, or is contaminated with
elements that spontaneously undergo radioactive decay (i.e., radionuclides). Radioactive materials
(and the waste and contamination associated with the production and use of such materials) are
generally categorized based on their origin and composition. The principal categories are defined
by statute, although a number of interchangeable and different terms are often used in practice (see
section 2.3 and Figure 1).
2.2 CERCLA and Radiological Releases
In general, radioactive materials are a hazardous substance under CERCLA and are subject to
CERCLA's notification, cleanup, and liability provisions. In terms of legislative authority, therefore,
radionuclides are considered like any other hazardous substance on site. However, CERCLA
response authority does not apply to sites falling within the following categories at specific facilities:
• Releases of radioactive wastes from uranium mill tailings that are being cleaned up by the
Department of Energy under Title I of the Uranium Mill Tailings Radiation Control Act.5
• Releases of "source, special nuclear, and byproduct materials" resulting from a nuclear
incident at private commercial facilities that are subject to the financial protection
requirements established by the Nuclear Regulatory Commission.6
However, releases under these categories account for a small portion of radiation releases in general.
Source, special nuclear, and byproduct materials are often referred to as "AEA wastes or material."
These are radiological materials associated with the production of nuclear energy that are given
special status by the Atomic Energy Act (AEA). In general, response to releases of these materials
is handled by either the Department of Energy (DOE) or the Nuclear Regulatory Commission
(NRC). Figure 1 provides brief descriptions of several types of AEA wastes.
If AEA materials are encountered on site, OSCs and site managers should contact the RRPM for
information about the proper agencies to contact and CERCLA eligibility.
2.3 Radioactive Materials at Superfund Sites
Radioactive wastes that are discovered at Superfund sites may consist of either AEA wastes, non-
AEA wastes, or both. However, since some AEA wastes are specifically excluded by CERCLA,
Superfund response is generally limited to non-AEA wastes (also known as naturally-occurring or
5 CERCLA §101 (22)(C)
6 CERCLA §101 (22)(C). CERCLA also restricts cleanup authority by excluding these materials specifically in the
definition of a release (§101).
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AEA Wastes
The following categories of radioactive material
and wastes are given special status under AEA
§2010 and §2011. CERCLA §101 (22)(C)
excludes these materials from the definition of
"release," limiting Superfund authority to
respond.
• Source Material — natural uranium, thorium,
or any combination thereof, in any physical
or chemical form, or ores that contain 0.05
percent or more (by weight) of uranium,
thorium, or any combination of the two.
• Special Nuclear Material — plutonium,
uranium-233, uranium enriched in the U-233
or U-235 isotope, and any other material that
the Nuclear Regulatory Commission,
pursuant to the provisions or §51 of the
AEA, determines to be special nuclear
material.
• Byproduct Material — any radioactive
material (except special nuclear material)
yielded in, or made radioactive by, exposure
incident to the process of producing or
utilizing special nuclear material; and the
tailings or wastes produced by the extraction
or concentration of uranium and thorium
from ore processed primarily for source
material content, including discrete surface
wastes resulting from uranium solution
extraction processes. Underground ore
operations do not constitute "byproduct"
material within this definition.
1. Any radioactive material produced
as a result of nuclear
transformations in an accelerator.
2. Naturally-occurring (not man-made)
radioactive material, excluding
source and special nuclear material
(NORM).
NORM can be further categorized based on
whether the radioactive materials are found
in their natural setting or whether they are
found in an altered or man-made setting.
This distinction is important because there
are additional CERCLA exclusions for
naturally-occurring substances found in their
natural settings (see section 2.4).
Examples Superfund response at NARM-
contaminated sites include: facilities or
laboratories that handle radium needles for
medical applications; radium refining
facilities; formulators of industrial
radiographics and radiochemicals;
manufacturers of X-ray equipment and
radiation detection equipment (calibration
materials); metal processing facilities; mine
tailings piles; landfills; and midnight
dumps. Often, there are responses at
associated facilities, residences, and
properties that have radiation contamination
because of poor housekeeping practices at
the primary facilities (listed above). For
example, a typical site might consist of an
abandoned factory that previously
manufactured watches with
radioluminescent faces and dials. Not only
is the facility itself contaminated, but
contamination is often found off site as well. An associated site might be a nearby residence where
a former employee of the watch factory stored radioactive materials taken from the job.
accelerator-produced radioactive materials
(NARM)). As implied by the name,
NARM consists of the following two
subsets of materials:
Figure 1: Categories of AEA Wastes
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2.4 Radon and Other Naturally Occurring Materials
CERCLA excludes response to releases of "a naturally occurring substance in its unaltered form ...
from a location where it is naturally found."7 This exclusion is cited most frequently during
responses to radon contamination, where the radon originates from natural radioactive formations
in the ground. This doesn't prevent EPA from responding to radon resulting from radioactive
materials placed on a site (i.e., not naturally occurring.)
The exclusion may be waived in certain emergency conditions, with Headquarters concurrence.8
To respond to radon, there must be a finding that:
1. The release is causing a public health or environmental emergency, and
2. No other person or agency with the authority and capability to respond to the emergency will
do so quickly enough.
If this situation comes up, the OSC should consult with the Regional Coordinator at EPA
Headquarters for information about the waiver.
2.5 Catastrophic Disasters
If cleanup is conducted under the authority of CERCLA, then any response to the radionuclide
release is carried out in accordance with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), just as with any oil spill or other hazardous substance release.
Under disaster conditions meeting the criteria for a Presidential declaration, other response
mechanisms are more appropriate, or are used in addition to CERCLA and the NCP. These include
incidents such as: major releases at nuclear reactors; releases associated with the manufacture,
transport, testing, and use of nuclear weapons; accidents or releases involving nuclear fuel or high-
level radioactive wastes; and incidents involving nuclear-powered satellites. In such cases, EPA
should act under other response mechanisms, which generally fall outside the scope of Superfund and
are covered only briefly below. In such a disaster, EPA will be working under the FRERP (Federal
Radiological Emergency Response Plan),9 which was established in 1985 as an interagency planning
and response guide to direct Federal agencies during responses to peacetime radiological disasters.
The FRERP covers any peacetime radiological disasters that require response by several Federal
agencies, including those at fixed nuclear facilities or during transportation of radioactive materials.
Depending on the type of radiological emergency, EPA may be the lead agency for coordinating the
Federal response in accordance with the provisions of the FRERP. The EPA is the lead agency for
(1) emergencies at radiological facilities not licensed, owned, or operated by a Federal agency or an
Agreement State; (2) transportation emergencies that involve radioactive material not licensed or
owned by a Federal agency or an Agreement State; and (3) emergencies that involve radioactive
7 CERCLA §104 (a)(3)(A).
8 See OSWER Directive 9360.0-19, Guidance on Non-NPL Removal Actions Involving Nationally Significant or Precedent-
Setting Issues, and OSWER Directive 9360.3-12, Response Actions at Sites with Contamination Inside Buildings.
9 As required in the NCP §300.130 (f).
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Figure 2: Limits of OSC Authority
material from a foreign source (e.g.,
Chernobyl, foreign satellite) that has actual,
potential, or perceived radiological
consequences in the United States, its
Territories, or possessions. Besides its role
as lead agency, EPA will act in a
monitoring and technical support role to
other lead Federal agencies. In the event of
such peacetime radiological emergencies,
EPA's activities will be directed by
specialists from the Office of Radiation and
Indoor Air (ORIA).
EPA activity under the FRERP is guided by
the EPA Radiological Emergency Response
Plan. This plan discusses EPA's specific
authorities, procedures, resources,
organization, responsibilities, and capabilities for responding to radiological emergencies either as
an independent agency or as a participant in the implementation of the FRERP. Figure 2 provides
general limits of OSC authority for radiation sites.
As a general rule, the OSC's responsibility
and/or authority to respond is limited if:
1. The facility is owned by DOE or DOD.
2, The release is from a facility licensed by fee
NRC or an NRC Agreement State (e.g., a
nuclear power plant or A research facility).
3. The waste is an AEA waste.
4.
There has been a disaster declaration, or
FRERP has been implemented.
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3.0 WORKER SAFETY ISSUES
3.1 Radiation Hazard Assessment
An initial radiation assessment should be performed in conjunction with initial site entry at any site
containing unknown materials. As with hazardous chemical substances, it is important to determine,
as soon as possible, whether radionuclides are present on site. Prior to any work being conducted
on site, perform a thorough areal survey using appropriate radiation detection equipment (see section
4.2.3). Using this survey information, the RRPM can assist in the interpretation and characterization
of both surface contamination and buried waste.
Most radioactive material encountered at Superfund sites can be considered an internal hazard (i.e.,
internal contamination through ingestion, inhalation, entry through open wounds, or from dermal
absorption). As such, it can present a significant health risk. In addition, much of the radioactive
material encountered at Superfund sites is also an external hazard (i.e., it does not require direct
contact to be hazardous). Alpha radiation is typically only an internal hazard through ingestion since
it does not have enough penetrating ability to pass through the body's outer layer of dead skin cells.
However, alpha particles with energies greater than about 7.5 MeV will penetrate the skin to
underlying tissue. Both uranium and thorium decay series have alpha particles with energies this
high. Therefore, digging in uranium, thorium, or radium-contaminated soil might lead to increased
dermal exposure as well as internal exposure to alpha particles. Beta particles can penetrate the outer
layer of skin and the lens of the eye. Gamma is high energy radiation and can readily pass through
the body. All of these types of ionizing radiation can damage cells.
If "labpack" quantities of suspected radioactive substances are present at the site, the OSC should
ensure that a complete radiological survey of the containers is made using appropriate surveying
equipment. The RRPM can assist the OSC in determining which laboratory substances may require
special attention as radioactive substances.
Once the types of radiation hazards and levels of contamination are known, specific control measures
can be employed to minimize both internal and external exposure to site workers. These measures
include: minimizing the time spent in a radiation-contaminated area; increasing the distance from
the source of radiation; using proper shielding to control external hazards; using personal protective
equipment; and implementing source and environmental controls to minimize internal hazards.
3.2 Special Precautions and Procedures for Site Entry
Prior to a response, selection of the proper equipment and survey instruments is extremely important
to assess the site adequately and protect workers. For example, a scintillation detector will easily
detect contamination at near-background levels but only for gamma radiation. A Geiger-Muller
(GM) detector may have difficulty detecting background gamma levels that indicate soil
contamination but can be used to monitor worker exposure levels where beta particles are of concern.
The RRPM or a health physicist should be consulted regarding monitoring needs.
Necessary equipment may include respirators with the appropriate radionuclide cartridges,
thermoluminescent dosimeters (TLDs or radiation badges) for monitoring individual exposure levels,
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and portable field radiation detection instruments, including GM detectors, scintillation detectors,
and/or ionization detectors. Detailed information on survey equipment is presented in chapter 4.
Proper decontamination procedures are important to prevent radioactive material uptake into the
human body, to limit external radiation exposure, and to prevent further spread of contamination (see
section 4.3).
3.3 Personal Protection
Personal protective equipment should include respiratory protection with appropriate cartridges if
suspended (airborne) particulates are of concern. Coveralls, gloves, and overboots can provide
protection against skin exposure. Air monitoring can be conducted using air pumps and particulate
filters. The filters can be scanned for the presence of gross levels of radioactive particles or can be
further analyzed for concentrations by isotope. Since site activities (e.g., digging) may increase the
risk of exposure, additional steps may become necessary, on a site-specific basis, to ensure personal
protection.
Biological monitoring for determination of internal exposure can include urinalysis, whole body
counting, nasal smears, and/or fecal analysis. External exposure can be measured with TLDs, film
badges, and/or direct-reading pocket dosimeters.
Specialists, like the RRPM or staff from ORIA, can function as OSC representatives or Health and
Safety Officers, as per 40 CFR §300.120 (h)(2). They can assist in determining the appropriate
personal monitoring needs for radiation safety concerns.
3.4 EPA Radiation Safety and Health Program
EPA 1440, Occupational Safety and Health Manual, documents the Agency's Radiation Safety and
Health Protection Program. This program implements policy and procedures for minimizing
exposure of EPA workers to ionizing radiation by defining exposure monitoring and safety training
requirements. The Standard Operating Procedure (SOP), "Radiation Safety and Health Practices for
Field Work," establishes guidelines for health and safety practices at Superfund and other sites.
3.5 Training
The Radiation Safety and Health Protection Program requires that dosimetry monitoring and basic
safety training be provided to each worker required to enter areas where there is potential for
radiation exposure above normal background levels. Additionally, advanced radiation safety training
is required for personnel who routinely work in radiation areas, and for supervisors of all workers
requiring dosimetry monitoring. For information about training and dosimetry, consult with the
Regional or Program Safety, Health, and Environmental Management Program (SHEMP) Manager,
or the RRPM.
All workers on a radiation site should receive some site-specific training designed specifically for
the individual site. Typical training should cover such topics as the nature and health effects of
ionizing radiation, prenatal radiation exposure, exposure limitations, and basic protective measures.
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3.6 Reference
EPA 1440, Occupational Safety and Health Manual, "Radiation Safety and Health Practices for Field
Work."
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4.0 CONDUCTING REMOVALS AT RADIATION SITES
4.1 Site Evaluation Issues
The primary objective of a site evaluation, either for chemical contaminants or for radionuclides, is
to determine whether there has been a release or if there is a threat of release of hazardous
substances. For chemical contaminants, rather than searching for the existence of any of the universe
of possible contaminants, the assessment frequently begins by narrowing down the target parameters,
if possible. The assessment is directed toward searching for those contaminants that are most likely
to be present, based on the site history or actual site conditions. This is appropriate when the risk
of a mistake (i.e., exposure) is relatively low, and the cost of testing for all contaminants is high.
During the assessment, a subset of the total number of samples usually undergoes confirmatory (or
full parameter) laboratory analysis to check whether the initial assumptions are correct. If at any
time during the site evaluation unexpected contaminants are detected or suspected to be present, then
response actions are adjusted accordingly. For example, if containers marked "cyanide" are
unexpectedly found during the initial site evaluation, then the sampling plan, health and safety plan,
and other response actions are adjusted to account for the actual or potential presence of cyanide.
This fairly conservative procedure is typical for sites where the anticipated hazardous substances are
other than radiation.
During the initial site evaluation, a radiation survey is required by the Occupational Safety and
Health Act (OSHA) at every site10. Although not necessarily more dangerous than chemical
contaminants, radiation is not visible to the naked eye and can affect site workers some distance from
the source. As such, initial site evaluation procedures for radionuclides detection assume that
radiation contamination is present in some form. An initial site survey might be fairly simple and
might consist of a gamma radiation survey only. This will be sufficient to detect most hidden
hazards in order to protect site workers, it will detect many but not all radionuclides, and is easy and
inexpensive to perform. Gross alpha and beta laboratory analysis can be run on selected samples
to detect alpha and beta sources which are not picked up in the initial survey. If radionuclides are
detected, then just as for chemical contaminants above, response actions are adjusted accordingly.
Note that negative survey results can be just as useful as positive ones when conducting a site
evaluation.
If the survey reveals the presence of radioactive materials, or if EPA is notified of a release (or
threatened release) of radioactive materials, the OSC should notify the RRPM. The RRPM can
supply the OSC with important information for a more comprehensive assessment, including personal
protective equipment, recommended surveillance equipment, and suggestions on other safety issues
necessary for site entry. The radiation program may already be aware of the site and might be able
to provide the OSC with site-specific information. A list of phone numbers of Regional Radiation
Program Offices appears in chapter 5.
10 OSHA 1910.120 (c)(6)(i)
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Initial Information
If the site is known or suspected to be radiologically contaminated, review all existing data about the
site to determine (1) the type of hazard present, (2) the level of contamination, and (3) potential
exposure to site workers. A health physicist or the RRPM will use this information to ensure that
workers' exposure to radiation is maintained at levels that are as low as reasonably achievable
(ALARA). Following notification of a threat, it is important to secure information about the site or
incident. For a release of radioactive materials, it is important to answer the following questions:
• Is there immediate danger, or is the situation stable? Should evacuation of surrounding
populations be considered?
• Have radiation measurements been taken? If there has been a release, what is the quantity?
• What radioactive materials are involved?
• Are there labeling or shipping papers that contain information?
• Are there shielded containers? In what condition are they?
• Is the site owned, operated, or licensed by DOE or DOD? Is the site regulated by DOE,
NRC, NRC Agreement State, or solely by the State? If so, those agencies have primary
responsibility (see chapter 2). Have they been notified? Are they responding?
Based on the information obtained in a preliminary assessment, consult the Regional Decision Team
about the appropriate action (early action, long-term action, etc.). These decisions may need to be
based on information collected during a more thorough site evaluation.
4.2 Site Surveying and Sampling
Site radiation monitoring generally occurs in two phases, a general area survey and a detailed
contamination survey. First, a general area survey is performed to find any radiation threat. If this
survey indicates the need (e.g., a threat is detected or more information is necessary), a more
detailed contamination survey is performed. Investigation during either phase can help to locate
airborne plumes, determine background radiation levels, and locate radiation areas close to the site.
Since radiation sampling involves greater expertise and knowledge of the methods and procedures
for acute site characterization than radiation survey techniques, the RRPM or other trained
individuals should be consulted to perform this phase of the investigation.
4.2.1 General Area Survey
A general area survey usually begins with a gamma detection sweep. Gamma is the most penetrating
form of radiation, the principal hazard to site workers, and the most detectable from the farthest
distances. Radionuclides are also usually readily detectable in air samples at ground level, and initial
air monitoring may provide the first indication of the presence and nature of radioactive
contamination. Be aware that radionuclides, even at high levels, will probably not be detectible
through or in surface water and/or ground water.
Once preliminary radiation levels are established, the OSC, in consultation with the RRPM, can
determine site safety precautions for site workers and the surrounding population. In the ERT
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Standard Operating Safety Guides, EPA has established the following guidelines for action:11
Less than twice gamma background Assume no radiation hazard is present.
Greater than three to five times background
but less than 1 mR/hr on contact
Above 1 mR/hour but less than 10 mR/hr
on contact
Above 10 mR on contact
There is probably radioactive material present
which could present a disposal problem, but
no immediate danger from external gamma
radiation. Obtain samples for radiological
analysis to see whether there is an ingestion
hazard.
There is the potential for a radiation hazard.
Consult a qualified health physicist before
disturbing or sampling the radioactive
material.
There is a radiation hazard present. Pull back
from the contaminated area and establish a hot
zone where the area gamma measurements are
2-3 mR/hr. This establishes a formal
radiation area and should be posted as such.
No one should enter the hot zone without
supervision of a certified health physicist,
appropriate badging, and other specific
radiation protection measures.
Background radiation levels for most Superfund sites can be determined by taking at least one
detector reading off site (i.e., outside the boundary but in the proximity of the site). Multiple
background readings can also be taken at several locations and then averaged. Note: Background
levels should be established away from high-energy electronic equipment, power lines, large rocks
and boulders, road-fill materials, direct sunlight, sources of electro-magnetic waves, and other
potential sources which can interfere with the direct-reading instrument's circuits or its ability to
measure naturally-occurring or manmade radiological substances.
Based on the initial monitoring data, the OSC in consultation with the Radiation Program Manager
can answer the following questions: Is evacuation of local residents necessary? Can a hot zone be
delineated? Can clean areas and decontamination areas be set up safely? Where might appropriate
sampling points for further investigation be located?
4.2.2 Detailed Contamination Survey and Sampling for Contamination
After the general area survey indicates the presence of radionuclides, a detailed contamination survey
is conducted. The purposes of the detailed survey are to:
1. Confirm the specific radionuclide(s) present and the concentration.
11 OSWER Directive 9285.1-03.
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2. Locate specific sources of radiation and hot spots.
3. Define the extent and boundaries of areas of contamination.
Sampling methods for radionuclides are similar to those for sampling other types of contaminants,
but there are some special sampling considerations involving:
• The media to be sampled
• Sampling collection and storage equipment
• The filtration of water samples
• The volume to be sampled
• The selection of ecological samples
Determine on-site levels of contamination by direct counting with a radiation detector, by wipe or
smear testing, and by air sampling. Gamma surveys should be conducted at ground level (for
maximum detection) and at one meter above ground level for dose and risk assessment purposes.
Since alpha and beta radiation do not travel far from the emitting source, the sweep for specific
sources is conducted with the detector or detector probe placed within one inch of potentially
contaminated surfaces. A more detailed contamination survey, therefore, is more time-consuming
and labor-intensive than the general area survey (or gamma survey). The information collected from
a detailed contamination survey can be used to formulate a more comprehensive assessment strategy,
and to begin mapping hot zones and areas of varying site contamination. Such a map, set out on a
grid, would ideally include sectors noting varying rates of exposure throughout the hot zone.
Consult a health physicist and/or the RRPM for the selection, application, and interpretation of
sampling methods and results for radionuclides.
4.2.3 Instrumentation for Surveying and Sampling
An initial gamma detection sweep is usually performed with a hand-held radiation meter(s) using
either gamma scintillation probes, Geiger-Miiller (GM) detectors, or ionization chambers. When
choosing an instrument, remember that each type of detector has different sensitivities and responses
to alpha, beta, and gamma radiation; the instruments are also susceptible to electromagnetic waves
and interference from temperature extremes and humidity.
Scintillation detectors, using materials such as zinc sulfide crystals for alpha detection or sodium
iodide crystals for gamma detection, are highly sensitive instruments. A microR meter with a
sodium iodide crystal can measure extremely low levels of gamma radiation (in the microRoentgen
per hour range). This portable instrument is an excellent choice for an initial field survey (provided
it is used properly and the sensitivity of the instrument does not give inaccurate or misleading results
from other interference sources).
For area monitoring, one of the most common portable field instruments is the GM detector, which
is used to measure exposure rate. GM detectors are particularly useful for obtaining relative
comparisons rather than absolute numerical levels. GM detectors with thin windows are sensitive
to beta radiation and to alpha radiation (if the window is thin enough), but are relatively insensitive
to gamma radiation. Gas proportional counters are especially good for alpha radiation.
Thermoluminescent dosimeters (TLDs) can be left on site for short-term or long-term gamma
exposure assessment. Radon monitors can be left indoors for short-term or long-term radon
assessment. Ionization chambers are primarily used for beta and gamma radiation detection.
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All instruments must be properly calibrated at least once a year. Check sources should be used for
calibration, prior to surveying, to ensure proper instrument response in the field. Consult with your
RRPM before making a choice of instruments for general area surveys or detailed contamination
surveys.
4.3 Decontamination
It is generally easier to spread radionuclides off site, due to improper decontamination procedures,
than most chemical contaminants. Equipment and personnel decontamination procedures at radiation
sites, therefore, are likely to be even more stringent than those at chemically-contaminated sites.
Detailed radiation decontamination procedures are beyond the scope of this reference document; it
is recommended that a qualified health physicist be consulted when implementing a radiation
decontamination and control program for a site.
4.4 Cleanup and Treatment Issues
The two ways for mitigating the hazard of radioactive materials from a site are:
1. gross removal with off-site disposal at a licensed facility, or
2. on-site treatment and stabilization.
Historically, gross removal and off-site disposal is the most widely used method of disposal at
radiation sites. However, several options exist for on-site treatment of radioactive material, although
they may have limited use at most Superfund sites. These include capping, vertical barriers,
stabilization and solidification, and in-situ vitrification.
Capping consists of covering the contaminated area with a thick layer of low-permeability soil,
sometimes augmented with a liner system to further prevent infiltration of water. This option would
attenuate the radiation and protect the groundwater. However, capping does not eliminate the source
of radioactivity and severely limits further use of the site. The cap must be maintained as long as
the contaminant exists. Also, horizontal migration of the radionuclides in groundwater could still
occur.
Vertical barriers serve as subsurface barriers to horizontal migration of radionuclides and, more
important, as barriers to the horizontal movement of groundwater that may be contaminated with
radionuclides.
Stabilization and solidification immobilize radionuclides by trapping them in an impervious matrix.
The solidification agent (such as silica grout, or chemical grout) can either be injected directly into
the waste mass in situ or the waste can be excavated, mixed, and replaced. Care should be exercised
before using this treatment on site because it may reduce options for future disposal and it can
greatly increase disposal costs.
The in-situ vitrification process also immobilizes radionuclides by trapping them in an impervious
matrix, but the method is somewhat different from solidification. The in-situ process melts the waste
materials between two or more electrodes using large amounts of electricity; the melted material then
cools to a glassy mass in which the radionuclides are trapped. Again, care should be exercised
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before using this technology on site because vitrification can drive radon and other hazardous
substances and toxic gases from the soil out into the atmosphere; controls may be required.
Note that some common cleanup methods may also spread radioactivity. For example, air stripping
and soil gas evacuation would remove radon from the groundwater or soil concurrently with volatiles
and release it to the air. This activity might also concentrate radionuclides, such as radon and other
volatile gases, at a point source. Such treatment methods may trigger applicable or relevant and
appropriate requirements (ARARs) under other Federal or State standards or criteria. It is important
to note that charcoal collection media used for cleanup at a site containing radionuclides would
become a gamma source.
4.4.1 Mixed Waste
Mixed waste is waste that contains both RCRA hazardous waste and AEA waste (source, special
nuclear, or by product material — see section 2.2 of this reference document).12 Because of the
combined risks, mixed wastes often pose additional problems for treatment and disposal. Most
chemical and radiological waste disposal facilities will not accept mixed wastes for disposal. There
are only a few facilities that will accept mixed waste and their requirements can be very restrictive.
The problem may be simplified by eliminating one or the other (chemical or radiological)
contaminant from the waste stream. One treatment option which has been suggested is chemical
separation. Pyrolysis or distillation might eliminate a combustible component, leaving a simple
radwaste. A second treatment option might be chemical neutralization. For example, a radioactive
"acid" (characteristic hazardous waste) could be neutralized to form a radioactive salt and water.
Controlled evaporation could reduce the material to a radioactive, non-hazardous waste salt. A third
potential treatment method is fixation. This is where a mixed waste (such as a radioactive/ignitable
waste) could be "fixed" onto another "inert" waste, eliminating its hazardous waste characteristic.
The remaining radioactive material could then be disposed of at an appropriate radioactive waste
facility.
It is important that site workers refrain from mixing together materials with chemical and radiological
hazards during response operations thereby creating mixed wastes. Contact your RRPM, the
Emergency Response Team (ERT), or other specialists if confronted by these situations.
4.4.2 Cleanup Levels
No one cleanup level for a particular radionuclide or source of radiological contamination will be
applicable at every removal action site. Cleanup levels under investigation might include cleanup
thresholds or minimum standards to be addressed at a particular kind of Superfund site.
Furthermore, State ARARs may also play a role in the OSCs' decision-making process where
cleanup levels or standards have been established for particular radiological contaminants. Where
appropriate and attainable, such standards or cleanup levels might be more restrictive than existing
or proposed Federal requirements. Even though some cleanup goals may not be achievable as part
of a long-term Superfund cleanup, removal actions may address interim measures to control the
migration or spread of contaminants to the extent practicable (i.e., providing some measures to
reduce the threat to the public and the environment.)
12 SWDA §1004 (41).
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The Office of Radiation and Indoor Air (ORIA) is developing regulations for cleaning up sites
contaminated with radionuclides. The regulations will include cleanup levels for radioactive
contamination (how clean is clean?), disposal of investigation-derived wastes, and reuse/recycling
of radioactive wastes. For information, contact the Radiation Studies Division of ORIA at 202-233-
9340.
4.5 Waste Transportation and Disposal
Transportation and disposal of radioactive materials are subject to both Federal and State regulations,
and to the requirements of storage and disposal facilities. This section lists sources of such
information and other issues related to the transport and disposal of radioactive wastes.
4.5.1 Transportation Issues
The requirements for transporting radioactive materials are particularly critical. Any radioactive
material which spontaneously emits ionizing radiation and has a specific activity in excess of 0.002
microcuries/gram of material is subject to Department of Transportation (DOT) and Nuclear
Regulatory Commission (NRC) regulations. These regulations can be found in:
• 10 CFR Part 71 (NRC): "Packaging and Transportation of Radioactive Materials."
• 49 CFR (DOT) Part 173 Subpart I (for transportation of radioactive waste); also Part 177,
"Carriage by Public Highway;" Part 178, "Shipping Container Specifications;" and Part 179,
"Specifications for Tank Cars."
Be sure to contact the shipping company about its requirements for shipping radioactive materials.
4.5.2 Radioactive Waste Disposal Issues
Disposal of radioactively contaminated wastes is complicated not only by requirements of the Federal
government, State governments, and disposal facilities, but also by the reluctance of disposal
facilities to accept these wastes. Disposal facilities are often very reluctant to handle radioactive
waste streams even if the radioactive portion of the stream is too small to be considered mixed waste.
Regulations referring to on-site storage of wastes can be found in 10 CFR Part 20 and clarified in
NRC document NUREG-1101, "On-Site Disposal of Radioactive Waste." See also EPA regulations
in 40 CFR Part 191. NRC regulations referring to final disposal can be found in 10 CFR Parts 61
and 71.
4.5.3 References
Radiochemistry Procedures Manual, NAREL. EPA 520/5-84/006.
Measurement of Radionuclides in Food and the Environment, International Atomic Energy Agency,
Technical Reports Series, #295.
Sampling Surface Soils for Radionuclides, American Society for Testing Materials, Publication C-
998-83.
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Assessment of Technologies for Cleanup of Radiologicatty Contaminated Superfund Sites,
OERR/ORD, January 1990. OSWER Directive 9380.0-20; EPA Report 540/2-90/001; NTIS
#PB90-204140/CCE.
Forum on Innovative Hazardous Waste Treatment Technologies, OSWER/TIO, 1989. EPA Report
540/2-89/055; NTIS #PB90-268509/CCE.
ERT Standard Operating Safety Guides, OSWER Directive 9285.1-03.
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5.0 AVAILABLE ASSISTANCE
There are several sources of assistance available within EPA for radiological contamination
associated with Superfund sites. Programs, services, and training are available to cover virtually
every type of radiological emergency that Superfund personnel may encounter.
If the situation involves a potentially significant release of radioactive substances and an emergency
response, consult the Regional Response Team.
5.1 Regional Radiation Programs
Each EPA Region has a radiation program, with experts in nuclear engineering, health physics, and
other relevant skills. The Regional Radiation Program Manager is a dedicated source of
technical assistance to the OSC for sites with radioactive contamination.
OSCs are encouraged to maintain contact with the radiation representatives as needed, and to call
on them for technical assistance. In addition to advice, radiation programs generally have access to
a variety of survey instruments, personal protective equipment, and dosimeters. Table 1 lists phone
numbers for the Radiation Program Office in each Region.
5.2 Environmental Response Team
The Removal Program specialists in radiation are located at the Environmental Response Team
Operations Section in Cincinnati, Ohio. They can provide assistance in response planning and
strategy, health and safety issues, and field monitoring.
ERT conducts a week-long course in Radiation Safety at Superfund Sites (Course No. 165.11).
Topics covered include radiation exposure and biological effects; radiation exposure limits and
methods to control exposure; basic concepts in radiation detection and measurement; surveying for
radioactive materials; radiation signs and labels; decontamination procedures; radioactive material
packaging; labeling, shipping and workshop; as well as regulations and guidance on radioactive waste
disposal. The course also covers fundamental concepts of atomic structure and radiation and
radioactive decay. It identifies the biological effects of radiation exposure and the existing rules and
regulations which establish the protection criteria for exposure; discusses radiation detection including
the theory of operation; and details the use and selection of radiation monitoring instruments.
Courses such as ERT's Radiation Safety at Superfund Sites and the EPA Radiation Safety and Health
Program are designed to provide basic radiation safety information. It is still necessary to seek the
assistance of a radiation specialist when radioactive materials are discovered at a site.
5.3 Headquarters Office of Radiation and Indoor Air (ORIA)
Within EPA Headquarters, ORIA is the primary regulatory and response organization for radiation
contamination. ORIA expertise includes nuclear emergency response and contingency planning,
emergency response capability for low-level and high-level radioactivity release incidents at
hazardous waste sites, mobile field monitoring and analysis capability, and radiation site risk
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Table 1: Regional Radiation Program Offices
REGION
1
2
3
4
5
6
7
8
9
10
OFFICE LOCATION
Boston, MA
New York, NY
Philadelphia, PA
Atlanta, GA
Chicago, IL
Dallas, TX
Kansas City, MO
Denver, CO
San Francisco, CA
Seattle, WA
TELEPHONE
(617) 565-4502
(212) 637-4010
(215) 597-8326
(404) 347-4232
(312) 886-6175
(214) 655-7224
(913) 551-7605
(303) 293-1440
(415) 744-1048
(206) 553-7660
assessment. In addition to radiation expertise, ORIA has staff experienced in Superfund removal
operations and in carrying out the requirements of the NCP and FRERP.
OSWER Directive 9360.0-19 requires the OSC to notify ORIA to obtain health and safety advice
when conducting radiation cleanup activities. However, during "classic" emergencies such as spills,
fires, transportation incidents, etc., it may not be possible for the OSC to contact ORIA immediately.
In such cases, the OSC must contact ORIA at the earliest time possible after the emergency situation
is stabilized.
5.4 EPA Radiological Monitoring Laboratories
EPA maintains three laboratories that provide radiological monitoring and assessment services for
emergency or day-to-day services:
• The National Air and Radiation Environmental Laboratory (NAREL) of the Office of
Radiation and Indoor Air, located at Gunter Air Force Base in Montgomery, Alabama (334-
270-3400)
• The Las Vegas Facility (LVF) of ORIA, located in Las Vegas, Nevada (702-798-2476)
• The Environmental Monitoring Systems Laboratory (EMSL) and Office of Research and
Development, located near Nellis Air Force Base outside of Las Vegas, Nevada.
OSCs can access any of these laboratories in the following ways:
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Figure 3: Sources of Assistance
1. Contact the RRPM who, often, can
handle many of the radiological
situations or questions that might be
presented. Or you may be referred
to the laboratories, if necessary.
2. Contact the laboratory directly or
through the Superfund Technical
Support Center system.
3. Contact ORIA at EPA Headquarters
in Washington, DC. They can
direct you through the appropriate
information channels.
In an emergency, these laboratories can
provide radioanalytical services at the
laboratory or at the scene of the accident.
These radiological facilities have mobile
laboratories, communications, and other
support vehicles that can be deployed in
various combinations, depending on the
type and magnitude of response required.
The support vehicles are equipped to
provide command and control activities,
sample preparation, sample storage, and
supply and equipment dispatch. Using
mobile equipment, staff from these facilities provide radiological services, including gamma
spectroscopy and alpha/beta analyses. Local VHP and long-distance, shortwave communication
capabilities help them keep in touch with response personnel from other agencies.
EMSL provides scientific and technical assistance in contaminant detection, hydrologic monitoring,
site characterization, sample analysis, data interpretation, and geophysics. Services include: saturated
and unsaturated zone monitoring; remote sensing; mapping and geostatistics; analytical methods and
quality assurance; bore-hole and surface geophysics; and X-ray fluorescence field survey methods.
NAREL also operates the Environmental Radiation Ambient Monitoring System (ERAMS), which
comprises sampling stations in each State that regularly collect air paniculate, surface water,
precipitation, and milk samples for radioactivity analyses. The system can track airborne
radioactivity from any accidental release. If necessary, the ERAMS sampling frequency can be
increased to meet the needs of any radiological emergency response.
5.5 Additional Assistance
Some States have their own State radiological teams which can offer assistance with certain aspects
of radiological problems. These teams can be very helpful for small quantities of radiological
materials, as they will actually handle the transportation and disposal tasks, often at little or no cost.
Training; ERTt ORIA
Health & Safety Consulting: EKT, RPM
Contingency Planning: ORM
Response Strategies: BRT, RPM, ORIA
Field Monitoring/Analysis: 3 teboratoms
Risk Assessment: ORIA, RPM
• Regional Radiation Program Manager
(Table 1)
« Bnvkonmental Response Team, Cincinnati
(513-569^7537)
« Office of Radiation and Indoor Air,
Washington (202-233-9360)
« National Air and Radiation Environmental
Laboratory, Montgomery (NAREL) (205-
270-3401)
* Office of Radiation and Indoor Air, Las
Vegas (702-798-2476)
• Environmental Monitoring Systems
Laboratory (EMSL) Nuclear Radiation
Assessinent Division, Las Vegas (702-
798-2305)
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