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            Agencv
                 Solid Waste and
                 Emergency Response
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.

                                             1

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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.
                                             10

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3.6    Reference

EPA 1440, Occupational Safety and Health Manual, "Radiation Safety and Health Practices for Field
Work."
                                          11

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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)
                                             13

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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
                                             17

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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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