UNITED STATES  ENVIRONMENTAL  PROTECTION AGENCY
                                     WASHINGTON,  D.C.  20460
                                       DEC  1 7 1999
 MEMORANDUM

 SUBJECT:   Dis

 FROM:
                          iation Risk Assessment Q & A's Final Guidance
 TO:

 PURPOSE
Office of Air and Radiation

Addressees
                           rgency an<8 Remedial Response (OERR)
                                ste and Emergency Response

                                  Director
                             ionand Indoor Air (ORIA)
        The purpose of this memorandum is to transmit to you a final guidance document entitled:
 "Radiation Risk Assessment At CERCLA Sites: Q & A." The guidance provides answers to several
 common questions about radiation risk assessments at CERCLA sites. It should be especially useful
 to Remedial Project Managers (RPMs), On-Scene Coordinators (OSCs), and risk assessors.1
 BACKGROUND

       The U.S. Environmental Protection Agency (EPA) issued guidance entitled "Establishment
 of Cleanup Levels for CERCLA Levels for CERCLA Sites with Radioactive Contamination"
 (OSWER No.  9200.4-18,  August 22,  1997).  This 1997 guidance provided clarification for
 establishing  protective  cleanup  levels  for radioactive contamination  at Comprehensive
 Environmental Response, Compensation, and Liability  Act of 1980 (CERCLA) sites.  The  1997
 guidance reiterated that cleanups of radionuclides are governed by the risk range for all carcinogens
 established in the NCP when ARARs are not available or are not sufficiently protective. Cleanup
 should generally achieve a cumulative risk within the 10"4 to 10"6 carcinogenic risk range based on
 the reasonable maximum exposure. The cleanup levels should consider exposures from all potential
        The attached document provides guidance on risk assessment issues involved at CERCLA sites and is
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). It does not alter the
NCP expectations regarding treatment of principal threat waste and the use of containment and institutional controls for
low level threat waste.  Consistent with CERCLA and the NCP, response actions must attain or waive Applicable or
relevant and appropriate requirements (ARARs).  CERCLA response actions for contaminated ground water at radiation
sites must attain (or waive as appropriate) the Maximum Contaminant Levels (MCLs) or non-zero Maximum
Contaminant Level Goals (MCLGs) established under the Safe Drinking Water Act, where the MCLs or MCLGs are
relevant and appropriate for the site.

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pathways, and through all relevant media (e.g., soil, ground water, surface water, sediment, air,
structures, etc.) The 1997 guidance also provides a listing of radiation standards that are likely to
be used as ARARs to establish cleanup levels or to conduct remedial actions.

       Since issuance of the 1997 guidance, regional staff have requested additional guidance on
specific Superfund process  and requirements related  to radiation cleanups.  Today's guidance
responds to these requests.

       The attached final Risk Q & A fact sheet is part of a continuing effort between the Office of
Emergency and Remedial Response (OERR) and the Office of Radiation and Indoor Air (ORIA) to
provide updated guidance for addressing radioactively contaminated sites that is consistent with our
guidance for addressing chemically contaminated sites,  except  to  account  for  the technical
differences between radionuclides and chemicals.  This effort is intended to facilitate compliance
with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) at radioactively
contaminated sites while incorporating the improvements to the Superfund program that have been
implemented through Administrative Reforms.

       Two issues addressed in this Risk Q & A should be noted here. First, the answer to question
32 in the Risk Q & A is intended to further clarify that 15 millirem per year is not a presumptive
cleanup level under CERCLA, but rather site decision-makers should continue to use the risk range
when ARARs are not used to set cleanup levels. There has been some confusion among stakeholders
regarding this point because of language in the 1997 guidance. EPA is issuing further guidance
today  to  site decision makers on this topic. This Risk Q&A clarifies that, in general, dose
assessments should only be conducted under CERCLA where necessary to demonstrate ARAR
compliance.   Further, dose recommendations (e.g., guidance such  as DOE  Orders and NRC
Regulatory Guides) should generally not be used as to-be-considered material (TBCs). Although
in other statutes EPA has used dose as a surrogate for risk, the selection of cleanup levels for
carcinogens for a CERCLA  remedy is  based on the risk range when ARARs are not available or
are not sufficiently protective. Thus, in general, site decision-makers  should not use  dose-based
guidance rather than the CERCLA risk range in developing cleanup levels.  This is because for
several reasons, using dose-based guidance would result in unnecessary inconsistency regarding how
radiological and non-radiological  (chemical) contaminants are addressed at CERCLA sites. These
reasons include: (1) estimates of risk from a given dose estimate may vary by an order of magnitude
or more for a particular radionuclide, and; (2) dose based guidance generally begins an analysis for
determining a site-specific cleanup level at a minimally acceptable risk level rather than the 10"6
point of departure set out in  the NCP.

Second, it is important that data that support remedial decisions be of known and acceptable quality.
There are a number of EPA guidances available that may aid the decision maker in gathering data
of acceptable  quality.  One  such  guidance is the Multi-Agency Radiation Survey and Site
Investigation Manual (MARSSIM).  The determination of what data are needed is a site-specific
decision and it is the responsibility of the site decision-maker (e.g., RPM, OSC) to use the tools that
are most  appropriate for that situation.
                                          -2-

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IMPLEMENTATION

      For questions regarding radiation site policy and guidance for CERCLA cleanup actions,
readers are  referred to the RCRA/Superfund Hotline at 1-800-424-9346.  The subject matter
specialists for this fact sheet are Stuart Walker of OERR and Dr. Kung-Wei Yeh of ORIA.

Attachments

Addressees:
      National Superfund Policy Managers
      Superfund Branch Chiefs (Regions I-X)
      Superfund Branch Chiefs, Office of Regional Counsel (Regions I-X)
      Radiation Program Managers (Regions I, IV, V, VI, VII, X)
      Radiation Branch Chief (Region n)
      Residential Domain Section Chief (Region in)
      Radiation and Indoor Air Program Branch Chief (Region VIII)
      Radiation and Indoor Office Director (Region IX)
      Federal Facilities Leadership Council
      OERR Center Directors

cc
      Jim Woolford, FFRRO
      Elizabeth Cotsworth, OSW
      Craig Hooks, FFEO
      Barry Breen, OSRE
      Joanna Gibson, HOSC/OERR
      Earl Salo, OGC
      Bob Cianciarulo, Region I
                                         -3-

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^ico sj^, United States Office of
„•* ^^ *^ Environmental Protection Agency Emergency and
£ ^^* 4 Remedial Response
Office of Directive 9200.4-31 P
Radiation and EPA 540/R/99/006
Indoor Air December 1999
%% PR^&<^ Radiation Risk Assessment
At CERCLA Sites: Q & A
  NOTICE: The policies set out in this document are intended solely as guidance to U.S. Environmental Protection Agency (EPA) personnel; they are
  not final EPA actions and do not constitute rulemaking. These policies are not intended, nor can they be relied upon, to create any rights enforceable
  by any party in litigation with the United States. EPA officials may decide to follow the guidance provided in this document, or to act at variance with
  the guidance, based on analysis of specific-site circumstances. EPA also reserves the right to change the guidance at any time without public notice.
 INTRODUCTION

 Some  sites on the U.S. Environmental Protection Agency's
 National Priorities List (NPL) are radioactively contaminated. To
 assist in the evaluation and cleanup of these sites and surrounding
 areas  under the  Comprehensive   Environmental Response,
 Compensation, and Liability Act (CERCLA or Superfund), EPA's
 Office of Emergency and Remedial Response (OERR) and the
 Office of Radiation and Indoor Air (ORIA) have developed
 guidance for conducting radiation  risk assessments during the
 remedial investigation/feasibility study (RI/FS) process.  This
 guidance is provided primarily in the multi-part document, Risk
 Assessment Guidance for Superfund, Volume I, Human Health
 Evaluation Manual (RAGS). Guidance specific to radiation risk
 includes:

 •  Chapter  10,  "Radiation Risk  Assessment Guidance,"  of
    RAGSPart A (U.S. EPA, 1989a) which covers data collection
    and  evaluation, exposure and dose assessment,  toxicity
    assessment, and risk characterization for sites contaminated
    with radioactive substances;

 •  Chapter4, "Risk-based PRGs for Radioactive Contaminants,"
    of RAGS Part B (U.S. EPA, 199 la) which presents standard-
    ized exposure parameters and equations that should generally
    be used for calculating preliminary remediation goals (PRGs)
    forradionuclidesunder residential and commercial/industrial
    land use exposure scenarios [the equations for residential
    land use  will  be updated shortly with a new soil screening
    guidance for radionuclides (U.S. EPA, 1998d)];

•   Appendix D, "Radiation Remediation Technologies,"  of
    RAGS Part C  (U.S. EPA, 1991b) which provides guidance
    on using risk information to evaluate and select remediation
    technologies for sites with radioactive substances; and

•   RAGSPart D, Standardized Planning, Reporting, and Review
    of Superfund Risk Assessments  (U.S. EPA, 1998a), which
    provides guidance on standardized risk assessment planning,
    reporting, and review throughout  the  CERCLA  process
    (Radionuclides Worksheet to be developed).
 In addition to RAGS, EPA has published several other guidance
 documents and OSWER Directives concerning risk assessment
 methods  for  radioactive and nonradioactive  contaminants.
 Attachment 1  presents a  bibliography  of selected Agency
 guidance  documents on risk assessment.   OSWER Directives
 specific to radioactive contaminants include:

 •  OSWERNo. 9200.4-18, Establishmentof'Cleanup Levelsfor
    CERCLA Sites with Radioactive Contamination (U.S. EPA
    1997a), which provides guidance for establishing protective
    cleanup levels for radioactive contamination at CERCLA
    sites; and

 •  OSWER No. 9200.4-25, Use of Soil Cleanup Criteria in 40
    CFR Part 192 as Remediation Goals for CERCLA Sites (U.S.
    EPA 1998c), which provides guidance regarding the circum-
    stances under which the subsurface soil cleanup criteria in 40
    CFR Part 192 should be considered an applicable or relevant
    and appropriate requirement (ARAR) for radium or thorium
    in developing a response action under CERCLA.

 Overall, the process for assessing radionuclide exposures and
 radiation risks presented in RAGS and in supplemental guidance
 documents parallels the process for assessing risks from chemical
 exposures. Both types of assessments follow the same four-step
 evaluationprocess(exposure assessment, toxicity assessment, risk
 characterization,  ecological  assessments) ,  consider similar
 exposure scenarios and pathways (except the external "direct
 exposure" pathway  which is unique to radiation), determine
 exposure point concentrations, and provide estimates of cancer
 risks to humans.

 However, several aspects of risk assessment for  radioactive
 contaminants do differ substantially  from  those considered for
 chemical  contaminants.  Occasionally these differences—in
 measurement units, exposure  terms and concepts, field and
 laboratory procedures and detection limits, and toxicity criteria,
 among others—have led to questions concerning the Agency's
recommended approach for addressing  radionuclide contamina-
tion and risk and the cleanup of CERCLA radiation sites.

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 PURPOSE

 OERR and  ORIA have prepared this  document to  provide
 answers to several commonly asked questions regarding risk
 assessments at radioactively contaminated CERCLA sites raised
 by Remedial Project Managers (RPMs), On-Scene Coordinators
 (OSCs),   risk assessors, Federal, State and  local agencies,
 potentially responsible parties  (PRPs),  and contractors.   Its
 purpose is to provide an overview of current EPA  guidance for
 risk assessment and related topics for radioactively contaminated
 CERCLA  sites. Guidance issued by other organizations (e.g.,
 NRC, DOE, ICRP, NCRP) may provide technical assistance,
 however the reader should exercise caution since some of these
 documents utilize a  framework for risk management (e.g.,
 allowable dose limits  of 25, 100, or 500 mrem/yr) that EPA has
 determined is not suitable for use at CERCLA sites.

 The questions and answers (Q & A) that follow are presented in
 sections corresponding to the four basic  steps in the CERCLA
 risk assessment process:

 1.   Data Collection and Evaluation
 2.   Exposure Assessment
 3.   Toxicity Assessment
 4.   Risk Characterization

 In addition, a bibliography of selected reference materials related
 to radiation risk assessment is provided in Attachment 1.

 Readers are strongly encouraged to direct all questions concern-
 ing site-specific evaluations involving radioactive contaminants
 to the EPA  Regional Radiation Program Office  or Regional
 Superfund Office in the EPA Region in which their site is located.
 EPA has found that early involvement of the Regional Radiation
 Program and Superfund staff in all phases of site characterization
 and cleanup improves and expedites the entire process.

 For general questions  on, or assistance with, radiation surveys or
 radioanalytical procedures,  readers  are directed to  EPA's
 National Air and Radiation Environmental Laboratory (NAREL)
 in Montgomery, AL,  or Radiation and  Indoor Environments
 National Laboratory (RIENL) in Las Vegas, NV. For questions
 regarding radiation site  policy  and guidance, readers are also
 referred to the RCRA/Superfund Hotline at 1-800-424-9346. The
 subject matter specialists for this fact sheet are Dr. Kung-Wei Yeh
 of ORIA and Stuart Walker of OERR.

 I.      DATA COLLECTION AND EVALUATION

 Ql.   What strategy  and key information should be consid-
      ered during the initial planning stage for radiological
      data collection?

A.    The  Data Quality Objectives (DQO) process is an impor-
      tant tool for project managers and planners to determine
      the types, quantity, and quality of data needed to support
      decisions.  Detailed guidance on the DQO Process can be
      found in Guidance for the Data Quality Objectives Process
       (U.S.  EPA,  1994a) and  Data Quality Objectives for
       Superfundr(U. S. EPA, 1993 a). Additional guidance on the
       application of this process at radiation sites can be found
       in the Multi-Agency Radiation Survey and Site Investiga-
       tion Manual (MARSSIM) (U.S. EPA et al. 1997).  The
       DQO  process outlined  in these documents should be
       completed during the initial  planning  stage  for  data
       collection.

       At a minimum,  site characterization  should include the
       following key information and considerations:

       •  Review of the site history and records collected during
       the preliminary  assessment and site inspection (PA/SI),
       considering:

       •  past site operations
       •  types and quantities  of radioactive material used or
          produced
       •  radioactive waste stream characteristics
       •  disposal practices and records
       •  previous  radiological  characterization  data and/or
          environmental monitoring data
       •  physical  site characteristics (hydrology,  geology,
          meteorology, etc.)
       •  demography
       •  current and potential future land use

       •  Formulation of a conceptual site model to:
          identify radionuclides of concern
          identify the time period for assessment
          identify potentially contaminated environmental media
          identify  likely  release  mechanisms and exposure
          pathways
          identify potential human and ecological receptors
          focus initial surveys and sampling and analysis plans
      • Development of comprehensive sampling plans based
      on  the  conceptual site  model and  available historical
      information to

      • confirm the identities of radionuclide contaminants
      • confirm release mechanisms and exposure pathways
      • measure or model exposure point concentrations and
         point exposure rate (as appropriate for the type of
         radioactive decay)
      • confirm human and ecological receptors
      • specify cleanup levels or develop preliminary remedia-
         tion goals
      • establish DQOs

The MARSSIM (U.S. EPA et al.  1997) provides guidance on
planning, implementing, and evaluating radiological site surveys.
This multi-agency consensus document was developed collabor-
atively by the four Federal Agencies having authority and control
over radioactive materials: the Department of Defense (DoD),
Department of Energy (DOE), EPA, and the Nuclear Regulatory

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Commission (NRC). While the primary focus of MARSSIM is
on final status surveys to demonstrate compliance with dose- or
risk-based criteria, guidance is also provided for designing and
conducting  scoping and characterizing surveys, based on the
DQO process.

Q2.   How should a list of radionuclides of concern be con-
       structed?

A.    An initial list of radionuclides of potential concern should
       be  based on a review of previous site operations  that
       contributed to the current levels of contamination and the
       conceptual site model. As a first  consideration, all radio-
       nuclides used or produced at the site should be included on
       the list.  If appropriate,  the  list  should  also include all
       radioactive decay products that  may have formed since
       disposal or termination of operations. Radionuclides with
       short half-lives  and no parent radionuclide to support
       ingrowth may be considered for exclusion from the list.
       However, before a  short-lived radionuclide  is excluded
       from  the list, careful consideration should be given to its
       initial and current activity inventories, its radioactive half-
       life, and the time elapsed since the contamination occurred
       to the present.

       Site characterization efforts should be directed to confirm-
       ing or refuting the presence of the radionuclides of concern
       in on-site sources and in environmental media contami-
       nated by releases migrating off-site. The activity concen-
       trations of radionuclides (and decay products, if appropri-
       ate) in each medium should then be compared with site-
       specific background concentrations of those radionuclides
       (i.e., radionuclide concentrations in environmental media
       not related to site operations or releases), PRGs, screening
       levels, or potential remediation criteria (see Q3). Caution
       should be exercised in making such  comparisons, since
       radionuclide concentrations in environmental media may
       change over time due to radioactive decay and ingrowth;
       therefore, consideration should be given to the radioactive
       half-life of the radionuclides of  concern and any decay
       products, and the time period over which risks will be
       evaluated.

Q3.    What criteria should be used  to determine areas of
       radioactive contamination or radioactivity releases?

A.     Section 7 of EPA's revised Hazard Ranking System (HRS)
       (see Appendix A to 40 CFR Part 300) provides general
       criteria for comparing concentrations of radionuclides in
       sources and various environmental media against back-
       ground levels for use in screening  sites for inclusion on the
      NPL.  Table 1 presents a summary of the HRS criteria for
      establishing  observed radiological  contamination  or
      observed releases of radioactive materials; key consider-
      ations include the measurement of radionuclide concentra-
      tions significantly above site-specific background levels.
      General guidance is provided in the following Agency
      documents:
•  Methods for Evaluating the Attainment of Cleanup
   Standards—Volume 1: Soil and Soil Media (U.S. EPA,
   1989b)
•  Statistical Methods for Evaluating the Attainment of
   Cleanup Standards—Volume 2: Ground Water (U.S.
   EPA, 1992a)
•  Statistical Methods for Evaluating the Attainment of
   Cleanup  Standards—Volume   3:  Reference-Based
   Standards for Soils and Solid Media (U.S. EPA, 1992b)

Although these documents do not specifically address
radionuclides, most of the evaluation methods and tests
provided in these documents should be applicable to both
radioactive and  nonradioactive  contaminants.   More
specific guidance for the measurement and evaluation of
radiological contaminants is provided in the MARSSIM
(U.S. EPAetal. 1997); MARS SIM also provides guidance
on the determination of site-specific background levels for
comparison to site measurements.  Additional guidance
regarding soil screening levels (SSLs) for radionuclides is
currently under development (U.S. EPA  1998d).  The
SSLs are not cleanup  standards, but may be used  to
identify areas that may require further investigation at NPL
sites. The SSL equations should also be used to establish
PRGs  for residential land  use where  ARARs are not
available or sufficiently  protective. For additional guid-
ance on this issue, readers should contaci the appropriate
EPA Regional Radiation Program Office or Regional
Superfund Office, as appropriate, or ORIA-HQ.

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     Table 1.  EPA's Hazard Ranking System Criteria for Establishing Radionuclide Contamination/Releases*
Based on:
Direct Observation
Analysis of
Radionuclide
Concentrations in
Samples (ground
water, soil, air,
surface water,
benthic, or sediment
samples)
Gamma Radiation
Exposure Rate
Measurements
Criteria for Establishing Observed Contamination or Observed Releases of Radionuclides
Applies to All Radionuclides
(I) For each migration pathway, a material that contains one or more radionuclides has been seen entering the
atmosphere, surface water, or ground water, as appropriate, or is known to have entered ground water or surface
water through direct deposition, or
(ii) For the surface water migration pathway, a source area containing radioactive substances has been flooded at a
time that radioactive substances were present and one or more radioactive substances were in contact with the
flood waters.
Applies to Naturally Occurring Radionuclides and Man-made Radionuclides
With Ubiquitous Background Concentrations in the Environment
(I) Measured concentrations (in- units of activity, for example pCi per kilogram [pCi/kg], pCi per liter [pCi/L], pCi per
cubic meter [pCi/m3]) of a given radionuclide in the sample are at a level that:
(a) Equals or exceeds a value 2 standard deviations above the mean site-specific background concentration for
that radionuclide in that type of sample, or
(b) Exceeds the upper-limit value of the range of regional background concentration values for that specific
radionuclide in that type of sample.
(ii) Some portion of the increase must be attributed to the site to establish the observed release (or observed
contamination).
(iii) For the soil exposure pathway only, the radionuclide must also be present at the surface or covered by 2 feet or
less of cover material (for example, soil) to establish observed contamination. **
Applies to Man-made Radionuclides
Without Ubiquitous Background Concentrations in the Environment:
I
(I) Measured concentrations (in units of activity) of a given radionuclide in the sample equals or exceeds the sample
quantitation limit for that specific radionuclide in that type of media and is attributable to the site.
(a) However, if the radionuclide concentration equals or exceeds its sample quantitation limit, but its release can
also be attributed to one or more neighboring sites, then the measured concentration of that radionuclide must
also equal or exceed a value either 2 standard deviations above the mean concentration of that radionuclide
contributed by the neighboring sites or 3 times its background concentration, whichever is lower.
(ii) If the sample quantitation limit cannot be established:
(a) use the EPA contract-required quantitation limit (CRQL) in place of the sample quantitation limit in
establishing an observed release (or observed contamination) if the sample analysis was performed under the
EPA Contract Laboratory Program, or
(b) use the detection limit in place of the sample quantitation limit if the sample analysis is not performed under
the EPA Contract Laboratory Program.
(iii) For the soil exposure pathway only, the radionuclide must also be present at the surface or covered by 2 feet or
less of cover material (for example, soil) to establish observed contamination.**
Applies to Gamma-Emitting Radiongclides
(I) The gamma radiation exposure rate in microroentgens per hour (uR/hr) using a survey instrument held 1 meter
away from the ground surface (or 1 meter away from an aboveground source), equals or exceeds 2 times the site-
specific background gamma radiation exposure rate.
(ii) Some portion of the increase must be attributable to the site to establish observed contamination.
(iii) The gamma-emitting radionuclides do not have to be within 2 feet of the surface of the source.
 Source: Hazard Ranking System; Final Rule, Environmental Protection Agency, 55 FR 51532, December 14, 1990.
* Note: This criterion should not be interpreted to mean that radionuclides present in soils at depths greater than 2 feet below the surface would not
 warrant investigation and potential response action, but only that such materials may not be readily detected by surface measurements.

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 Q4.   How should the area! extent and depth of radioactivity
       contamination be determined?

 A.    As noted in Ql, a conceptual site model should be devel-
       oped to identify reasonable boundaries for investigating
       the nature and extent of contamination.  General guidance
       for site characterization activities is provided in Guidance
       for Conducting Remedial Investigations and Feasibility
       Studies Under CERCLA (U.S. EPA 1988a).

       The choice of a specific method or methods to characterize
       sites contaminated with radioactive substances depends on
       several factors, including the decay characteristics of the
       radionuclides potentially  present at the site,  suspected
       contamination patterns, and activity  concentrations. For
       gamma-emitting radionuclides in near-surface sources,
       walk-over radiation surveys are typically conducted to
       characterize the areal extent of contamination. For subsur-
       face contamination, borehole logging for gamma emitters,
       core sampling programs for radionuclides that emit only
       alpha or beta particles, or a combination of both types of
       methods, may be advisable.  In addition to measurements
       to determine volumetric contamination in environmental
       media, measurementsof surface contamination on building
       and equipment surfaces may also be required. Additional
       discussion of measurement techniquesand their limitations
       is provided in MARSSIM (U.S. EPA et al. 1997) For site-
       specific assessments, readers should consult the appropri-
       ate EPA Regional  Radiation Program Office or Regional
       Superfund Office.

 Q5.   What Held radiation survey instruments should be used
       and what are their lower limits of detection?

 A.    Selection of appropriate radiation detection instrumentsfor
       site characterization depends on the decay characteristics
       of the radionuclides potentially present at the site, sus-
       pected contamination patterns, and activity concentrations,
       among other factors. Numerous documents have  been
       written on this topic.  For a general discussion on radiation
       survey  instruments, readers are directed  to MARSSIM
       (U.S. EPA 402-R-96-018) and Chapter 10 of RAGs Part A
       (U.S. EPA, 1989a). For supplemental information regard-
       ing the  usability  of analytical  data for performing a
       baseline risk assessment at sites contaminated with radio-
       activity, readers should  refer to  "Guidance  for  Data
       Usability in Risk Assessment, Part B" (U.S. EPA, 1992d).
       For site-specific  applications of field radiation survey
       instruments,  readers  should contact their  appropriate
       Regional Radiation Program Office or Regional Superfund
       Office.

 Q6.   What  sample measurement units  for radiation risk
       assessment are typically used?

A.     Concentrations of radionuclides in environmental media
       are  typically expressed in terms  of "activity"  of the
      radionuclide per unit mass (for soil, sediment, and food-
      stuffs) or volume (for water and air) of the environmental
      medium.  Two different systems of units for radioactivity
      are currently in common usage: the International System
      (SI) units and the "conventional" or "traditional" units
      which were used before the advent of the SI system. The
      principal  unit of radioactivity  in  the  SI system is  the
      becquerel (1 Bq = 1 disintegration/second), while the basic
      conventional unit of activity is the Curie (1 Ci = 3.7 x 10'°
      Bq).   Since most radiation  standards  in  the  U.S.  are
      expressed in conventional units, this system is used for the
      purpose of this document. Concentrations of radionuclides
      in environmental media at contaminated sites are typically
      far below Curie quantities, and are commonly expressed in
      units of picocuries (1 pCi = 10'12 Ci = 3.7 x  10'2 Bq).
      Typical conventional units for reporting environmental
      measurements are pCi/g for soil (dry-weight), pCi/L for
      groundwater or surface water, and pCi/m3 for air.

      A special unit, the working level (WL), is used as a measure
      of the concentration of short-lived radon decay products in
      air. WL  is any combination  of short-lived radon decay
      products in one liter of air that will result in the ultimate
      emission of 1.3 x 10s million electron volts (MeV) of alpha
      energy. The Working Level Month (WLM) is the exposure
      to 1 WL for 170 hours (1 working month).

      In addition to radionuclide concentrations in environmental
      media, the radiation "exposure" rate is  often reported.
      Radiation exposure, in this context, refers to the transfer of
      energy from a gamma radiation field to a unit mass of air.
      The unit for radiation exposure is the roentgen (1 R = 2.58
      x 10"4 coulombs of charge per kg of air). Exposure rates at
      contaminated  sites are typically  expressed in units  of
      microroentgens/hour (u.R/hr).

      Radionuclide concentrations  on building or  equipment
      surfaces are specified in units of the activity concentrations
      of the radionuclide of concern in a specified surface area,
      typically dpm (disintegration  per minute) per 100 cm2 or
      pCi per 100cm2.

Q7.   What  sample measurement  units for remedial  action
      evaluation may be used?

      For remedial action evaluations it is often useful to express
      radionuclide  concentrations  in  terms of mass  (mass
      concentration).  The carcinogenic effects of a radionuclide
      are due to its disintegration rate that occurs during its decay
      process, concentrations of radionuclides are generally
      measured in terms  of activity for health evaluation
      purposes.    Mass units, however, provide insight and
      information   into   treatment  selection,  treatment
      compatibility, and treatment efficiency,  particularly  for
      remedial actions involving mixed waste. The practice of
      using activity concentration should  continue for response
      actions at CERCLA sites.   Mass concentration estimates
      contained  in proposed and final site decision documents
      [e.g., proposed plans, Record of Decisions (RODs))] may

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      include, in addition to activity measurements, estimates of
      concentrations in terms of mass consistent with those used
      for non-radiological contaminants.  Typically units  for
      expressing mass in environmental media for soil and water
      are mg/kg for soil and mg/1 for water.  These mass units
      also can be expressed as parts per million (ppm) for soil
      and water, which is equivalent to mg/kg  and  mg/1.  To
      estimate  the  radionuclide concentrations  in  ppm,  the
      following equations are given below:

          mg/kgson = (2.8xlO-|2)x/lx  TlKxpCi/g

          mg/lva,,, = (2.8 x 10'15) x A x  Tl/2 x pCi/l

         ppmsoil = (2.8 xlO'12) x A x TV2xpCi/g

         ppmmler = (2.&\lQ-*5)xA\  TmxpCi/l

      where A is the radionuclide atomic weight and T1/2 is the
      radionuclide half-life in years.  Most radionuclides have
      half-lives ranging from a few years to 10,000 years, which
      means that for most radionuclides, an activity of 1 pCi/g
      would mean the  concentration value of the radionuclide
      would be well under 1 x 10"6 ppm.
                                 I
Q8.  Are  radionuclides   included  in  EPA's Contract
      Laboratory  Program (CLP)?  If not, where should
      comparable radioanalytical services be obtained?

A.    Radionuclides are not standard analytes in EPA's CLP
      program. However,  EPA has published guidance  for
      radionuclide methods in Chapter 10 of RAGS Part A (U.S.
      EPA,   1989a).    In  addition,  EPA's Radiochemistry
      Procedures   Manual  (U.S.  EPA,     1984)   provides
      information       for  radionuclide-specific  analytical
      techniques.   For additional guidance on selection of
      radiological laboratories and analytical methods, readers
      should contact the appropriate RegionalRadiationProgram
      Office or Regional Superfund Office,  NAREL, or RIENL.

Q9.  How can I decide if the data collected are complete and
      of good quality?

A.    EPA's Guidance for Data Quality Assessment (U.S. EPA,
      1995), Guidance for Data Useability in Risk Assessment,
      Part /((U.S. EPA, \992c) and Part B (U.S. EPA, 1992d),
      provide procedures and statistical tests that may be used to
      determine whether or not collected data are of the correct
      type, quality, and quantity to support their intended use. In
      addition, the MARSSIM (U.S. EPA et al. 1997) addresses
      quality assurance and quality control  requirements  for
      radiological data.

II.    EXPOSURE ASSESSMENT

Q10. How does the exposure assessment for radionuclides
      differ from that for chemicals?
A.    Exposure assessment for radionuclides is very similarto that
      for chemicals.  Both nonradioactive chemical assessments
      and  radionuclide assessments  follow  the same  basic
      steps—i.e., characterizing the exposure setting, identifying
      exposure pathways  and potential receptors, estimating
      exposure   point  concentrations,   and  estimating
      exposures/intakes. In addition to the exposure pathways
      considered for chemicals (e.g., ingestion of contaminated
      water, soil, or  foodstuffs, and inhalation of contaminated
      air), external exposure to penetrating radiation (i.e., gamma
      radiation and  x-rays) may  be an  important  exposure
      pathway for certain radionuclides in near-surface soils. On
      the other hand, with the primary exception of tritium (H-3)
      as tritiated water or  water vapor,  dermal absorption is
      typically not a significant exposure pathway  for radio-
      nuclides and generally need not be considered.  (Other
      possible exceptions  could  include  organic compounds
      containing radionuclides.) Figure 1 depicts typical exposure
      pathways for radionuclides; additional pathways that may
      be considered  on a site-specific basis, where appropriate,
      are discussed in Ql 1. Additional discussion of radiation
      exposure pathways is provided in the Radiation Exposure
      and Risk Assessment Manual (RERAM), June 1996 (EPA
      402-R-96-016).

Qll. Can exposure pathways be added  or deleted based on
      site-specific conditions?

A.    Yes. Inclusion or deletion of exposure pathways should be
      based  upon   site-specific  conditions,  including   local
      hydrology, geology,  potential receptors, and current and
      potential future land use, among other factors. Accordingly,
      some exposure pathways may not be appropriate for a given
      site and may be deleted, if justification is provided. In other
      cases, exposure pathways that are typically not significant
      may be important for the site-specific conditions (e.g.,
      ingestion of contaminated fish for recreational scenarios,
      ingestion of contaminated meat or milk from livestock for
      agricultural  scenarios) and  should  be included in the
      assessment.

Q12 . How should radioactive decay products be addressed?

A.    All radionuclides, by definition, undergo radioactive decay.
      In this process, one unstable  nucleus  of an  element
      transforms (decays) spontaneously to a nucleus of another
      element. As the unstable nucleus decays, energy is released
      as particulate  or photon  radiation, or both,  and the
      radionuclide is transformed in atomic number and/or atomic
      mass.  The resulting decay products, or progeny, may also
      be radioactive  and undergo further decay. Various decay
      products may  have  different  physical  and  chemical
      characteristics  that affect their fate and transport in the
      environment as well as their radiotoxicity.  In cases where
      decay products have greater radiotoxicity than the original
      radionuclide, the potential radiation dose and health risk
      may  increase  over  time;  in such cases,  the  exposure
      assessment should consider the change in concentrations of

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      all decay products over time, to determine the time of
      maximum potential impact.

      Consideration of all potential radioactive decay products
      is  a key  element of the exposure  assessment for
      radionuclides. Many of the computerized mathematical
      models  available  for simulating  the  behavior  of
      radionuclides in the environment (see Q15) incorporate the
      ingrowth and decay of radioactive decay products as a
      function of  time;  these  models  are  very  useful in
      pinpointing the time of maximum dose or risk.  Similarly,
      slope factors (see Q20) and dose conversion factors (see
      Q21) for some radionuclides may include consideration of
      radioactive decay products, where appropriate, to facilitate
      these considerations in estimating potential radiation dose
      and risk. However, such values typically assume that all
      decay products are present at the same concentration as the
      primaryradionuclide(i.e., secular equilibrium), whichmay
      not  be  appropriate  for all situations.  Readers should
      consult  their  Regional Radiation Program Office  or
      Regional Superfund Office for additional  information
      regarding such limitations.  See also section "Modeling
      Assessment of Future Exposures" in  OSWER Directive
      9200.4-18 (U.S.  EPA 1997a) for  information modeling
      decay products.

Q13. To what extent should generic and site-specific factors
      and parameter values be used in exposure assessments?

A.    For both radionuclide  and chemical assessments, EPA
      recommends the  use of empirically-derived,  site-specific
      factors and parameter values, where such values can be
      justified and documented.  For generic assessments, EPA
      recommends  the use of the  default parameter values
      provided in  OSWER Directive  9285.6-03  Standard
      Default Exposure Factors  (U.S.  EPA, 1991c) and the
      Exposure Factors Handbook (U.S. EPA, 1990, 1997b).

Q14. How  should   exposure  point  concentrations be
      determined?

A.    As  for  chemical   contaminants,   exposure   point
      concentrations of radionuclides in environmental media
      and  radiation exposure rates (e.g., alpha, beta, gamma)
      should be either measured, modeled, or both. To the
      extent possible,  measurement data  should  be used to
      evaluate current exposures. When  measurements at the
      exposure locations cannot  be made, or  when predicting
      potential concentrations and exposures at future times,
      modeling is required (see Q15).

Q15. What calculation methods or multimedia radionuclide
      transport and exposure models are recommended by
      EPA for Superfund risk assessments?

A.    Currently, only the equations in RAGS Part B (U.S. EPA,
      1991 a) - which are used to develop risk-based preliminary
      remediation goals for hazardous chemicals and radio-
      nuclides  - are recommended by  EPA for Superfund
      radiation risk  assessments. (Note:  The  Soil Screening
      Guidance for Radionuclides (U.S. EPA 1998d) is expected
      to supersede the RAGS Part B algorithms when finalized.)
      Numerous computerized mathematical models have been
      developed by EPA and other organizations to predict the
      fate and transport of radionuclides in the environment; these
      include single-media models (e.g., ground water transport)
      as well as multi-media models.  These models have been
      designed for a variety of goals, objectives and applications,
      but no single model may be appropriate for all site-specific
      conditions.  While the Agency has approved individual
      models for specific applications (e.g., CAP88 or COMPLY
      for  atmospheric transport  calculations  to  demonstrate
      compliance with 40 CFR Part 61 requirements), no model
      has yet been formally endorsed for evaluating  potential
      impacts from radionuclides in soil. For further information
      on selection of models appropriate to meet a specific-site
      characteristics and requirements, readers  can refer to
      Ground-Water Modeling Compendium (U.S. EPA 1994c),
      and A Technical Guide to Ground- Water Model Selection at
      Sites Contaminated with Radioactive Substances (U.S. EPA
      1994d).   While these  documents specifically address
      groundwater models, the model selection criteria and logic
      may be useful for other types of models as well.

      Attachment  1  provides  a  bibliography  of reference
      documents  for numerous  models currently  available.
      Readers  are  strongly  encouraged  to  consult  with  the
      appropriate EPA Regional Radiation Program Office or
      Regional Superfund Office in which the site is located for
      guidance on selection and use of radionuclide fate and
      transport models for site-specific applications.

Q16. How should Radon-222 (radon) and Radon-220 (thoron)
      exposures and risks be evaluated?

A.    Radon-222  (Rn-222)   and  Radon-220 (Rn-220)   are
      radioactive gases that are isotopes of the element radon
      (Rn).  Each is produced by the radioactive  decay of an
      isotope of radium (Ra). For Rn-222 (also called radon), the
      parent radium isotope is Ra-226 and for Rn-220 (also called
      thoron), the parent radium isotope is Ra-224. (Although
      thoron is produced from the radioactive decay of Ra-224,
      it is often referred to as a decay product of Ra-228, which
      is  a  longer-lived  precursor  typically  measured   in
      environmental samples.)   Each radon isotope gives rise to
      a series or chain of short-lived radioactive decay products
      that emit alpha particles which can damage lung tissues if
      inhaled. Of the two decay chains, the radon series is longer
      lived  and  more   hazardous  than  the  thoron  series.
      Consequently, most (but not all) radon exposure and risk
      assessments deal with radon (Rn-222) arising from radium
      (Ra-226) contamination.

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Structures  built   on  radium-contaminated  soil   or
constructed with radium-bearing materials can accumulate
elevated concentrations of radon in indoor air.   Some
radiation protection standards which may be potential
ARARs at a site, explicitly exclude dose or risk from radon
and its decay products from consideration. Other potential
ARARs and to-be-considered (TBC) information directly
address radon and its decay products  (e.g.,  allowable
concentrations of radon decay products in indoor air under
40 CFR 192(b)(l) of a standard of 0.003 working level
(WL) and a goal of 0.002 WL, as well as the  U.S. EPA
Guideline of 4 pCi radon-222 per liter of indoor air).

Several  EPA-approved   methods  are  available  for
measuring radon and progeny concentrations in indoor air
(EPA et al, 1997).  Computer codes have been developed
to predict radon concentrations in indoor air and potential
human  exposure,  based  on simplified equations and
assumptions;  these models  may yield results that  are
meaningful on average (e.g., for a geographical region) but
highly imprecise for an  individual house or structure.
Despite their widespread use, these codes should be used
with caution and their estimates interpreted carefully.

Readers are encouraged to consult with the EPA Regional
Radiation Program Office or Regional Superfund Office
for specific guidance and recommendations concerning
measurement  of radon  concentrations in indoor air,
evaluation  of  potential  exposures,  and  applicable
      mitigation measures.   Also, some states have their own.
      radon  testing  and   mitigation  requirement  or
      recommendations. Readers should also determine if any of
      the standards for radon are potential ARARs at their site
      (see Q 34).

Q17. How  long a time period  should be considered for
      possible future exposures?

A.    Section "Modeling Assessment of Future Exposures" in
      OSWER Directive 9200.4-18 (U.S. EPA 1997a) provides
      guidance for estimating future threats. Also, in some cases,
      Federal or State ARARs may include specific time-frame
      requirements  for a given  purpose, such  as disposal of
      radioactive materials in an approved waste repository.

Q18 . How should the results of the exposure assessment for
      radionuclides be presented?

A.    Results of the exposure assessment for radionuclides should
      be presented in two stages: (1) intake and external exposure
      estimates for use in risk characterization; and (2) estimates
      of radiation dose (see Q22 for discussion of specific
      dosimetric  quantities  that  may  be  appropriate) for
      comparison with dose-based standards.  Note that intake
      estimates for radionuclides  should not be divided by body
      weight or  averaging  time  as  is done for  chemical
      contaminants. Intake estimates for inhalation or ingestion
      pathways  should include  the  total  activity  of each
                           \  V\   °	7;	7
                               R&dioaetive Contaminants in Soil
                           Figure 1. Typical Radionuclide Exposure Pathways
                                                     8

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       radionuclide inhaled or ingested via each pertinent route of
       exposure (e.g., ingestion of contaminated drinking water,
       direct  ingestion  of contaminated  soil,  ingestion of
       contaminated produce/milk/meat). Measured or predicted
       external exposure rates should be presented, along with the
       exposure time, frequency, and duration. In the absence of
       measured exposure  rates,  the concentration  of each
       radionuclide in soil is needed to estimate the risk from the
       external  pathway using slope factors.   When present,
       estimates of radiation surface contamination also should be
       presented by radiation type (alpha, beta, gamma).

 III.    TOXICITY ASSESSMENT

 Q19.  What is the mechanism of radiation damage?

 A.    Radiation emitted by radioactive substances can transfer
       sufficient localized energy to atoms to remove electrons
       from the electric field  of their nucleus  (ionization). In
       living tissue, this energy transfer can produce chemically
       reactive ions or free radicals, destroy cellular constituents,
       and damage DNA. Irreparable DNA damage is thought to
       be a  major factor  in  carcinogenesis.  [While ionizing
       radiation may also cause other detrimental health impacts,
       only radiogenic  cancer risk is normally considered in
       CERCLA risk assessments (see Q24).]

       The type of ionizing radiation emitted by a particular
       radionuclide depends upon the exact nature of the nuclear
       transformation,  and  may  include emission  of alpha
       particles, beta particles (electrons or  positrons),  and
       neutrons;  each   of these  transformations  may  be
       accompanied by emission of photons (gamma radiation or
       x-rays).  Each type of  radiation  differs  in  its physical
       characteristics  and in  its ability to  inflict damage to
       biological tissue.  For purposes of radiation risk estimates,
       the various types of radiation are often categorized as low
       linear energy  transfer  (LET) radiation  (photons  and
       electrons) and high-LET radiations (alpha particles and
       neutrons).

       Ionizing radiation can cause deleterious effects on biologi-
       cal  tissues  only when the  energy  released  during
       radioactive  decay is  absorbed in tissue.   The average
       energy imparted by ionizing radiation per unit mass of
       tissue  is called the  "absorbed dose".   The  SI unit of
       absorbed dose is the joule per kilogram, also assigned the
       special name  the Gray (1  Gy  =  1  joule/kg);  the
       conventional unit of absorbed dose is the rad (1 rad = 100
       ergs/g = 0.01 Gy).

Q20 .  What are radionuclide slope factors?

A.     EPA   has  developed  slope   factors  for  estimating
       incremental  cancer  risks resulting from  exposure  to
      radionuclides  via inhalation,  ingestion,  and external
      exposure  pathways.  Slope factors  for  radionuclides
      represent the probability of cancer incidence as a result of
       a unit exposure to a given radionuclide averaged over a
       lifetime.  It is the age-averaged lifetime excess cancer
       incident rate per unit intake (or unit exposure for external
       exposure pathway) of a radionuclide (U.S. EPA 1989a).

       Current radionuclide slope factors incorporate the age- and
       gender-specific  radiogenic cancer  risk  models  from
       Estimating Radiogenic Cancer Risks (U.S. EPA, 1994b).
       Age-specific estimates of absorbed dose rate are used,
       where available, for internal exposure pathways, whereas
       dose estimates for external exposure are taken directly from
       Federal Guidance  Report No.  12  (U.S. EPA  1993b).
       Population  mortality statistics and  baseline cancer rates
       reflect the U.S. population of 1989-1991 (1979-1981  for
       slope factors derived prior to 1998). Detailed information
       on the derivation and application of risk coefficients and
       radionuclide slope factors is  presented  in  Radiation
       Exposure and Risk Assessment  Manual (RERAM) (U.S.
       EPA, 1996,1998h).Agency-recommendedslope factors for
       radionuclides (as well as nonradioactive carcinogens)  are
       published in EPA's Health Effects Assessment Summary
       Tables (HEAST) (U.S. EPA, 1998e). EPA plans to revise
       the  HEAST tables  based on  information in  Federal
       Guidance Report No.  13:  Health Risks from Low-Level
       Environmental Exposure to  Radionuclides (U.S.  EPA
       1998g).

Q21 .  What are radionuclide dose conversion factors?

A.     Dose conversion factors (DCFs), or "dose coefficients",  for
       a given radionuclide represent the dose equivalent per unit
       intake (i.e., ingestion or inhalation) or external exposure of
       that radionuclide. These DCFs are used to convert a radio-
       nuclide concentration in soil, air, water, or foodstuffs to a
       radiation dose.  DCFs may be  specified for specific body
       organs  or tissues of interest,  or as a weighted sum of
       individual organ dose, termed the effective dose equivalent
       (these quantities are discussed further in Q21). These DCFs
       may be multiplied by the total activity of each radionuclide
       inhaled or ingested per  year, or the external exposure
       concentration to which a  receptor  may  be exposed, to
       estimate the dose equivalent to  the receptor.

       EPA-approved DCFs for inhalation and ingestion exposure
       are published in Federal Guidance Report No.  11 (U.S.
       EPA, 1988b). EPA-approved DCFs for external exposure
       are published in Federal Guidance Report No.  12 (U.S.
       EPA, 1993b). Both compilations provide DCF values for a
       reference  adult  only,  but it  is anticipated that future
       revisions will include values for other age groups.

Q22 . What is dose equivalent, effective dose equivalent, and
       related quantities?

      As  discussed in Q18,  different types of radiation have
      differing effectiveness in transferring their energy to living
      tissue.  Since it is often desirable to compare doses from
      different types of radiation, the  quantity "dose equivalent"

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      has been defined as a measure of the energy absorbed by
      living  tissues,  adjusted  for   the  relative  biological
      effectiveness of the type of radiation present. The SI unit
      for dose equivalent is the sievert (Sv) and the conventional
      unit is the rem (1 rem = 0.01 Sv). For computation of dose
      equivalent, the absorbed dose is multiplied by Quality
      Factor (Q) or radiation weighting factor (WR); these values
      range from 1 for photons and electrons to 10 for neutrons
      to 20 for alpha particles (i.e.,  for an equal amount of
      energy   absorbed,  an  alpha  particle   will  inflict
      approximately 20 times more damage to biological tissue
      than that inflicted  by a beta  particle  or gamma  ray).
      Internally   deposited  (i.e.,   inhaled   or  ingested)
      radionuclides may  be deposited in various organs and
      tissues long after initial deposition.  The "committed dose
      equivalent" is defined as the integrated dose equivalent
      that will be received by an individual during a 50-year
      period (based on occupational  exposure) following the
      intake. By contrast, external radiation exposure contribute
      to dose only  as long as the receptor is present within the
      external radiation field.

      When exposed to equal doses of radiation, different organs
      and tissues in the human body will exhibit different cancer
      induction rates. The quantity "effective dose equivalent"
      was developed  by the  International Commission on
      Radiological Protection  (ICRP) to  account for these
      differences and to normalize radiation doses and effects on
      a  whole  body  basis  for  regulation  of occupational
      exposure. The effective dose equivalent is computed as a
      weighted sum of organ-specific dose equivalent values,
      with weighting factors specified by the ICRP (ICRP 1977,
      1979). The effective dose equivalent is equal to that dose
      equivalent, delivered at  a uniform whole-body rate, that
      corresponds to the same number (but possibly dissimilar
      distribution)  of fatal  stochastic health effects  as the
      particular combination of organ  dose equivalents.

Q23. What is the critical organ approach to dose limitation?

A.    Critical organ standards developed by EPA and NRC
      usually consist of a combination of whole body and critical
      organ dose limits, such as 25 mrem/yr to the whole body,
      75 mrem/yr to the thyroid, and 25 mrem/yr to any critical
      organ other than the thyroid. When these standards were
      adopted, dose was calculated and controlled for each organ
      in the body and uniform radiation of the "whole body."
      The "critical organ" was the organ that received the most
      dose for the radionuclide concerned. With the adoption of
      the dose  equivalent concept, the dose to each organ is
      weighted according to the effect of the radiation on the
      overall system (person).  The new system allows for one
      value of dose equivalent to be assigned as a limit, which is
      protective  of the  entire system.   The  critical organ
      approach required individual limits  for each organ based
      on the effect of radiation on that organ.

      It  should  be noted that although  most  critical organ
      standards include 25 mrem/yr or higher (75 mrem/yr) dose
      limits, these critical organ standards are not comparable to
      25 mrem/yr effective dose equivalent standards or guidance.
      EPA's determination that the 25 mrem/yr dose level found
      in NRC's decommissioning standard and various guidance
      should not be used to establish cleanup levels at CERCLA
      sites does not apply to critical organ standards.

Q24. How should  radionuclide  slope  factors  and dose
      conversion factors be used?

A.    EPA recommends that radionuclide  slope factors  be
      used to estimate the  excess cancer risk resulting from
      exposure to radionuclides at radiologically contaminated
      sites for comparison with EPA's target risk range (i.e.,
      10"4 to 10"6 lifetime excess cancer risk). The incremental
      risk is calculated by multiplying estimates of the lifetime
      intake via inhalation and ingestion of each radionuclide of
      concern,  and   the   duration  and   concentration   in
      environmental media to which the receptor is exposed via
      the external exposure pathway, by the  appropriate slope
      factor values for that exposure pathway and radionuclide.
      Additional  information on the use of radionuclide slope
      factors and their underlying assumptions, which introduce
      significant  uncertainties,  is provided in the  Radiation
      Exposure and Risk Assessment Manual (RERAM) (U.S.
      EPA 1996a, 1999b).

      Estimates of cancer risk from radionuclide exposures may
      also  be computed by  multiplying  the effective dose
      equivalent computed using the DCFs by a  risk-per-dose
      factor. EPA recommends that this method not be used at
      CERCLA sites to estimate risks for PRGs or cleanup levels,
      and estimates computed using this method may tend to
      inaccurately estimate potential risks, with the magnitude of
      discrepancy dependent on the dominant radionuclides and
      exposure pathways for the site-specific  conditions. These
      differences can be  attributed to factors  such as  the
      consideration of  competing mortality risks  and age-
      dependent radiation risk models in the development of the
      slope factors, different  distributions  of relative  weights
      assigned to individual  organ risks in the two methods, and
      differences in dosimetric and toxicological  assumptions.
      Some key differences  in  the two methods are summarized
      in Table 2.

      Due  to  these factors, no  simple  and direct conversion
      between radiation dose and radiogenic cancer risk  is
      available.   Given the differing  dosimetric and radio-
      toxicological  characteristics of different radionuclides, as
      reflected in the DCFs and slope factors, respectively, a
      given dose from one  radionuclide via a  given exposure
      pathway may present a much greater  cancer risk than the
      same dose  from  another radionuclide and/or exposure
      pathway. Therefore, any conversion between dose and risk
      now must be performed on a radionuclide- and pathway-
      specific basis.
                                                            10

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      The primary use of DCFs should generally be to compute
      doses resulting from site-related exposures for comparison
      with radiation protection standards and dose limits (see
      Q31 -32) that are determined to be ARARs or TBCs.  This
      is accomplished by multiplying the exposure estimates
      produced through the exposure assessment (i.e., the intake
      of each radionuclide  of  concern  via  inhalation  and
      ingestion, and the duration  of exposure and concentration
      of each radionuclide of concern in environmental media
      for external exposure) by the appropriate DCF values for
      that exposure pathway and radionuclide.  Unlike excess
      cancerrisk, which represents cumulative lifetimeexposure,
      dose estimates are typically expressed in terms of annual
      exposure (e.g., the effective dose equivalent resulting from
      exposure during a one-year period, mrem/year).

      Unless  otherwise stated in  the  standard,  DCFs  from
      Federal Guidance Report No. 11 (U.S. EPA, 1988b) and
      Federal Guidance  Report No.  12 (U.S. EPA, 1993b)
      should  be  used for  complying with ARARs based on
      effective dose equivalent, while DCFs from ICRP 2 should
      be used when complying with ARARs based on the critical
      organ approach.

Q25. In addition to cancer, should the potential teratogenic
      and  genetic   effects  of  radiation  exposures  be
      considered?

A.    Biological  effects associated with exposure to ionizing
      radiation in the  environment may include carcinogenicity
      (i.e., induction of cancer), mutagenicity (i.e., induction of
      mutations  in somatic  or  reproductive cells, including
      genetic effects), and teratogeniciry  (i.e., effects on the
      growth and development of an embryo or fetus). Agency
      guidance (U.S. EPA, 1989a, 1994b)  indicates that the
      radiogenic cancer risk is normally assumed to be limiting
      for risk assessments at Superfund sites, and evaluation of
      teratogenic and genetic effects is not required. Similarly,
      consideration of acute  effects normally is not required,
      since these effects occur only at doses  much higher than
      normally associated with environmental exposures.

Q26. Should  chemical   toxicity  of  radionuclides be
      considered?

A.    At Superfund radiation sites, EPA  generally evaluates
      potential human health risks based on the radiotoxicity
      (i.e.,  the  adverse  health  effects  caused by  ionizing
      radiation), rather than on the chemical toxicity, of each
      radionuclide present. Uranium, in soluble form, is a kidney
      toxin at mass concentrations slightly above  background
      levels, and is the only radionuclide for which the chemical
      toxicity has been identified  to be comparable to or greater
      than the radiotoxicity,  and for which  a reference dose
      (RfD) has been  established to evaluate chemical toxicity.
      For radioisotopes of uranium, both effects  (radiogenic
      cancer risk and chemical toxicity)  should be considered.
IV.   RISK CHARACTERIZATION

Q27.  How should radionuclide risks be estimated?

A.    Risks from radionuclide exposures should be estimated in
      a manner analogous to that used for chemical contaminants.
      That is the estimates of intakes by inhalation and ingestion
      and the external exposure over the period of exposure
      estimated for the land use (e.g., 30 years residential, 25
      years commercial/industrial) from the exposure assessment
      should be coupled with the appropriate slope factors for
      each radionuclide and exposure pathway. Only excess
      cancer risk should be considered for most radionuclides
      (except for  uranium as  discussed in Q25). The total
      incremental  lifetime cancer risk attributed to radiation
      exposure is  estimated as  the sum of the  risks from all
      radionuclides in all exposure pathways.

Q28 . Should radionuclide and chemical risks be combined?

A.    Yes. Excess cancer risk from  both radionuclides  and
      chemical carcinogens should be summed to provide an
      estimate  of the  combined  risk presented   by  all
      carcinogenic contaminants  as specified in  OSWER
      directive 9200.4-18 (U.S. EPA 1997a).  An exception
      would be cases in which a person reasonably can not be
      exposed to both chemical and radiological carcinogens.
      Similarly, the chemical toxicity from uranium should be
      combined with that of other site-related contaminants.  As
      recommended in RAGS Part A (U.S. EPA 1989a),  risk
      estimates for radionuclides and chemical contaminants also
      should be tabulated and presented separately in the  risk
      characterization report.

      There  are generally several differences between slope
      factors for radionuclides and chemicals . However, similar
      differences also occur between  different chemical slope
      factors. In the  absence of additional information, it is
      reasonable to assume that excess cancer risks  are additive
      for purposes of evaluating the total incremental cancer risk
      associated with a contaminated site.

Q29  How  should risk  characterization  results for radio-
      nuclides be presented?

A.    Results should be presented according to the standardized
      reporting format presented in RAGS Part D  (U.S. EPA,
      1998a). However, specific guidance for radionuclides (i.e.,
      the Radionuclides Worksheet) is not yet available.

      EPA guidance for risk characterization (U.S. EPA, 1992e)
      indicates that four descriptors of risk are generally needed
      for a full characterization of risk: (1) central tendency (e.g.,
      median, mean) estimate of individual  risk; (2) high-end
      estimate (e.g., 95th percentile) of individual risk; (3) risk to
      important subgroups (e.g., children) of the population, such
      as  highly exposed  or highly  susceptible  groups  or
      individuals,  if known; and  (4) population  risk.  The
      reasonable maximum exposure (RME) estimate of individ-
                                                            11

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      ual risk typically presented in Superrund risk assessments
      represents a measure of the high-end individual exposure
      and risk.  While the RME estimate remains the primary
      scenario for risk management decisions, additional risk
      descriptors may be included to  describe site risks more
      fully.

Q30 . Should the collective risk to populations be estimated
      along with that to individual receptors?

A.    Risk to potential individual receptors  is the primary
      measure of protectiveness under the CERCLA  process
      (i.e., the target range of 10~6 to 10"4 lifetime excess cancer
      risk to the RME receptor).  As  noted in Q28, however,
      Agency guidance (U.S. EPA, 1992e) also indicates that the
      collective risk to the potentially exposed population and to
      important  subgroups of the  population  also should be
      evaluated  where possible.  Consideration of population
      risk  provides  additional  input to  risk  management
      decisions;  such considerations may be either qualitative or
      quantitative depending on the availability of data and the
      magnitude of projected population risk.
Q31.  How should uncertainty in estimates of radiation risk be
      addressed in the risk characterization report?

A.    Consideration  of uncertainty  in estimates of risks from
      potential exposure to radioactive materials at CERCLA sites
      is essential for informed risk management decisions. RAGS
      and subsequent guidance (U.S. EPA, 1992e, 1995b) stress
      the  importance  of  a  thorough  presentation  of  the
      uncertainties, limitations, and assumptions that underlay
      estimates of risk. Either qualitative or quantitative evalu-
      ation may be appropriate, depending on the availability of
      data and the magnitude of predicted risk. In either case, the
      evaluation should address both uncertainty (i.e., "the lack of
      knowledge about specific factors, parameters, or models")
      and variability (i.e., "observed differences attributable to
      true heterogeneity or diversity in a population or exposure
      parameter").  Estimates of potential risk should include
      both central tendency estimates (median, mean) and  high-
      end estimates (e.g., RME or 95th percentile).
   Table 2. Comparison of Radiation Risk Estimation Methodologies: Slope Factors vs Effective Dose Equivalent
Parameter
Competing
Risks
Risk
Models
Genetic
Risk
Dose
Estimates
RBE for high-
LET (alpha)
radiation
Organs
Considered
Lung Dose
Definition
Integration
Period
Dosimetric /
Metabolic
Models
Slope Factor Approach
• Persons dying from competing causes of death (e.g., disease,
accidents) are not considered susceptible to radiogenic cancer.
• Probability of dying at a particular age from competing risks is
considered based on the mortality rate from all causes at that age in
the 1989-1991 (previously 1979-1981) U.S. population.
• Age-dependent and gender-dependent risk models for 14 cancer
sites are considered individually and integrated into the slope factor
estimate.
• Genetic risk is not considered in the slope factor estimates; however,
ovary is considered as a potential cancer site.
• Low-LET and high-LET dose estimates considered separately for
each target organ.
• 20 for most sites (8 prior to 1994)
• 10 for breast (8 prior to 1994)
• 1 for leukemia (1.117 prior to 1994)
• Estimates of absorbed dose to 16 target organs/tissues considered
for 13 specific cancer sites plus residual cancers.
• Absorbed dose used to estimate lung cancer risk computed as
weighted sum of dose to tracheobronchial region (80%) and
pulmonary lung (20%).
• Variable length (depending on organ-specific risk models and
consideration of competing risks) not to exceed 1 1 0 years.
• Metabolic models and parameters for dose estimates follow recent
recommendations of the ICRP series of documents on age-specific
dosimetry (ICRP, 1989, 1993, 1995a, 1995b), where available;
previous estimates based primarily on ICRP 30 (ICRP, 1979).
Effective Dose Equivalent x Risk Factor Approach
• Competing risks not considered.
• Risk estimate averaged over all ages, sexes, and cancer
sites.
• Effective dose equivalent (EDE) value includes genetic risk
component.
• Dose-equivalent includes both low-LET and high-LET
radiation, multiplied by appropriate Quality Factors.
• 20 (all sites)
• EDE (ICRP, 1979) considers dose estimates to 6 specific
target organs plus remainder (weighted average of 5 other
organs).
• Average dose to total lung (mass weighted sum of doses to
the tracheobronchial region, pulmonary region, and
plumonary lymph nodes).
• Fixed integration period of 50 years typically considered.
• Typically employ ICRP Publication 30 (ICRP, 1 979) models
and parameter for radionuclide uptake, distribution, and
retention.
                                                            12

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    \ For  both chemical  carcinogens and   radionuclides,
      extrapolation from high dose and dose rate exposure is
      generally required to estimate risks of low-level exposures.
      This extrapolation typically constitutes the greatest source
      of uncertainty.  For  chemical carcinogens, additional
      uncertainty may be introduced due to extrapolation of
      animal  data  to  humans.   Slope  factors  for both
      radionuclides  and  chemicals  are   used to  estimate
      incremental cancer risk, which typically represents a small
      increment over a relatively high baseline incidence. Other
      sources of uncertainty may include that associated with
      instrumentation and measurements used to characterize the
      nature and extent of radionuclides of concern,  and the
      parameters used to  characterize potential exposures of
      current and future receptors (e.g., intake rates, frequency
      of exposure).

      Probabilistic  Risk Assessment  (PRA)  may be  used to
      provide quantitative estimates of the uncertainties in the
      risk assessment. However, probabilistic estimates of risk
      should always be presented as a supplement  to - not
      instead of- the deterministic (i.e., point estimate) methods
      outlined  in RAGS Part A.  A tiered approach  is often
      useful, with the rigor of the analysis dependent on the
      magnitude of predicted risk.  Factors to be considered in
      conducting a probabilistic analysistypically should include
      the   sensitivity  of  parameters,  the  correlation  or
      dependencies between parameters, and the distributions of
      parameter values and model estimates. Detailed guidance
      on this topic is provided in Use of Probabilistic Techniques
      (Including Monte Carlo Analysis) in Risk Assessment (U.S.
      EPA  1997c)  and  Guiding Principles for  Monte Carlo
      Analysis (U.S. EPA 1997d).

Q32 . When should a dose assessment be performed?

      OSWER Directive 9200.4-18 (U.S. EPA 1997a) specifies
      that  cleanup  levels  for  radioactive contamination at
      CERCLA sites should be established as they would for any
      chemical that poses an unacceptable risk and the risks
      should be characterized in standard Agency risk language
      consistent with CERCLA guidance. Cleanup levels not
      based on an ARAR should be based on the carcinogenic
      risk range (generally 10"4 to 10'6, with 10"6 as the point
      of departure and 1 x 10"* used for PRGs) and expressed
      in terms of risk (# x 10"*). While the upper end of the risk
      range is not a discrete line at 1 x 10"4, EPA generally uses
      1  x 10"4 in making risk management decisions. A specific
      risk estimate around 10"4 may be considered acceptable if
      based  on site-specific circumstances.   For  further
      discussion of how EPA uses the risk range, see OSWER
      Directive9355.0-30, Role of the Baseline Risk Assessment
      in Superfund Remedy  Selection Decisions (U.S. EPA
      199Id).  In general, dose assessment used as a method to
      assess risk is not recommended at CERCLA sites.

      Please note that the references to 15 mrem/yr in OSWER
      Directive 9200.4-18 are intended as guidance  for the
      evaluation of potential ARARs and TBCs, and should not
      be used as a TBC for  establishing 15 mrem/yr cleanup
      levels  at  CERCLA sites.  At  CERCLA  sites  dose
      assessments should generally not be performed to assess
      risks  or to establish cleanup levels  except to show
      compliance with an ARAR that requires a dose assessment
      (e.g., 40 CFR 61 Subparts H and I, and 10 CFR 61.41).

Q33  How and when should exposure rate be used to estimate
      radionuclide risks?

      As  discussed previously (see Q24 and  Q27), EPA
      recommends that estimates of radiation risk should be
      derived using slope factors, in a manner analogous to
      that used for chemical contaminants.  However, there
      may be circumstances where it is desirable to also consider
      estimates  of  risk  based  on   direct   exposure  rate
      measurements of penetrating radiation. Instances where it
      may be beneficial  to also use direct measurements for
      assessing  risk  from external  exposure  to  penetrating
      radiation include:

      •  During early site assessment  efforts  when the  site
         manager is attempting to communicate the relative risk
         posed by areas containing elevated levels of radiation,

      •  As  a real-time  method for  indicating that remedial
         objectives are  being met during  the conduct of the
         response action. The use of exposure rate measurements
         during  the conduct  of the response actions may not
         decrease the need for a final status  survey.

      •  When risk estimates developed during a risk assessment
         may underestimate  the  level of risk  posed  by
         radionuclides.  An example of this situation would be
         where the source of the radiation is highly irregular
         (inside a contaminated structure) instead of being an
         infinite plane, which is the standard assumption used
         during risk assessments.

      When  developing  risk  estimates  under any  of these
      situations, risk factors from "Estimating Radiogenic Cancer
      Risks, EPA 402-R-93-076" or HEAST plus shape & area
      factor, should  be used  in conjunction with the measured
      dose rate to develop a risk estimate for external exposure to
      penetrating radiation.

      Direct radiation exposure rate measurements may provide
      important indications of radiation risks  at a site, particularly
      during early investigations, when these may be the first data
      available. However, such data may only reflect a subset of
      the  radionuclides  and  exposure pathways  of potential
      concern (e.g., only external exposure from gamma-emitting
      radionuclides in near-surface soil), and may present an
      incomplete picture  of site  risks (e.g., risk from internal
      exposures,  or  potential increased   future risks  from
      radionuclides in subsurface soils).  In most cases, more
      accurate estimation of radiation risks will require additional
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      site characterization data, including concentrations of all
      radionuclides of concern in all pertinent environmental
      media.    The  principal   benefits   of exposure  rate
      measurements is the speed and convenience of analysis,
      and the elimination of potential modeling uncertainties.
      However, these data should be used in conjunction with,
      rather   than   instead  of,  characterization   data  of
      radionuclides concentrations in environmental media to
      obtain a complete picture of potential site-related risks.

Q34. What  radiation  standards   may  be  applicable or
      relevant and appropriate requirements (ARARs)?

A.    In some cases,  cleanup levels may be derived based on
      compliance with ARARs. Attachment A "Likely Federal
      Radiation Applicable  or  Relevant  and  Appropriate
      Requirements (ARARs)" of OSWER Directive 9200.4-18
      (U.S. EPA 1997a) provides  information regarding the
      circumstances in which federal  standards that have often
      been selected as ARARs may be either applicable or
      relevant  and  appropriate  for particular  site-specific
      conditions.  It  should  be  noted  that  the Agency has
      determined that the NRC decommissioning require-
      ments (e.g., 25,100 mrem/yr dose limits) under 10 CFR
      20 Subpart E should generally not be used to establish
      cleanup levels  under CERCLA,  even  when  these
      regulations are ARARs.  OSWER Directive 9200.4-25,
      Use  of Soil Cleanup Criteria  in  40 CFR Part 192 as
      Remediation Goals for CERCLA Sites (U.S. EPA 1998c),
      provides more  detailed discussion on the use  of the
      concentration limits for radium and/or thorium in subsur-
      face soils.

V.    ECOLOGICAL ASSESSMENTS

Q35 . What guidance is  available for  conducting ecological
      risk assessments.

A.    OSWER Directive 9285.7-25, Ecological Risk Assessment
      Guidance for Superfund:  Process for Designing and
      Conducting Ecological Risk Assessments (U.S. EPA June
      1997) is intended to facilitate defensible and appropriately-
      scaled   site-specific  ecological  risk  assessments at
      CERCLA sites. This guidance  is  not intended to dictate
      the  scale,   complexity,  protocols,  data  needs,  or
      investigation methods for such assessments. Professional
      judgement is required to apply the  process outlined in this
      guidance to ecological risk assessments at specific sites.

VI.   BACKGROUND CONTAMINATION

Q36. How  should  background   levels  of  radiation be
      addressed?

A.    Background  radiation  levels  on a  specific site  will
      generally  be  determined  as  background  levels are
      determined for other contaminants, on a  radionuclide-
      specific basis when the same constituents are found in on-
      site samples as well as in background samples. The levels
      of each constituent in background are compared to that on
      site-related contaminant to determine  its impact, if any.
      Background  is  generally  measured  only  for  those
      radionuclides that are contaminants of concern and  is
      compared on a radionuclide specific basis to determine
      cleanup levels. For example, background levels for radium-
      226 and radon-222 would generally not be evaluated at a
      site  if  those  radionuclides   were  not  site-related
      contaminants.

      In certain situations background levels  of a site-related
      contaminant may equal or exceed PRGs established for a
      site. In these situations background and site-related levels
      of radiation will be  addressed as they  are  for other
      contaminants at CERCLA sites.  For further information
      regarding  background,   see  section   "Background
      Contamination" in OSWER Directive 9200.4-18 (U.S. EPA
      1997a).
WHERE TO GO FOR FURTHER INFORMATION

Attachment 1 provides a bibliography of selected EPA documents
related to radiation risk assessment.  Readers should periodically
consult the  EPA  Headquarters and Regional  Superfund and
Radiation  Program Offices for updates on current guidances and
for copies of new documents.  Copies of many of the documents
listed in Attachment 1 are available to the public for a fee from the
National Technical Information Service (NTIS) at (703) 605-6000
or (800) 553-6847. Many documents are also available from EPA
on the Internet.

Radiation  and radioactive materials pose special hazards and
require  specialized detection  instrumentation, techniques and
safety  precautions. EPA  strongly encourages  RPMs  and risk
assessors to consult with individuals trained and experienced in
radiation measurements and protection. Such individuals include
health physicists and  radiochemists who can provide additional
assistance in designing and executing radionuclide sampling and
analysis plans and interpreting radioanalytical results.

The subject matter specialists for this fact sheet are Dr. Kung-Wei
Yeh  of ORIA and Stuart Walker of OERR. General questions
about this  fact sheet should be directed to 1-800-424-9346.
REFERENCES

International Atomic Energy Agency (IAEA). 1992. Effects of
    Ionizing Radiation on Plants and Animals at Levels Implied by
    Current Radiation Protection Standards.  IAEA Technical
    Report Series No. 332.

International Commission  on Radiological Protection (ICRP).
    1977. Recommendations of the ICRP. ICRP Publication 26.
    Pergamon Press, Oxford, UK.
                                                           14

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 International Commission on Radiological Protection (ICRP).
     1979. Limits for Intakes ofRadionuclides by Workers.  ICRP
     Publication 30. Pergamon Press, Oxford, UK.

 International Commission on Radiological Protection (ICRP).
     1989. Age-Dependent Doses to Members of the Public from
     Intake of Radionuclides, Part 1.  ICRP Publication 56.
     Pergamon Press, Oxford, UK.

 International Commission on Radiological Protection (ICRP).
     1991.  7990  Recommendations  of the  International
     Commission on Radiological Protection.  ICRP Publication
     60. Pergamon Press, Oxford, UK.

 International Commission on Radiological Protection (ICRP).
     1993. Age-Dependent Doses to Members of the Public from
     Intake of Radionuclides, Part 2.  ICRP Publication 67.
     Pergamon Press, Oxford, UK.

 International Commission on Radiological Protection (ICRP).
     1995a. Age-Dependent Doses to Members of the Public from
     Intake of Radionuclides, Part 3.  ICRP Publication 69.
     Pergamon Press, Oxford, UK.

 International Commission on Radiological Protection (ICRP).
     1995b. Age-Dependent Doses to Members of the Public from
     Intake of Radionuclides, Part 4.  ICRP Publication 71.
     Pergamon Press, Oxford, UK.

 National Academy of Sciences (NAS).  1980. The Effects on
     Populations of  Exposure to  Low  Levels  of Ionizing
     Radiation: 1980.  National Research Council, Committee on
     the Biological Effects of Ionizing Radiation (BEIR III).
     National Academy Press, Washington, DC.

 National Academy of Sciences (NAS).  1988. Health Effects of
     Radon and Other Internally Deposited Alpha-Emitters
     National Research Council, Committee on the  Biological
     Effects of Ionizing Radiation (BEIR IV). National Academy
     Press., Washington, DC.

 National Academy of Sciences (NAS).  1990. Health Effects of
     Exposure to Low  Levels of Ionizing Radiation.  National
     Research Council, Committee on the Biological Effects of
     Ionizing Radiation (BEIR V). National Academy Press.,
     Washington, DC.

 National Council on  Radiation Protection and Measurements
     (NCRP).   1976. Environmental Radiation Measurements.
    NCRP Report No. 50. Bethesda, MD.

National Council on Radiation Protection and Measurements
    (NCRP). 1978. Instrumentation and Monitoring Methods for
    Radiation Protection. NCRP Report No. 57. Bethesda, MD.

National Council on Radiation  Protection and Measurements
    (NCRP).  1987. Exposure of the Population in the United
    States and Canada from Natural Background Radiation.
    NCRP Report No. 94. Bethesda, MD.

United Nations Scientific Committee on the Effects of Atomic
    Radiation (UNSCEAR). 1988. Sources, Effects and Risks of
    Ionizing Radiation. United Nations, NY.

U.S. EPA. 1980. Upgrading Environmental Data: Health Physics
    Society Committee  Report  HPSR-1 (1980).   Office of
    Radiation Programs,  Washington, DC.

U.S.  EPA. 1984.  EERF Radiochemistry Procedures Manual.
    EPA 520/5-84-006.  Office of Radiation Programs, Eastern
    Environmental Radiation Facility, Montgomery, AL.

U.S.   EPA.   1988a.   Guidance for  Conducting Remedial
    Investigations and  Feasibility  Studies  Under  CERCLA.
    EPA/540/G-89/004.   Office  of  Radiation   Programs,
    Washington, DC.

U.S. EPA.  1988b. Limiting Values of Radionuclide Intake and
    Air  Concentration  and Dose  Conversion  Factors for
    Inhalation, Submersion, and Ingestion:  Federal Guidance
    Report No.  11. EPA-520/1-88/020. Office of Radiation
    Programs, Washington, DC.

U.S.  EPA.  1989a.  Risk Assessment Guidance for Superfund,
    Volume I: Human Health Evaluation Manual, Part A, Interim
    Final.  EPA/540/1-89/002.    Office of Emergency  and
    Remedial Response,  Washington, DC. NTIS PB90-155581/
    CCE.

U.S. EPA. 1989b. Methods for Evaluating the Attainment of Soil
    Cleanup Standards.  Volume I: Soils and Solids. EPA/540/1 -
    89/003. Statistical Policy Branch, Office of Policy, Planning,
    and Evaluation, Washington,  DC.

U.S. EPA. 1989c. Risk Assessment Methodology: Environmental
    Impact Statement—NESHAPsfor Radionuclides, Background
    Information Document—Volume I. EPA-520/1-89-006-1.
    Office of Radiation Programs, Washington, DC.

U.S.  EPA.  1990.  Exposure Factors Handbook.  EPA/600/8-
    89/043. Office of Health and Environmental Assessment,
    Washington, DC.

U.S.  EPA. 199la.  Risk Assessment Guidance for Superfund,
    Volume I: Human  Health  Evaluation  Manual (Part B,
    Development of Risk-Based Preliminary Remediation Goals).
    Publication 9285.7-0 IB. Office of Emergency and Remedial
    Response, Washington, DC. NTIS PB92-963333.

U.S.  EPA. 1991b.  Risk Assessment Guidance for Superfund,
    Volume I: Human Health Evaluation Manual (Part C, Risk
    Evaluation of Remedial Alternatives).  Interim. OSWER
    Directive 9285.7-01C. Office of Emergency and Remedial
    Response, Washington, DC.

U.S.   EPA.   1991c.    Human  Health  Evaluation  Manual,
                                                          15

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    Supplemental Guidance: StandardDefaultExposureFactors.
    OSWER 9285.6-03. Office  of Emergency and Remedial
    Response, Washington, DC. NTIS PB91-921314.

  U.S. EPA. 199Id.  Role of the Baseline Risk Assessment in
  Superfund Remedy Selection Decisions.  OSWER Directive
  9355.0-30. Office of Solid Waste and Emergency Response.

 U.S.   EPA.   1992a. Statistical Methods for Evaluating  the
    Attainment of Cleanup Standards—Volume2: Ground Water.
    Draft. Statistical Policy Branch, Office of Policy, Planning,
    and Evaluation, Washington, DC.

 U.S.   EPA.   1992b. Statistical Methods for Evaluating  the
    Attainment of Cleanup Standards—Volume 3: Reference-
    Based Standards for Soils and Solid Media. PB94  176831.
    Statistical Policy Branch,  Office of Policy, Planning, and
    Evaluation, Washington, DC.

 U.S.   EPA.   1992c. Guidance  for  Data  Useability  in Risk
    Assessment (Part A).  Publication  9285.7A.   Office  of
    Emergency and Remedial Response, Washington, DC.

 U.S.   EPA.   1992d. Guidance  for  Data  Useability  in Risk
    Assessment (Part B).  Publication  9285.7B.   Office  of
    Emergency and Remedial Response, Washington, DC.

 U.S. EPA.  1992e. Guidance on Risk Characterization for Risk
    Managers and  Risk Assessors.  Memorandum from F.H.
    Habicht, Deputy Administrator, Washington, DC, 2/26/92.

 U.S.   EPA. Implementing the  Deputy Administrator's Risk
    Characterization Memorandum. Memorandum from H.L.
    Longest, Director of Office  of Emergency and Remedial
    Response, Washington, DC, 5/26/92.

 U.S.  EPA.  1993a.  Data Quality Objectives for Superfund,
    Interim Final Guidance.  EPA 504-R-93/071.  Office  of
    Emergency and Remedial Response,  Washington, DC. NTIS
    PB94-963203.

 U.S. EPA. 1993b.  External Exposure to Radionuclides in Air,
    Water, and Soil: Federal Guidance Report No. 12. EPA-402-
    R-93-081. Office of Air and Radiation, Washington, DC.

 U.S. EPA.  1994a.   Guidance for the Data Quality Objectives
    Process.    EPA  QA/G4.   Office   of  Research  and
    Development.

 U.S. EPA. 1994b. Estimating Radiogenic Cancer Risks.  EPA
    402-R-93-076.    Office of  Radiation  and  Indoor Air,
    Washington, DC.

U.S.  EPA.   1995a. Guidance for Data Quality  Assessment.
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    Washington, DC.
U.S.   EPA.  1995b. EPA  Risk Characterization Program.
    Memorandum  from  Carol  Browner,  Office  of  the
    Administrator, Washington, DC, 3/21/95.

U.S.  EPA.   1996. Radiation Exposure and Risk Assessment
    Manual: Risk Assessment Using Radionuclide Slope Factors.
    EPA 402-R-96-016,  Office of Radiation and  Indoor Air,
    Washington, DC, June 1996.

 U.S. EPA. 1997a. Establishment of 'Cleanup Levels for CERCLA
   Sites with Radioactive Contamination, OSWER No. 9200.4-
   18, August 1997.

 U.S.  EPA.  1997b.  Exposure Factors Handbook (Update).
   EPA/600/P-95/002F. Office of Research and Development,
   Washington, DC, August 1997.

 U.S. EPA.  1997c.  Use of Probabilistic Techniques (Including
   Monte Carlo Analysis) in Risk Assessment, Memorandum from
   Deputy Administrator Hansen, August 1997.

 U.S. EPA. 1997d. Guiding Principles for Monte Carlo Analysis,
   EPA/630/R-97-001.

 U.S. EPA.  1998a.  Risk Assessment Guidance for Superfund,
   Volume  I: Human Health  Evaluation  Manual,  Part D,
   Standardized Planning, Reporting, and Review of Superfund
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   Response, Washington, DC.

 U.S.  EPA.  1998b. Risk Assessment Guidance for Superfund,
   Volume  I:  Human  Health  Evaluation  Manual,  Part  E,
   Supplemental Guidance to RAGS: The Use of Probabilistic
   Analysis in Risk Assessment. (Working Draft).  Office  of
   Emergency and Remedial Response, Washington, DC.

 U.S.  EPA. 1998c. Use of Soil Cleanup Criteria in 40 CFR Part
   192 as Remediation Goals for CERCLA Sites,   OSWER
   Directive No. 9200.4-25, February 1998.

 U.S.  EPA. 1998d, Soil Screening Guidance for Radionuclides:
   User's Guide (Draft). Office of Emergency and Remedial
   Response, Washington, DC. August 1998.

 U.S.  EPA.  1998e. Integrated Risk Information System (IRIS).
   Cincinnati, OH.

 U.S.  EPA.  1998f. Health Effects Summary Tables (HEAST);
   Annual  Update,  FY1998.  Environmental  Criteria  and
   Assessment Office, Office of Health and Environmental
   Assessment, Office of Research and Development, Cincinnati,
   OH.

 U.S. EPA. 1998g. Health Risks from Low-Level Environmental
   Exposure to Radionuclides: Federal Guidance Report No. 13 -
   Part I, Interim Version. EPA 402-R-97-014. Office of Air and
   Radiation, Washington, DC.
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U.S. EPA.  1998H. Radiation Exposure and Risk Assessment
  Manual: Risk Assessment Using Radionuclide Slope Factors
  Derived Under Federal Guidance Report No. 13.  (Draft),
  Office of Radiation and Indoor Air, Washington, DC.

U.S. EPA, NRC, U.S. DOE, and U.S. Department of Defense.
  1997. Multi-Agency Radiation Survey and Site Investigation
  Manual (MARSSIM). NUREG-1575, EPA 402-R-97-016,
  Washington, DC.

U.S. EPA, NRC, U.S. DOE, and U.S. Department of Defense.
  1998.   Multi-Agency  Radiation  Laboratory  Analytical
  Protocols(MARLAP). Washington,DC. (Under Development)
                                                       17

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                                               ATTACHMENT #1

                                         Bibliography of Selected EPA
                         Guidance Documents and Directives on Risk Assessment
 U.S. ENVIRONMENTAL PROTECTION AGENCY

 EPA Human Health Risk Assessment

 •  Risk Assessment  Guidance for  Superfund:  Volume I:
    Human Health Evaluation Manual, Part A, Interim Final.
    EPA/540/1-89/002.  Office of Emergency and Remedial
    Response, Washington, DC, March 1989.
 •  Role of the Baseline Risk Assessment in Superfund Remedy
    Selection Decisions.  OSWER Directive 9355.0-30. ^Office
    of Solid Waste and Emergency Response, Washington, DC.
    April 22, 1991.
 •  Guidance on Risk Characterization for Risk Managers and
    Risk Assessors. Memorandum from Deputy Administrator,
    U.S. Environmental  Protection Agency  H. Habicht  to
    Assistant and Regional Administrators. Feb. 26, 1992.

 EPA Ecological Risk Assessment

 •  Risk Assessment Guidance for Superfund:  Volume II:
    Environmental  Evaluation  Manual,  Interim Final.
    EPA/540/1-89/001.  Office of Emergency and Remedial
    Response, Washington, DC.  March 1989.
 •  Ecological Assessment of Hazardous Waste Sites: A Field
    and Laboratory Reference.  EPA/600/3-89/013.  Environ-
    mental Research Laboratory, CorvaHis, OR. March 1989.
 •  Framework for Ecological Risk Assessment. EPA/630/R-
    92/001. Risk Assessment Forum, Washington, DC. Febru-
    ary  1992.

 EPA Exposure Assessment

 •  Superfund Exposure Assessment Manual. OSWER Direc-
    tive 9285.5-1.  EPA/540/1-88/001.  NTIS PB89-135859.
    Office of Emergency and Remedial Response, Washington,
    DC.  April 1988.
 •  Guidelines for Exposure Assessment. Federal Register, Vol.
    57,  No.  104,  pp 22888-22938, Office of Health and
    Environmental Assessment, Washington, DC. 5/22/92.

 EPA Standard  Exposure Scenarios and Default Ex-
 posure Factors

 •  Exposure Factors Handbook: Final Report. EPA/600/8-
    89/043. Office of Health  and Environmental Assessment,
    Office of Research and Development, Washington, DC.
    March 1989.
•  Exposure Factors Handbook (Update).  EPA/600/P-95/
    002F. Office of Research and Development, Washington,
    DC. August  1997.
•   Human Health Evaluation Manual, Supplemental Guid-
    ance:  Standard Default Exposure Factors.   OSWER
    Directive 9285.6-03. Office of Emergency and Remedial
    Response, Washington, DC. March 25, 1991.
•   Radiation Site Cleanup Regulations:  Technical Support
    Document for the Development of Radionuclide Cleanup
    Levels for Soil (Review Draft).  Office of Air and Radiation,
    Washington, DC.  September 1994.
•   Soil Screening Guidance: User's Guide. EPA/540/R-
    96/018,  Office of Emergency and Remedial Response,
    Washington, DC.  June 1996.
•   Soil Screening Guidance: Technical Background Docu-
    ment.  EPA/540/R-96/128,  Office of   Emergency and
    Remedial Response, Washington, DC. June 1996.

EPA-Approved  Toxicity Criteria

•   IntegratedRiskInformationSystem(lRlS). Cincinnati,OH.
•   Health Effects Assessment Summary Tables (HEAST).
    Annual Update, FY 1997. Environmental Criteria and
    Assessment Office, Office of Health and Environmental
    Assessment,  Office  of  Research  and.  Development,
    Cincinnati, OH. 1997.
•   Limiting Values of Radionuclide Intake and Air Concentra-
    tion and Dose Conversion Factors for Inhalation, Submer-
    sion,  and Ingestion:  Federal Guidance Report No. 11.
    EPA-520/1-88-020.    Office  of  Radiation  Programs,
    Washington, DC. September 1988.
•   External Exposure to Radionuclides in A ir, Water, and Soil:
    Federal Guidance Report No. 12.  EPA 402-R-93-081.
    Office of Air  and Radiation. September 1993.
•   Health Risks from Low-Level Environmental Exposure to
    Radionuclides: Federal Guidance Report No. 13 - Part 1
    (Interim Version).  EPA402-R-97-014. Office of Air and
    Radiation. January 1998.

EPA Methods for Deriving Preliminary Remediation
Goals and Soil Screening Levels

•   Risk Assessment  Guidance for Superfund:  Volume  I:
    Human Health Evaluation Manual, Part B, Development of
    Risk-Based Preliminary Remediation  Goals,  Interim.
    EPA/540/R-92/003. Office of Research and Development,
    Washington, DC.  December 1991.
•   Soil Screening Guidance: User's  Guide. EPA/540/R-
    96/018,  Office of Emergency and Remedial Response,
    Washington, DC.  June 1996.
•   Soil Screening Guidance: Technical Background Docu-
    ment.  EPA/540/R-96/128, Office  of   Emergency and
    Remedial Response, Washington, DC. June 1996.
•   Soil Screening Guidance for Radionuclides: User's Guide
    (Draft). Office of Radiation and Indoor Air and Office of
    Emergency and Remedial Response, Washington,  DC.
    September 1998.
                                                     A1-1

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                                        ATTACHMENT #1 (Continued)

                                        Bibliography of Selected EPA
                         Guidance Documents and Directives on Risk Assessment
 EPA Modeling

 •  OSWER Models Study:  Promoting Appropriate Use of
    Models in Hazardous Waste /Superfund'Programs: Phase
    I:  Final Report.   Office of Program Management and
    Technology, Office of Solid Waste and Emergency Re-
    sponse, Washington, DC.  May 26, 1989.
 •  OSWER Models Management Initiative: Report on the
    Usage of Models in Hazardous Waste / Superfund Pro-
    grams: Phase II: Final Report. Office of Program Man-
    agement and Technology,  Office  of Solid  Waste  and
    Emergency Response, Washington, DC.  December 1990.
 •  Environmental Pathway Models—Ground- Water Modeling
    in Support of Remedial Decision Making at Sites Contami-
    nated with Radioactive Material.   EPA 402-R-93-009.
    Office of Air and Radiation, Washington, DC. March 1993.
 •  Frameworkfor Assessing Groundwater Modeling Applica-
    tions.  EPA-500-B-94-004. Resource Management and
    Information Staff, Office of Solid Waste and Emergency
    Response,  Washington, DC.  1994.
 •  Groundwater Modeling Compendium,  Second Edition.
    EPA-500-B-94-003. Resource Management and Informa-
    tion Staff, Office of Solid Waste and Emergency Response,
    Washington,  DC. 1994.
 •  Modifications to the PRESTO-CPG Code to Facilitate the
    Analysis of Soil Contamination Sites.  RAE-9231/6-1.
    Rogers &  Associates Engineering  Corporation with S.
    Cohen & Associates, Inc.  Jan. 14, 1994.

 EPA Data Quality/Data Control (QA/QC) and Data
 Useability

 •  Soil Sampling  Quality Assurance User's Guide.   EPA
    600/4-84-0043.  Office  of Emergency and  Remedial
    Response,  Washington, DC. May 1984.
 •  Guidance for Data Useability in Risk Assessment (Part A):
    Final Advance Copy. Publication  9285.7A.   Office of
    Emergency and Remedial Response, Washington, DC.
    April  1992. [Covers data Useability for hazardous chemi-
    cals.]
 •  Guidance for Data Useability in Risk Assessment (Part B):
    Final.  Publication 9285.7B.  PB92-963362.  Office of
    Emergency and Remedial Response, Washington, DC. May
    1992. [Covers data useability for radionuclides.]
•  Data  Quality Objectives for Superfund: Interim Final
    Guidance.  EPA 540-R-93-071.  Publication 9255.9-01.
    NTIS  PB92-96338. Office of Emergency and Remedial
    Response, Washington, DC.  1993.
•   Quality Assurance for Superfund Environmental Data
    Collection Activities.  Quick Reference Fact Sheet.  NTIS
    PB93-963273.Office  of Emergency and Remedial Re-
    sponse, Washington, DC.  1993.
•   Guidance for the Data Quality Objectives Process: Final.
    EPA QA/G-4.   Quality Assurance Management Staff,
    Office of Research and Development, Washington, DC.
    September 1994.
•   Guidance for the Data Quality Assessment.  EPA/600/R-
    96/084.  Quality Assurance Management Staff, Office of
    Research and Development, Washington,  DC. January
    1998.

EPA Statistical Methods for Compliance Demonstra-
tion

•   Methods for Evaluating the Attainment of Soil Cleanup
    Standards: Volume I: Soil and Soil Media.  EPA 230/02-
    89-042.   Office  of  Policy, Planning  and Evaluation,
    Washington, DC. February 1989.
•   Statistical  Methods for Evaluating the Attainment  of
    Cleanup Standards: Volume 2 .'Ground Water. Draft Office
    of Policy,  Planning  and  Evaluation, Washington, DC.
    February 1992.
•   Statistical  Methods for Evaluating the Attainment  of
    Cleanup Standards: Volume 3: Reference-Based Standards
    For Soils and Solid Media. PB94 176831. Office of Policy,
    Planning and  Evaluation, Washington, DC.  December
    1992.
•   Guidance for the Data  Quality Assessment: External
    Working Draft. EPAQA/G-9. Quality Assurance Manage-
    ment  Staff,  Office  of  Research  and Development,
    Washington, DC. March 27,  1995.

EPA Survey/Measurement Methods

•   Samplers and Sampling Procedures for Hazardous Waste
    Streams. EPA 600/2-80-018. Environmental Monitoring
    and Support Laboratory, Cincinnati, OH. 1980.
•   Handbookfor Sampling and Sample Preservation of Water
    and Wastewater.   EPA-600/4-82-029.   PB83-124503.
    Environmental  Monitoring   and Support  Laboratory,
    Cincinnati, OH. September 1982.
•   Eastern Environmental Radiation Facility: Radiochemistry
    Procedures Manual. EPA 520/5-84-006. Eastern Environ-
    mental Radiation Facility, Montgomery, AL. August 1984.
•   A Compendium of Superfund Field Operations Methods.
    EPA/540/P-87/001. OSWER Directive 9355.0-14. Office
    of Emergency and Remedial  Response, Washington, DC.
    December 1987.
•   Field Screening Methods Catalog—User's Guide. EPA
    540/2-88-005.  Office of Emergency and Remedial Re-
    sponse, Washington, DC. September 1988.
                                                      A1-2

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                                  ATTACHMENT #1 (Continued)

                                  Bibliography of Selected EPA
                   Guidance Documents and Directives on Risk Assessment
Compendium of ERTGround Water Sampling Procedures.
EPA 540/P-91-005. PB91-921274/CCE. January 1991.
Compendium of ERT Soil Sampling andSurfaceGeophysics
Procedures.   EPA 540/P-91-006.   PB91-921273/CCE.
January 1991.
Compendium of ERT Ground Water Sampling Procedures.
EPA 540/P-91-007. PB91-921275/CCE. January 1991.
Description and Sampling of Contaminated Soils.  EPA
625/12-91-002. Office of Emergency and Remedial Re-
sponse, Washington, DC. November 1991.
User's Guide to the Contract Laboratory Program. PB91 -
921278CDH.  Office of Emergency and Remedial Re-
sponse, Washington, DC. 1991.
                                               A1-3

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