xvEPA
         United States
         Environmental Protection
         Agency
Office of Radiation
and Indoor Air
Office of Solid Waste and
Emergency Response
Washington, DC 20460
9355.4-16A
EPA/540-R-00-007
PB2000 963307
October 2000
         ORIA/Superfund
         Soil  Screening
         for Radionuclides: User's
         Guide

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                                 EPA/540-R-00-007
                                    October 2000
Soil Screening Guidance
    for Radionuclides:
        User's Guide
      Office of Radiation and Indoor Air
  Office of Emergency and Remedial Response
    U.S. Environmental Protection Agency
         Washington, DC 20460

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                                       ACKNOWLEDGMENTS
The development of this guidance was a team effort led by the staff of the Office of Radiation and Indoor Air (ORIA), and the
Office of Emergency and Remedial Response (OERR). Phil Newkirk and Ron Wilhelm of ORIA, and Stuart Walker of OERR,
are the principal EPA authors of the document, with significant contributions from Ken Lovelace and Janine Dinan of OERR.

Early drafts of this document and the Technical Background Document were prepared by Sandy Cohen and Associates (SC&A)
under EPA Contract 68D70073.  John Mauro of SC&A led their team effort.

In addition, the authors would like to thank all EPA reviewers whose careful review and thoughtful comment greatly contributed
to the quality of this document.

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                                                DISCLAIMER
Notice: The Soil Screening Guidance is based on policies set out in the Preamble to the Final Rule of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), which was published onMarch 8,1990 (55 Federal Register 8666).

This guidance document sets forth recommended approaches based on EP A's best thinking to date with respect to soil screening
for radionuclides. This document does not establish binding rules. Alternative approaches for screening radionuclides in soil
may be found to be more appropriate at specific sites (e.g., where site circumstances do not match the underlying assumptions,
conditions and models of the guidance).  The decision whether to use an alternative approach and a description of any such
approach should be placed in the Administrative Record for the site.  Accordingly, if comments are received at individual sites
questioning the use of the approaches recommended in this guidance, the comments should be considered and an explanation
provided for the selected approach. The Soil Screening Guidance for Radionuclides: Technical Background Document (TBD)
may be helpful in responding to such comments.

The policies set out in both the Soil Screening Guidance for Radionuclides: User's Guide and the supporting TBD are intended
solely as guidance to the 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 government. EPA officials may decide to follow the guidance provided in this document, or
to act at variance with the guidance, based on an analysis of specific site circumstances. EPA also reserves the right to change
the guidance at any time without public notice.

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                                        TABLE OF CONTENTS
1.0 INTRODUCTION  	   1-1
    1.1      Purpose  	1-1
    1.2      Role of Soil Screening Levels	1-2
    1.3      Scope of Soil Screening Guidance for Radionuclides	1-6
2.0 SOIL SCREENING PROCESS	    2-1
    2.1      Step 1: Developing a Conceptual Site Model	    2-1
            2.1.1   Collect Existing Site Data 	    2-1
            2.1.2   Organize and Analyze Existing Site Data 	    2-1
            2.1.3   Construct a Preliminary Diagram of the CSM  	    2-3
            2.1.4   Perform Site Reconnaissance 	    2-3
    2.2      Step 2: Comparing CSM to SSL Scenario  	    2-3
            2.2.1   Identify Pathways Present at the Site Addressed by Guidance  	    2-3
            2.2.2   Identify Additional Pathways Present at the Site Not Addressed by Guidance  	   2-4
            2.2.3   Compare Available Data to Background	   2-4
    2.3      Step 3: Defining Data Collection Needs for Soils   	   2-5
            2.3.1   Stratify the Site Based on Existing Data 	   2-5
            2.3.2   Identify Exposure Areas  	   2-6
            2.3.3   Develop Sampling and Analysis Plan for Surface Soil	   2-6
            2.3.4   Develop Sampling and Analysis Plan for Subsurface Soils  	  2-11
            2.3.5   Develop Sampling and Analysis Plan to Determine Soil Characteristics 	  2-13
            2.3.6   Determine Analytical Methods and Establish QA/QC Protocols  	  2-14
    2.4      Step 4: Sampling and Analyzing Site Soils & DQA  	  2-15
            2.4.1   Delineate Area and Depth of Source 	  2-15
            2.4.2   Perform DQA Using Sample Results  	  2-15
            2.4.3   Revise the CSM	  2-18
    2.5      Step 5: Calculating Site-specific SSLs   	  2-18
            2.5.1   SSL Equations-Surface Soils 	  2-19
            2.5.2   SSL Equations-Subsurface Soils  	  2-24
            2.5.3   Address Exposure to Multiple Radionuclides   	  2-28
    2.6      Step 6: Comparing Site Soil Radionuclide Concentrations to Calculated SSLs  	  2-29
            2.6.1   Evaluation of Data for Surface Soils 	  2-29
            2.6.2   Evaluation of Data for Subsurface Soils 	  2-30
    2.7      Step 7: Addressing Areas Identified for Further Study  	  2-30
REFERENCES  	   R-l
                                                     in

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                                TABLE OF CONTENTS (continued)
ATTACHMENTS
    A.     Conceptual Site Model Summary	 A-l
    B.     Soil Screening DQOs for Surface Soils and Subsurface Soils
           for Radionuclides Not Present in Background  	B-l
    C.     Radiological Properties for SSL Development  	 C-l
    D.     Regulatory and Human Health Radiological Benchmarks Used for SSL Development	 D-l



                                          LIST OF EXHIBITS


Exhibit 1        Conceptual Risk Management Spectrum for Contaminated Soil  	1-2
Exhibit 2        Exposure Pathways Addressed by SSLs for Radionuclides 	1-7
Exhibit 3        Key Attributes of the User's Guide	1-7
Exhibit 4        Soil Screening Process for Radionuclides	2-2
Exhibit 5        Data Quality Objectives Process	2-8
Exhibit 6        Defining the Study Boundaries	2-9
Exhibit 7        Designing a Sampling and Analysis Plan for Surface Soils 	2-12
Exhibit 8        Designing a Sampling and Analysis Plan for Subsurface Soils 	2-16
Exhibit 9        U.S. Department of Agriculture Soil Texture Classification	2-17
Exhibit 10      Q/C Values by Source Area, City, and Climatic Zone 	2-21
Exhibit 11      Site-Specific Parameters for Calculating Subsurface SSLs	2-25
Exhibit 12      Simplifying Assumptions for the SSL Migration to Ground Water Pathway	2-26
                                                   IV

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                                        LIST OF ACRONYMS
ARAR
ASTM
CERCLA
CLP
CSM
CV
DAF
DQA
DQO
EA
EPA
HEAST
HELP
HHEM
IRIS
ISC2
MARSSIM
MCL
MDC
NPL
NTIS
OERR
ORIA
PA/SI
PEF
PRO
QAPP
Q/C
QA/QC
RAGS
RCRA
RfD
RI
RI/FS
RME
ROD
SAB
SAP
SSL
TBD
USDA
WRS
Applicable or Relevant and Appropriate Requirement
American Society for Testing and Materials
Comprehensive Environmental Response, Compensation and Liability Act
Contract Laboratory Program
Conceptual Site Model
Coefficient of Variation
Dilution Attenuation Factor
Data Quality Assessment
Data Quality Objective
Exposure Area
Environmental Protection Agency
Health Effects Assessment Summary Table
Hydrological Evaluation of Landfill Performance
Human Health Evaluation Manual
Integrated Risk Information System
Industrial Source Complex Model
Multi-Agency Radiation Survey and Site Investigation Manual
Maximum  Contaminant Level
Minimum Detectable  Concentration
National Priorities List
National Technical Information Service
Office of Emergency and Remedial Response
Office of Radiation and Indoor Air
Preliminary Assessment/Site Inspection
Paniculate Emission Factor
Preliminary Remediation Goal
Quality Assurance Project
Site-Specific Dispersion Model
Quality Assurance/Quality Control
Risk Assessment Guidance for Superfund
Resource Conservation and Recovery Act
Reference Dose
Remedial Investigation
Remedial Investigation/Feasibility Study
Reasonable Maximum Exposure
Record of Decision
Science Advisory Board
Sampling and Analysis Plan
Soil Screening Level
Technical Background Document
U.S. Department of Agriculture
Wilcoxon Rank Sum

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             1.0  INTRODUCTION
1.1     Purpose

The Soil Screening Guidance for Radionuclides is a tool
that the U.S. Environmental Protection Agency (EPA)
developed  to  help  standardize  and  accelerate  the
evaluation  and cleanup of soils contaminated with
radioactive materials at sites on the National Priorities
List  (NPL) with  future residential land use.1  This
guidance provides a methodology for environmental
science/engineering professionals with a background in
radiological risk assessmentto calculate risk-based, site-
specific, soil screening levels (SSLs) for radionuclides
in soil that may be used to identify areas needing further
investigation at NPL sites. :

SSLs are not national cleanup standards. SSLs alone
do not trigger the need for response actions or define
"unacceptable" levels of radionuclides in soil.  In this
guidance,   "screening"  refers to  the   process   of
identifying and  defining  areas,  radionuclides,  and
conditions, at a particular site that do not require further
Federal attention. Generally, at sites where radionuclide
concentrations fall below SSLs,  no further action or
study  is   warranted   under  the  Comprehensive
Environmental Response, Compensation  and Liability
Act  (CERCLA).    Generally,  where  radionuclide
concentrations equal  or exceed SSLs, further study or
investigation, but not necessarily cleanup, is warranted.

This radionuclide SSL guidance  is a continuation of
other EPA documents related to  SSL for chemicals.
These include EPA's Soil Screening Guidance: User's
Guide  (U.S.  EPA,  1996a)  and the Soil Screening
Guidance: Technical Background'Document(U.S. EPA,
1996b) that apply the SSL framework to NPL sites with
hazardous organic and  inorganic  soil contaminants.
They do not address sites with radioactive contaminants.
These   documents  provide  standardized  exposure
equations for deriving generic and site-specific SSLs for
chemicals under a residential land use setting, assuming
three soil exposure pathways—soil ingestion, inhalation
         Note that the Superfimd program defines "soil" as having a
particle size under 2 mm, while the RCRA program allows for particles
under 9 mm in size.
of volatiles  and fugitive  dusts,  and  ingestion of
contaminated ground water.  Chemical- specific SSLs
are based on a target risk of one-in-a-million (10~6) for
carcinogens, a hazard quotient of 1 for noncarcinogens,
or, for the ground water migration pathway, a nonzero
maximum contaminant level goal (MCLG), maximum
contaminant level (MCL), or a risk-based level.  For
each contaminant, the lowest pathway-specific SSL is
selected as the appropriate screening level.

An overview of a comparison between the key features
of the soil screening  frameworks for chemicals and
radionuclides is provided in Table 1 below. Much of the
guidance  for radionuclides  is  based  on or  cites
information presented in the chemical Soil Screening
Guidance  documents.  Users are therefore  strongly
encouraged to become familiar with these documents.

This guidance elaborates a framework developed for soil
screening levels for radionuclides that is consistent and
compatible with the SSL framework for chemicals.
Radionuclide SSLs  are risk-based  concentrations, in
activity units of picocuries per gram of soil (pCi/g),
derived from equations combining exposure information
assumptions with EPA radiotoxicity data. This User's
Guide focuses on the application  of a simple  site-
specific  approach   by  providing  a  step-by-step
methodology to calculate site-specific SSLs and is part
of a larger framework that includes both generic and
more detailed approaches to calculating screening levels.
The   Soil Screening  Guidance for  Radionuclides:
Technical Background Document (TBD) (U.S.  EPA,
2000), provides detailed information about these other
approaches.   Generic  SSLs for the  most common
radionuclides found at NPL sites are included in the
TBD.  Generic  SSLs are calculated from the  same
equations presented in this guidance, but are based on a
number of default assumptions chosen to be protective
of human health for most site conditions. Generic SSLs
can be used in place of site-specific screening levels;
however,  in general, they are  expected to be  more
conservative than site-specific levels. The site manager
should weigh the cost of collecting the data necessary to
develop  site-specific  SSLs  with  the  potential  for
deriving a higher SSL that provides an appropriate level
of protection.

The framework presented in the TBD also includes more
detailed modeling approaches for developing screening
levels  that  take into  account  more  complex site
conditions than the  simple  site-specific methodology
                                                  1-1

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emphasized in this guidance. More detailed approaches
may be appropriate when site conditions (e.g.,  very
deep water table, very thick uncontaminated unsaturated
zone, soils underlain by karst or fractured rock aquifers)
are different from those assumed in the simple site-
specific methodology presented here.   The technical
details supporting the methodology used in this guidance
are provided in the TBD.

SSLs developed in accordance with this guidance are
based on future residential land use  assumptions and
related exposure pathways. Using this guidance for sites
where  residential land use assumptions do not apply
could result in overly conservative screening levels;
however, EPA recognizes that some parties responsible
for sites with non-residential land use might still find
benefit  in  using  the  SSLs as  a tool  to  conduct a
conservative initial screening.

SSLs developed in accordance with this guidance could
also be used for Resource Conservation and Recovery
Act (RCRA) corrective action sites as "action levels,"
since the RCRA  corrective action program currently
views the role of action levels as generally fulfilling the
same purpose as  soil screening levels.2 In addition,
States may use this guidance in their voluntary cleanup
programs, to the extent they deem appropriate. When
applying SSLs to RCRA corrective action sites or for
sites under State voluntary cleanup programs, users of
this guidance should  recognize, as stated above, that
SSLs are based on residential land use assumptions.
Where these assumptions do not apply, other approaches
for determining the need for further study might be more
appropriate.

1.2     Role of Soil Screening  Levels

In identifying  and  managing  risks at  sites,  EPA
considers  a spectrum of radionuclide concentrations.
The   level  of  concern   associated   with  those
concentrations depends on the likelihood of exposure to
radioactive soil  contamination  at levels of potential
concern to human health.

Exhibit 1 illustrates the spectrum of soil contamination
encountered at Superfund sites and the conceptual range
of risk management responses. At one end are levels of
contamination that clearly warrant a response action; at
the  other end are levels that warrant no further study
under CERCLA.   Screening levels identify the lower
bound of the  spectrum—levels  below  which  EPA
believes no further study is warranted under CERCLA,
provided conditions associated with the SSLs are met.
Appropriate cleanup goals for a particular site may fall
anywhere within this range depending on site-specific
conditions.
      No further study
      warranted under
        CERCLA
      Site-specific
        cleanup
       goal/level
     Response
    action clearly
     warranted
   "Zero"
concentration
Screening
  level
Response
  level
 Very high
concentration
 Exhibit 1. Conceptual Risk Management Spectrum
              for Contaminated Soil
         Further information on the role of action levels in the RCRA
corrective action program is available in an Advance Notice of Proposed
Rulemaking (signed April 1996).
EPA anticipates the use of SSLs as a tool to facilitate
prompt identification of radionuclides and exposure
areas of concern during both remedial actions and some
removal  actions  under  CERCLA.   However,  the
application of this or any screening methodology is not
mandatory at sites being addressed under CERCLA or
RCRA.  The framework leaves discretion to the site
manager and technical experts (e.g.,  risk assessors,
hydrogeologists) to  determine whether  a  screening
approach is appropriate for the site and, if screening is
to be used, the proper method  of implementation. If
comments are received at individual sites questioning
the use  of  the  approaches  recommended in  this
guidance, the comments should be  considered and an
explanation provided as part of the site's Record of
Decision (ROD).  The decision to use a  screening
approach should be  made early  in the process of
investigation at the site.

EPA  developed the  Soil Screening  Guidance  for
Radionuclides to be consistent with and to enhance the
current Superfund investigation process and anticipates
its primary use during the early stages of a remedial
investigation (RI) at NPL sites.  It does not replace the
Remedial Investigation/Feasibility Study (RI/FS) or risk
assessment, but use of screening levels can focus the RI
and risk assessment on aspects of the site that are more
likely to be a concern under CERCLA. By screening out
                                                   1-2

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areas of sites, potential radionuclides of concern, or
exposure  pathways  from further investigation,  site
managers and technical experts can limit the scope of
the remedial investigation or risk assessment. SSLs can
save resources by helping to determine which areas do
not require  additional Federal  attention early in the
process.   Furthermore, data gathered during  the  soil
screening process can be used in later Superfund phases,
such as the baseline risk assessment, feasibility study,
treatability study, and remedial design.  This guidance
may also be appropriate for use by the removal program
when demarcation of soils above residential risk-based
numbers coincides with the purpose and scope of the
removal action.

The process presented in this guidance to develop and
apply simple, site-specific soil screening levels is likely
to be most  useful where it is  difficult to determine
whether areas of soil are contaminated to an extent that
warrants further investigation or response (e.g., whether
areas of soil at an NPL site require further investigation
under CERCLA through an RI/FS). As noted above, the
screening levels  have   been  developed  assuming
residential land use. Although some of the models and
methods presented in this guidance could be modified to
address exposures under other land uses, EPA has not
yet standardized assumptions for those other uses.

Applying  site-specific   screening   levels  involves
developing a conceptual site model (CSM), collecting a
few easily obtained site-specific soil parameters (such as
the dry bulk density and percent moisture), and sampling
to measure radionuclide levels in surface and subsurface
soils. Often, much of the information needed to develop
the  CSM  can  be  derived  from previous   site
investigations [e.g., the Preliminary Assessment/Site
Inspection (PA/SI)]  and, if  properly planned,  SSL
sampling can be  accomplished in one mobilization.

An important part of this guidance is a recommended
sampling approach that balances the need for more data
to reduce uncertainty  with the  need  to limit  data
collection costs.

Knowledge of background radionuclide concentrations
at the  site is critical when screening site  soils, since
facility operations may have contaminated site soils with
some of the same radionuclides that are found naturally-
occurring in background soil.   In many cases,  the
concentration of  the  radionuclide of concern  in
background  soil, and the variability of the background
soil  concentration, may be  much greater  than the
screening level.  In these situations, the site manager
should not exclude the radionuclide of potential concern
from being  evaluated in the risk assessment, as the
contamination from the facility may pose a threat to
human health and the environment.  Risk management
options for the  radionuclides of concern  will  be
evaluated in the CERCLA remedy selection process.

This  guidance  provides the information needed to
calculate SSLs for 60 radionuclides (See Attachment C
for list of radionuclides).  Sufficient information may
not be available to develop soil  screening levels for
additional radionuclides. These radionuclides should
not be screened out, but should  be addressed in the
baseline  risk  assessment  for  the site.   The  Risk
Assessment Guidance for Superfund (RAGS), Volume 1:
Human Health Evaluation Manual (HHEM), Part A,
Interim Final. (U.S. EPA, 1989a) provides guidance on
conducting baseline risk assessments for NPL sites. In
addition, the baseline risk assessment should address the
radionuclides, exposure pathways, and areas at the site
that are not screened out.

Although SSLs are "risk-based," they do not eliminate
the need to conduct a  site-specific risk assessment.
SSLs are concentrations of radionuclides in soil that are
designed to be protective of exposures in a residential
setting.  A site-specific risk assessment is an evaluation
of the risk posed by exposure to  site contaminants in
various media.   To calculate SSLs, the  exposure
equations and pathway  models are run in reverse to
backcalculate an "acceptable level" of radionuclides in
soil. For each pathway, radiotoxicity criteria are used to
define an acceptable level of contamination in soil,
based on a one-in-a-million  (10~6) individual excess
lifetime cancer risk.  SSLs are backcalculated for the
migration to ground water pathway using ground water
concentration  limits [maximum  contaminant  levels
(MCLs)].
                                                  1-3

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          Table 1.  Comparison of Soil Screening Frameworks for Chemicals and Radionuclides
        Guidance
       Chemicals
     Radionuclides
        Comments
Applicable land use expo-
Residential only
Same as chemicals
sure scenanos
EPA may include additional
guidance for other land uses
(e.g., commercial/ industrial,
suburban, playground, and
hunter/fisher) in future up-
dates.
Target receptor
RME individual
Same as chemicals
Ecological receptors are not
addressed
Standardized equations
for deriving SSLs for soil
exposure pathways
•  Soil ingestion
•  Inhalation of volatiles
   and fugitive dusts
•  Ingestion of potable
   ground water contain-
   ing chemicals leached
   from soil
Identifies dermal absorp-
tion, plant uptake, and
migration of volatiles into
basement pathways but
does not calculate SSLs
for these pathways
   Soil ingestion
   Inhalation fugitive
   dusts
   Ingestion of potable
   ground water contain-
   ing radionuclides
   leached from soil
   Direct external radia-
   tion exposure
   Ingestion of home
   grown fruits  and vege-
   tables
Chemical-specific SSLs are
expressed in mass concen-
tration units of milligrams of
contaminant per kilogram of
soil (mg/kg).  Radionu-clide-
specific SSLs are expressed
in activity concentration
units of picocuries per gram
of soil (pCi/g).  Additional
equations are required for
radionuclides to account for
other significant soil expo-
sure pathways while some
chemical pathways are not
applicable to radionuclides.
Basis for SSLs
   Target risk limit of
   10"6 for carcinogens
   Hazard quotient of 1
   for noncarcinogens
   Nonzero MCLGs or
   MCLs (whichever is
   most protective), or if
   neither were available
   risk-based limits, for
   the ground water mi-
   gration pathway
   Uses same target risk
   limit as chemicals
   Uses MCLs, proposed
   MCLs (for uranium),
   or risk-based limits for
   the ground water mi-
   gration pathway for
   radionuclides
EPA classifies all radionu-
clides as known human
(Group A) carcinogens.  For
noncarcinogenic chemicals,
nonzero MCLGs are consid-
ered (if available). MCLs
exist for almost every
radionuclide.
Default values for the
age-adjusted soil inges-
tion factor
   IF,
     soil/adj
   114 mg-yr/kg-day
   T soil/adj
   120 mg-yr/day
The radionuclide slope fac-
tors for soil ingestion use a
biokinetic model that
accounts for the age and sex
weighted mass of the
affected organs.  Therefore,
it is not necessary to include
the mass of the receptor in
the default IFsofl/adj for
radionuclides.
                                                      1-4

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          Table 1. Comparison of Soil Screening Frameworks for Chemicals and Radionuclides
        Guidance
     Chemicals
     Radionuclides
        Comments
Default values for the
dilution/attenuation factor
(DAF) and the paniculate
emission factor (PEF)
DAF = 20
PEF=1.32E+9m3/kg
Same as chemicals
The default PEF is the same
as for chemicals.  A key as-
sumption in the derivation of
the PEF is that the 1/2 acre
lot has only 50% vegetative
cover. Although the inges-
tion of homegrown produce
is not quantitatively evalu-
ated in the SSG for chemi-
cals, the assumption of 50%
vegetative cover allows for
the presence of a family gar-
den.
Soil measurement/
verification of guidelines
Measured average soil
contaminant concentra-
tions in exposure areas
of concern
Exposure area (EA) for
averaging concentra-
tions: 0.5 acres (resi-
dential lot)
Averaging depth for
surface soils: 0-2 cm
Evaluation depth for
subsurface soil con-
tamination: surface to
the limit of detectable
contamination or to the
top of the saturated
zone
Number of surface soil
samples required:
Based on site-specific
conditions or a default
value of 6 randomly-
selected specimens
composited into 4 sam-
ples for analyses.
Number of subsurface
soil samples required:
For each source area,
takes 2 or 3 soil bor-
ings in areas suspected
of having the highest
contaminant concentra-
tions.
  Measures same param-
  eter as for chemicals
  Uses same exposure
  area (EA) as chemicals
  Averaging depth for
  surface soils: 0-15 cm
  Uses same evaluation
  depth for subsurface
  soil contamination as
  for chemicals
  Uses same number of
  surface soil samples as
  for chemicals.
  Uses same number of
  subsurface soil sam-
  ples as for chemicals
  Conducts surface scans
  for small areas of
  elevated activity
See Step 3, Defining Data
Collection Needs for Soils
for more detailed guidance.
                                                     1-5

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One exception to the above approach is uranium, which
presents both chemical and radiological hazards.  SSLs
for uranium must consider  both  of these  types  of
hazards.  As a general rule, the radiological hazard
dominates inhalation of insoluble  forms of uranium,
while the chemical toxicity is the  major hazard from
intake of soluble forms of uranium.  Chemical toxicity
of uranium  in  the  kidney has been a concern  in
establishing health protection standards for workers and
the general public for many years.  EPA developed for
its  rulemaking  addressing radionuclide MCLs  an
updated oral RfD  for uranium of 0.6 ^g/kg/day (U.S.
EPA, 1998c). SSLs for uranium should be calculated
using both the radiological guidelines presented in this
document  and  the  approach provided  in  the  Soil
Screening  Guidance for non-carcinogenic chemicals.
Since the SSL is a numerical concentration, it should be
based on the most protective health quantity whether it
be kidney toxicity or radiological risk.

SSLs can be used as Preliminary Remediation Goals
(PRGs) provided appropriate conditions are  met (i.e.,
conditions  found at a specific  site are similar  to
conditions assumed  in developing the  SSLs).  The
concept of calculating risk-based contaminant levels in
soils for use as  PRGs (or "draft" cleanup levels) was
introduced in the RAGS HHEM, Part B, Development
of Risk-Based Preliminary Remediation Goals.  (U.S.
EPA,  1991c).     The   models,  equations,   and
assumptions presented   in  the  Soil  Screening
Guidance   for  Radionuclides  supersede  those
described in RAGS HHEM, Part B, for residential
soils.    In  addition,   this   guidance   presents
methodologies   to   address  the  leaching   of
contaminants through soil to an underlying potable
aquifer.  This pathway should be addressed in the
development of PRGs.

PRGs may then be used as the basis for developing final
cleanup levels  based on the  nine-criteria analysis
described in the National Contingency Plan [Section
300.430 (3)(2)(I)(A)]. The directive entitled Role of the
Baseline  Risk  Assessment  in Superfund Remedy
Selection Decisions  (U.S. EPA, 1991d) discusses the
modification of PRGs to generate cleanup levels.  The
SSLs should only be used as cleanup levels when a site-
specific nine-criteria evaluation of the SSLs as PRGs for
soils indicates that a selected remedy achieving the SSLs
is protective, complies with Applicable or Relevant and
Appropriate Requirements (ARARs), and appropriately
balances the other criteria, including cost.  Note that
potential soil ARARs exist for several of the more
common naturally-occurring radionuclide s (226Ra, 228Ra,
230Th,  232Th,  235U,  and 238U)  under 40  CFR  Part
192.12(a), Part 192.32(b)(2), and Part 192.41, and 10
CFR Part 40 Appendix A, I, Criterion 6(6).  For further
guidance on using these ARARs, see OSWER Directive
9200.4-25 (U.S. EPA, 1998b), dated February 12, 1998
and OSWER Directive 9200.4-35P (U.S. EPA, 2000a),
dated April 11, 2000.  The equations presented in this
document supersede those described in RAGS HHEM,
Part B, and should be used to determine PRGs and RGs.

1.3  Scope of Soil Screening Guidance for
     Radionuclides

In a residential setting, potential pathways of exposure
to radionuclides in soil included in this guidance are as
follows (see Exhibit 2):

• Direct ingestion of soil
• Inhalation of fugitive dusts
• Ingestion of contaminated ground water caused by
  migration of  radionuclides  through  soil  to  an
  underlying potable aquifer
• External radiation exposure from photon-emitting
  radionuclides in soil
• Ingestion of homegrown produce that has been
  contaminated via plant uptake
                                                 1-6

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Produce IngesUon
        •xxxx:
         son   .III .  Radlau
         y^O^l
                   Groundwater
    Exhibit 2: Exposure Pathways Addressed by
              SSLs for Radionuclides
The  Soil  Screening  Guidance  for  Radionuclides
addresses each of these pathways to the greatest extent
practical.  The mode of exposure to radionuclides is
different than that of  chemicals.  This renders some
chemical pathways inapplicable to radionuclides (e.g.,
inhalation of volatiles, dermal absorption) while adding
other pathways  unique  to radiation  (e.g., external
exposure to photons emitted by radionuclides).  The
radiological pathways  listed above represent the most
likely  exposure  mechanisms  for  individuals in  a
residential setting.  The external exposure pathway is,
for most radionuclides,  the  dominant exposure and
typically represents the most significant risk. For some
radionuclides, the ingestion of contaminated produce
and drinking water constitute the most likely exposure
pathways provided that these items are obtained from
onsite sources. The inhalation of fugitive dust pathway
is included in the analysis; however, it is of significance
for only a very few radionuclides. All of these pathways
have generally accepted radiological  risk methods,
models, and assumptions that lend  themselves to  a
standardized approach.

The Soil Screening  Guidance for Radionuclides
addresses  the  human  exposure pathways listed
previously and  will be  appropriate  for  most
residential settings.  The presence  of  additional
pathways  or  unusual  site conditions   does  not
preclude the use of SSLs in areas of the site that are
                                                    currently residential or likely to be residential in the
                                                    future. However, the risks associated with additional
                                                    pathways  or  conditions  (e.g., fish  consumption,
                                                    raising of livestock for meat or milk consumption,
                                                    fugitive  dusts  caused by heavy truck traffic on
                                                    unpaved roads) should be considered in the RI/FS to
                                                    determine whether SSLs are adequately protective.

                                                    The Soil Screening  Guidance for Radionuclides
                                                    should not  be  used for screening out areas with
                                                    chemical contaminants.

                                                    Exhibit 3 provides key attributes of the Soil Screening
                                                    Guidance for Radionuclides: User's Guide.
                                                    Exhibit 3: Key Attributes of the
                                                             User's Guide

                                                Standardized  equations  are   presented  to
                                                address  human  exposure  pathways  in  a
                                                residential setting consistent with  Superfund's
                                                concept of "Reasonable Maximum Exposure"
                                                (RME).
                                                Source size (area and depth) can be considered
                                                on a site-specific basis using mass-limit models.
                                                Parameters are identified for which site-specific
                                                information is needed to develop SSLs.
                                                Default  parameter  values  are  provided  to
                                                calculate  generic SSLs  when  site-specific
                                                information is not available.
                                                SSLs forthe migration to ground water pathway
                                                are based on  maximum  contaminant levels
                                                (MCLs), while SSLs for all other pathways are
                                                based on a 10"6 lifetime cancer risk to  an
                                                individual.
                                                Radiation  risk  coefficients used to  calculate
                                                SSLs   represent the  average risk  per unit
                                                exposure to members of a population exposed
                                                throughout life to a constant concentration of a
                                                radionuclide  in  a   specific  environmental
                                                medium. They assume no radioactive decay.
                                                 1-7

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      2.0 SOIL SCREENING PROCESS
The soil screening process (Exhibit 4) is a step-by-step
approach that involves:

•  Developing a conceptual site model (CSM)
•  Comparing the CSM to the SSL scenario
•  Defining data collection needs
•  Sampling and analyzing soils at site
•  Calculating site-specific SSLs
•  Comparing site soil radionuclide concentrations to
   calculated SSLs
•  Determining which areas of the site require further
   study.

It is important to follow this process to implement the
Soil Screening Guidance for Radionuclides  properly.
The remainder of this guidance discusses each activity
in  detail.

2.1    Step 1:  Developing a
                  Conceptual Site Model

The  CSM  is a three-dimensional  "picture" of  site
conditions that  illustrates radionuclide distributions,
release mechanisms, exposure pathways and migration
routes, and potential receptors. The CSM documents
current site conditions and is supported by maps, cross
sections, and site  diagrams that illustrate human and
environmental exposure through  radionuclide release
and migration to potential receptors.  Developing  an
accurate CSM is critical to proper implementation of the
Soil Screening Guidance for Radionuclides.

As a  key component of the RI/FS and EPA's Data
Quality Objectives (DQO) process, the CSM should be
updated and revised as investigations produce new
information  about a site. Data Quality Objectives for
Superfund: Interim Final Guidance (U.S. EPA, 1993a)
and Guidance for Conducting Remedial Investigations
and Feasibility Studies under CERCLA (U.S.  EPA,
1989c)  provide   a general  discussion  about  the
development and  use  of the  CSM during  RIs.
Developing the CSM involves several steps, discussed
in the following subsections.

2.1.1    Collect Existing Site Data. The initial
design of the CSM is  based on existing  site  data
compiled during previous studies.   These data  may
include  site sampling data, historical records, aerial
photographs, maps, and  State soil surveys, as well as
information on local and regional conditions re levant to
radionuclide migration and potential receptors. Data
sources  include  Superfund site assessment documents
(i.e., the PA/SI), documentation of removal actions, and
records  of  other site characterizations or  actions.
Published information on local and regional climate,
soils,  hydrogeology, and ecology may be  useful.  In
addition, information on the population and land use at
and surrounding the site will be important to identify
potential exposure pathways and receptors. The RI/FS
guidance (U.S.  EPA, 1989c) discusses  collection of
existing data during RI scoping, including an extensive
list of  potential data sources.   The  Multi-Agency
Radiation   Survey  and  Site Investigation  Manual
(MARSSIM) (U.S. EPA,  1997b) [Section 3.4] discusses
the collection  of existing  data specific  to  sites
contaminated with radioactive materials.

2.1.2    Organize and Analyze Existing Site
Data.  One of the most important aspects of the CSM
development process  is to identify and characterize all
potential exposure pathways and receptors at the site by
considering site conditions, relevant exposure scenarios,
and the properties of radionuclides present in site soils.

Attachment A, the  Conceptual Site Model Summary,
provides four forms  for organizing site data for soil
screening purposes.  The CSM summary  organizes site
data  according  to   general  site information,  soil
radionuclide source characteristics, exposure pathways
and receptors.

Note: If a CSM has already been developed for the site
in question, use the summary forms in Attachment A to
ensure that it is adequate.
                                                 2-1

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                                                         Exhibit 4

                                        Soil Screening Process for Radionuclides


Step One:         Develop Conceptual Site Model
                  •    Collect existing site data (historical records such as previous surveys and sampling data, site operating records,
                      aerial photographs, maps, PA/SI data, available background information, State soil surveys, etc.)
                  •    Organize and analyze existing site data
                          Identify known sources of contamination and potential contaminants
                          Identify potentially contaminated areas and affected media
                          Identify potential migration routes, exposure pathways, and receptors
                  •    Construct a preliminary diagram of the CSM
                  •    Perform site reconnaissance
                          Confirm and/or modify CSM
                          Identify remaining data gaps
Step Two:         Compare Soil Component of CSM to Soil Screening Scenario
                  •    Confirm that future residential  land use is a reasonable assumption for the site
                  •    Identify pathways present at the site that are addressed by the guidance
                  •    Identify additional pathways present at the site not addressed by the guidance
                  •    Compare pathway-specific generic SSLs with available concentration data
                  •    Estimate whether background levels exceed  generic SSLs
Step Three:       Define Data Collection Needs for Soils to Determine Which Site Areas Exceed SSLs
                  •    Stratify the site based on existing data
                  •    Identify exposure areas
                  •    Develop sampling  and analysis plan for determining mean soil radionuclide concentrations
                          Determine appropriate survey instruments and techniques and establish QA/QC protocols
                          Sampling strategy for surface soils (includes  defining study boundaries, developing a decision rule,
                          specifying limits on decision errors, and optimizing the design)
                          Sampling strategy for subsurface soils (includes defining study boundaries, developing a decision rule,
                          specifying limits on decision errors, and optimizing the design)
                          Sampling to measure soil characteristics (bulk density, moisture content, porosity, soil texture, pH)
                  •    Determine  appropriate field methods and establish QA/QC protocols
Step Four:        Sample and Analyze Soils at Site
                      Identify radionuclides
                      Delineate area and depth of sources and identify non-impacted areas as appropriate
                      Determine  soil characteristics
                      Conduct preliminary data review
                      Revise CSM, as appropriate
Step Five:         Derive Site-specific SSLs, if needed
                      Identify SSL equations for relevant pathways
                      Obtain site-specific input parameters from CSM summary
                      Replace variables in SSL equations with site-specific data gathered in Step 4
                      Calculate SSLs
                          Account for exposure to multiple contaminants
Step Six:          Compare Site Soil Contaminant Concentrations to  Calculated SSLs
                      Select appropriate  statistical tests and verify test assumptions
                      For surface soils, screen out exposure areas where all composite samples do not exceed SSLs by a factor of two
                      For subsurface soils, screen out source areas where the highest average soil core concentration does not exceed
                      the SSLs

Step Seven:       Decide How to  Address Areas Identified for Further Study
                      Review and confirm the data that led to the decision
                      Consider likelihood that additional areas can be screened out by collecting additional data
                      Integrate soil data with other media in the baseline risk assessment to estimate cumulative risk at the site
                      Determine  the need for action
                      Use SSLs as PRGs
                                                         2-2

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2.1.3
Construct   a   Preliminary
Diagram Of the CSM.  Once the existing site data
have been organized and a basic understanding of the
site has been attained, draw a preliminary "sketch" of
the site conditions, highlighting source areas, potential
exposure pathways, and receptors. Ultimately, when site
investigations are complete, this sketch will be refined
into a three-dimensional diagram that summarizes the
data.   Also,  a  brief summary of the contamination
problem should accompany the CSM.  Attachment A
provides an example of a complete CSM summary.

2.1.4    Perform Site  Reconnaissance.  At
this point, a site visit would be useful because conditions
at the  site may have  changed since the PA/SI was
performed (e.g., removal actions may have been taken).
During   site   reconnaissance,  update   site
sketches/topographic   maps  with   the  locations  of
buildings,   source   areas,  wells,  and   sensitive
environments.  Anecdotal information from nearby
residents or site workers may reveal undocumented
disposal practices and thus previously unknown areas of
contamination  that may  affect the  current  CSM
interpretation.

Based  on the  new   information  gained  from  site
reconnaissance,  update the  CSM as  appropriate.
Identify any remaining data gaps in the CSM so that
these data needs can be incorporated into the Sampling
and Analysis Plan (SAP).

2.2   Step 2:  Comparing CSM to
                  SSL Scenario

The Soil Screening Guidance for Radionuclides is likely
to be appropriate for sites where residential land use is
reasonably anticipated. However, the CSM may include
other  sources and exposure pathways that are  not
covered by this  guidance.  Compare the CSM with the
assumptions and limitations  inherent in the SSLs to
determine  whether   additional  or  more detailed
assessments  are needed for any exposure pathways or
radionuclides. Early identification of areas or conditions
where SSLs are not applicable is important so that other
characterization and response efforts can be considered
when planning the sampling strategy.

2.2.1    Identify Pathways Present at the
Site Addressed by Guidance. The following are
potential pathways  of exposure to radioactive soil
contaminants in a residential setting and are addressed
by this guidance document:

•  Direct ingestion of soil
•  Inhalation of fugitive dusts
•  Ingestion of contaminated ground water caused by
   migration of radionuclides through soil to an under-
   lying potable aquifer
•  External radiation exposure from radionuclides in soil
•  Ingestion of homegrown produce that has been
   contaminated via plant uptake

This guidance quantitatively addresses  each of these
pathways. Whether  some or all of the  pathways are
relevant at the site depends upon the radionuclides and
conditions at the site.

For  surface soils  under the  residential land use
assumption, the external exposure pathway will typically
be  the  dominant   exposure  pathway   for  most
radionuclides (e.g., 54Mn, 60Co, 137Cs, etc.). For some
radionuclides (e.g., 3H, "Tc, 129I, etc.), the ground water
pathway often dominates, although not to the extent that
the external exposure pathway does. The plant ingestion
pathway and soil   ingestion  pathway  also  play  a
dominant role for a  few radionuclides of interest (for
plant ingestion - 14C, 63Ni, 90Sr, etc.; for soil ingestion -
241Am, 244Cm, 230Th, 232Th, etc.).  In the majority  of
cases, the inhalation of fugitive dust pathway plays an
insignificant role.

For  subsurface  soils,  risks  from   migration  of
radionuclides to an underlying aquifer is the  only
potential concern for this scenario. Volatilization is not
included as a pathway since it is a concern for only a
very limited number of radionuclides (such as 3H and
14C).  The majority of all radionuclides  are present in
soil as nonvolatile ionic species or inorganic compounds
(i.e., Henry's law constant is zero). Thus, volatilization
and subsequent inhalation has not been included. If 3H
or 14C volatilization is a concern, an approach similar to
that in the Soil Screening Guidance for chemicals can be
used to model the  exposure.   Consideration  of the
ground water pathway may be  eliminated if ground
water beneath or adjacent to the site is not a potential
source of drinking water. Coordinate this decision on a
site-specific  basis   with  State  or local  authorities
responsible for ground water use and classification. The
                                                   20
                                                  -3

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rationale for excluding this exposure pathway should be
consistent with EPA ground water policy (U.S. EPA,
1988a, 1990a,  1992a, 1992c, and 1993b).

In addition to the more common pathways of exposure
in a residential  setting, concerns have been raised
regarding  the  potential for migration  of radon from
subsurface soils into basements. The dominant factor in
indoor radon levels is home construction practices and
the  extent to  which these practices employ radon-
resistant techniques.   Homes built atop soil  with
identical levels of radium can have orders of magnitude
differences in  indoor radon levels depending on the
extent to which radon-resistant techniques are used. As
NORM, radium is  present in all soils.  Reducing the
radium  content  in  the  soil may not  result  in  any
reduction  in indoor radon levels.   However, taking
simple and inexpensive steps in home construction will
ensure that radon levels in homes are kept below ARAR
levels.  For existing homes with elevated levels of radon,
a variety  of methods can  be  used  to  reduce radon
concentrations to ARAR levels. Discussion of radon
mitigation standards may  be  found in several  EPA
publications, including Radon  Mitigation Standards,
EPA 402-R-93-078.  Also note that  potential  soil
Applicable or Relevant and Appropriate Requirements
(ARARs)  exist  for radon under  192.12(b)(l)  and
192.41(b). For further guidance on using these ARARs,
see the August 1997 memorandum from Stephen Luftig
(OERR)  and   Larry   Weinstock   (ORIA)  titled
"Establishment of cleanup levels for CERCLA sites with
radioactive contamination," OSWER Directive 9200.4-
18, (U.S. EPA, 1997c).

2.2.2    Identify   Additional    Pathways
Present  at the  Site  Not  Addressed  by
Guidance. The presence of additional pathways does
not  preclude the use of SSLs in site areas  that are
currently residential or likely to be residential in the
future.  However,  the  risks   associated with these
additional pathways should also be considered in the
RI/FS to determine whether SSLs are adequately pro-
tective. Where the  following conditions exist, a more
detailed site-specific study should be performed:

• The site is  adjacent to bodies of  surface water
  where the potential  for contamination of surface
  water by overland flow  or release of contaminated
  ground water into surface water through seeps should
  be considered.
•  There are potential terrestrial or aquatic ecological
   concerns.

•  There are other likely human exposure pathways
   that were not considered in development of the SSLs
   (e.g., local fish consumption; raising of beef, dairy, or
   other  livestock; recreational  activities  such  as
   playground  activities,   hunting  and  fishing,
   construction activities).

•  There are unusual site conditions such as large areas
   of contamination, unusually high fugitive dust levels
   due to soil being tilled for agricultural use, or heavy
   traffic on unpaved roads.

•  There are certain subsurface site conditions such as
   karst,  fractured  rock  aquifers, or  contamination
   extending below the water table,  that result in the
   screening models not being sufficiently conservative.

•  There is the probability of prolonged skin contact
   with  high  levels of  high  energy  beta-emitting
   contaminants for periods of time (several years), and
   all other pathways show a very low risk.  The skin
   contact exposure pathway is normally several orders
   of magnitude  lower than either the  inhalation,
   ingestion, or external exposure pathway (depending
   on the radionuclide,  see Section 2.2.1) due to very
   low risk coefficients and normal hygiene practices
   (washing skin routinely).

2.2.3   Compare   Available    Data   to
Background. EPA may be concerned with two types
of radioactivity background at sites: naturally-occurring
and  anthropogenic.  Naturally-occurring background
radiation is much  more  ubiquitous in the environment
than naturally-occurring background chemicals.

Natural   background  radiation  includes   terrestrial
radionuclides,   cosmic   radiation  and  cosmogenic
radionuclide s.  Anthropogenic background consists of
manmade  isotopes  which  are  distributed  in  the
environment due  primarily to  releases  from nuclear
weapons testing and to the very  small, but measurable
releases from nuclear facilities.

A comparison of available data (e.g.,  State soil surveys
or other sources of soil radioactivity analyses) on local
background concentrations with  generic SSLs may
indicate whether background concentrations at the site
are elevated. Generally, EPA does not cleanup below
natural  background   levels;  however,  where
                                                 2-4

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anthropogenic background levels exceed SSLs and EPA
has determined that a response action is necessary and
feasible, EPA's goal will be to develop a comprehensive
response to address area soils.  This will  often require
coordination  with  different  authorities  that  have
jurisdiction over other sources of contamination in the
area.  This will  help avoid response actions that create
"clean islands"  amid widespread contamination.

Knowledge of background radionuclide concentrations
at the  site is  critical when  screening site soils,  since
facility operations may have contaminated site soils with
some of the same radionuclide s that are found naturally-
occurring in  background  soil.   In many cases, the
concentration  of  the  radionuclide  of  concern  in
background soil, and the variability of the background
soil  concentration,  may  be much  greater than the
screening level. In these situations, the  site manager
should not exclude the radionuclide of potential concern
from  being evaluated in the risk assessment, as the
contamination from the facility may pose a threat  to
human health and the environment. Risk management
options for the  radionuclides of  concern  will  be
evaluated in the CERCLA remedy selection process.

Note that potential soil ARARs exist for several of the
more common naturally-occurring radionuclides (226Ra,
228Ra, 230Th, 232Th, 235U, and 238U) under 40 CFR Part
192.12(a), Part  192.32(b)(2), and Part 192.41, and 10
CFR Part 40 Appendix A, I, Criterion 6(6).  For further
guidance on using these ARARs, see OSWER Directive
9200.4-25 (U.S. EPA, 1998b), dated February 12, 1998
and OSWER Directive 9200.4-35P (U.S. EPA, 2000a),
dated April 11,2000.

2.3    Step  3:  Defining Data
                   Collection Needs for
                   Soils

Once the CSM has been developed and the site manager
has determined that the Soil Screening Guidance for
Radionuclides  is appropriate  to use at  a  site,  an
Sampling and Analysis Plan (SAP) should be developed.
Attachment A,  the Conceptual Site  Model Summary,
lists the data  needed  to apply the Soil Screening
Guidance for Radionuclides.  The summary will help
identify data gaps in the CSM that require collection  of
site-specific data. The  soil SAP is likely to contain
different sampling strategies that address:
•  Surface soil
•  Subsurface soil
•  Soil characteristics

To develop sampling strategies that will properly assess
site contamination, EPA recommends that site managers
consult with the technical experts in their Region,
including risk assessors, toxicologists, health physicists,
chemists and hydrogeologists.  These experts can assist
the site manager to use the Data Quality Objectives
(DQO) process to satisfy Superfund program objectives.

The DQO  process is  a systematic planning process
developed by EPA to ensure  that  sufficient data are
collected to support EPA decision making. Using the
DQO Process ensures that the type, quantity, and quality
of environmental data used in decision making will be
appropriate for the intended medium. A full discussion
of  the  DQO process  is provided in  Data Quality
Objectives for Superfund: Interim Final Guidance (U.S.
EPA, 1993a) and the Guidance for the Data Quality
Objectives Process (U.S. EPA, 1994b).  In addition,
MARSSIM provides extensive discussions of the DQO
Process as  it is applied to conducting radiation site
surveys.

Most key elements of the DQO process have already
been  incorporated as  part of this  Soil Screening
Guidance  for Radionuclides.    Exhibit 5  shows the
general components of the DQO process as it is applied
to environmental data analysis.  Detailed DQOs for the
soil screening process are provided in Attachment B.
Exhibit 6 expands upon step 4 of the DQO process, and
provides additional guidance   to  define  site  study
boundaries The remaining elements involve identifying
the site-specific information needed to calculate SSLs.
The following sections present an overview of the
sampling strategies needed  to use the Soil Screening
Guidance  for Radionuclides.   For a more detailed
discussion, see the supporting Soil Screening Guidance
for Radionuclides:  Technical  Background Document
(TBD).

2.3.1    Stratify the Site  Based on Existing
Data.  At  this  point  in the  soil  screening process,
existing data can be used to stratify the site into three
types of areas requiring different levels of investigation:

•    Areas unlikely to  be contaminated
                                                  2-5

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•    Areas known to be highly contaminated
•    Areas that may be contaminated and cannot be
     ruled out.

Areas that are unlikely to be contaminated generally will
not require further investigation if historical site use
information or other site data, which are reasonably
complete and accurate, confirm this assumption. These
may be  areas  of the site that were  completely
undisturbed by activities at the facility.

A crude estimate of the degree of soil contamination can
be made  for other areas of the site by comparing site
concentrations to the generic SSLs in Appendix A of the
TBD.  Generic SSLs have  been calculated  for 60
radionuclides using default values in the SSL equations,
resulting  in conservative values that will be protective
for the majority of site conditions.

The pathway-specific generic SSLs can be compared
with available concentration data from previous site
investigations or removal actions to help divide the site
into areas with similar levels of soil contamination and
develop appropriate sampling strategies.

The surface soil  sampling strategy discussed in this
document is most appropriate for those areas that may
be  contaminated  and  can not be  designated as
uncontaminated.    Areas  which  are known  to  be
contaminated  (based  on   existing  data)  will  be
investigated and characterized in the RI/FS.

2.3.2    Identify Exposure Areas. An exposure
area (EA)  is a physical area of a specified size and
shape for which a separate decision will be made as to
whether or not the area exceeds the screening criteria.
To facilitate survey design and ensure that the number of
survey data points  for a specific site are  relatively
uniformly  distributed   among   areas   of  similar
contamination potential, the site is divided into EAs that
share a common history or other characteristics, or are
naturally distinguishable from other portions of the site
(see Exhibit 6).

An EA should not include areas that have potentially
different   levels  of contamination.    The   EA's
characteristics should be generally consistent with the
SSL exposure pathway modeling.   EAs  should be
limited in size based on classification, exposure pathway
modeling assumptions, and site-specific conditions.
This guidance suggests an upper bound for the size of an
EA is 2,000 m2 (0.5-acre).

This limitation on EA size is intended to ensure that
each area is assigned an adequate number of data points.
Because the number of samples is independent of the
EA size, limiting the  size of an EA ensures that the
default sample density does not exceed  333 m2 per
sample.  This also serves to limit the sample spacing.
The statistical basis for the default sample number is
provided in Section 3.3.3.

2.3.3    Develop Sampling  and  Analysis
Plan for Surface Soil. The surface soil sampling
strategy is designed to collect  the  data needed to
evaluate exposures via direct ingestion of soil, inhalation
of fugitive dusts, external radiation exposure, ingestion
of homegrown produce pathways, as well as migration
of contaminants to groundwater.

The SAP  developed for surface soils should specify
sampling  and analytical procedures as well as the
development of QA/QC procedures.  To identify the
appropriate analytical procedures, the screening levels
must be known.  If data are not available to calculate
site-specific SSLs (Section 2.5.1), then the generic SSLs
in Appendix A of the TBD should be used.

The depth over which surface soils are sampled should
reflect the CSM and the pathway assumptions that form
the  basis for the  SSL  determination.  The residential
setting used to develop the SSLs  for each  pathway
assumes that:  1) there is no clean cover of soil; 2) the
top   few  centimeters  of soil  are   available  for
re suspension in air; 3) the top 15 cm of contaminated
soil are homogenized by agricultural activities  (e.g.,
plowing); 4) there is a sufficiently large area and depth
of contamination to approximate an infinite slab source
for external exposure purposes; 5) there is enough land
for  the  residential garden to supply one-half of the
residents' annual produce consumption; and,  6) while
the  plant root system grows to a depth of 1 meter, most
plant nutrients are obtained from within the upper 20 cm
of soil.  Further discussion  of the basis  for these
assumptions is provided in the appropriate  pathway
discussions in Section 2.5.1.

Note that the size, shape, and orientation of sampling
volume (i.e., "support") for heterogenous media have a
significant effect on  reported  measurement values.
                                                  2-6

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Sample characteristics such as sample depth, volume,
area, moisture level, and composition, as well as sample
preparation techniques which may alter the sample, are
important planning considerations for Data Quality
Objectives. Comparison of data from methods that are
based on different supports can be difficult. Defining
the sampling support is important in the early stages of
site characterization. This maybe accomplished through
the DQO process with existing knowledge  of the site,
contamination,  and  identification of  the exposure
pathways  that need to  be characterized.   Refer to
Preparation of  Soil Sampling Protocols:  Sampling
Techniques and Strategies (U.S. EPA, 1992e) for more
information about soil sampling support.

As explained in the Supplemental Guidance to RAGS:
Calculating the Concentration Term (U.S. EPA, 1992d),
an individual is assumed to move randomly across an
exposure  area (EA) over time, spending  equivalent
amounts  of  time  in  each  location.    Thus, the
concentration contacted overtime is best represented by
the spatially averaged  concentration over the  EA.
Ideally, the surface  soil  sampling  strategy  would
determine the true population mean of radionuclide soil
concentrations in an EA. Because determination of the
"true" mean would require extensive sampling at high
costs, the  maximum radionuclide concentration from
composite samples is used as a conservative  estimate of
the mean.

The number of samples required to satisfy the DQOs for
the survey is then based on the selection of a statistical
test,  which in turn is based on whether  or not the
radionuclide of concern is present in background. For
guidance when the radionuclide of concern is present in
background, refer to the TBD.

Radionuclide Not Present  in Background. For
those radionuclides that are not generally  present in
background,   measurement  of  background  soil
concentration  is  not  necessary  and  radionuclide
concentrations are compared directly with the screening
level.  With only a single  set of EA samples, the
statistical test used here is called a one-sample test. The
one-sample test may also be used for those radionuclides
that are present in background but are found only at a
small fraction of the SSL. In this case, the background
contribution is included in the radioactivity  in the
samples for the EA.  Thus, the total concentration is
compared to the  screening level.  This option  should
only be used if one expects that ignoring the background
concentration  will  not affect the  outcome  of the
statistical  test.   The advantage of ignoring a small
background contribution is that a background reference
area is not required and  no background sampling is
needed. This may simplify the soil screening process
considerably.
                                                  2-7

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                   Exhibit 5: Data Quality Objectives Process
                     1. State the Problem

 Summarize the contamination problem that will require new environmental
     data, and identify the resources  available to resolve the problem.
                    2.  Identify the Decision

          Identify  the decision that requires new environmental
              data to address the contamination problem.
               3.  Identify Inputs to the  Decision
       Identify the information needed to support the decision, and
     specify which inputs require new environmental measurements.
               4. Define the Study Boundaries
      Specify the spatial and temporal aspects of the environmental
       media that the  data m ust represent to s upport the decision.
                 5.  Develop a Decision Rule
 Develop a logical "if... then ..." statement that defines the conditions that
  would cause the decision  maker to choose among alternative actions.
             6.  Specify  Limits on Decision Errors
Specify the decision maker's acceptable limits on decision errors, which are
  used to establish performance goals for limiting uncertainty  in the data.
         7. Optimize the Design for Obtaining Data
    Identify  the most resource-effective sampling and analysis design
           fora data that are ex pected to satisfy the DQOs.

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               Exhibit 6: Defining the Study Boundaries
                                                   Study Boundaries
1.   Define Geographic Area
    of the Investigation
 2.   Define Population
      of Interest
              Subsurface Soil.
                                 Surface Soil (usually top 15 centimeters)
                                                 \
 3.   Stratify the Site
                                         Area of Suspected
                        Area Unlikely to be     Contamination
                          Contaminated
              Water Table
             (Saturated Zone)


           Area of Known
           Contamination
           (possible source)
 4.   Define Scale of Decision Making for Surface or Subsurface Soils

          SURFACE SOILS                    SUBSURFACE SOILS
           0.5-acre exposure areas (EAs)
Contaminant Source
                   Back to Exhibit 5 Step 5, "Develop a Decision Rule"
                                    2-9

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The Max test, which is used when the radionuclide of
concern is not  generally present  in background, is a
simple  decision  rule   comparing   the   maximum
radionuclide concentrations of composite samples with
soil screening levels. Another, more complex strategy
called the Sign  test is presented in Part 6 of the TBD.
The User's Guide for Radionuclides uses the Max test
rather than the Sign test to maintain consistency with the
approach taken in the SSG for chemicals.   While the
Sign test is a more  complex statistical method than the
Max test,  it is based  on the same statistical null
hypothesis (i.e., the EA requires further investigation).
Some EAs that cannot be screened out with the Max test
could be screened out with the Sign test since  it uses a
less conservative estimate of the  mean concentration
than does the Max test.

In addition to determining the mean concentration of a
radionuclide in an EA, it is important to identify the
presence of small  areas of elevated activity.   This is
done by the performance of scanning surveys.  The
sensitivity of scanning surveys will be insufficient to
detect  small areas  of  elevated activity  for most
radionuclides with levels of contamination as low as
those of the SSLs calculated for large areas of uniform
contamination.   However, standard  scanning survey
techniques may be able to detect  SSLs calculated for
smaller areas  of contamination.   Scan  surveys are
intended to provide  a degree of  confidence that any
significant areas of elevated  activity are  identified.
Therefore, scanning surveys should be performed for all
EAs prior to  sampling.   The extent  of  the survey
coverage should be dictated by the potential for small
areas of elevated activity in the EA.  EAs with a high
potential for small areas of elevated activity should
receive  100%  coverage.  In  EAs with  a very low
potential for small  areas of elevated activity, scanning
surveys should be performed in at least 10% of the area.
In such cases, the areas selected for scan should be those
with highest potential based on professional judgement.
Due to the limited sensitivity of scan surveys, any small
areas of elevated activity found during the survey should
be identified for further investigation (i.e., not screened
out).

Exhibit  7 provides a  summary  of  SAP  design
considerations  for EAs  when the  radionuclides  of
concern for surface soils are not present in background.
The following strategy can be used for surface soils to
estimate the mean concentration of radionuclides in an
EA when the radionuclide of concern is not present in
background.

•   Divide areas to be sampled in the screening process
    into 0.5-acre exposure areas, the size of a suburban
    residential lot.  If the site is currently residential, the
    exposure area  should be the actual residential lot
    size. The exposure areas should not be laid out in
    such a way that they unnecessarily combine areas of
    high and low levels of contamination.   The
    orientation and exact location of the EA, relative to
    the distribution of the contaminant in the soil, can
    lead to instances where sampling the EA may have
    contaminant concentration results above the mean,
    and in other instances, results below the mean.

•   Composite  surface  soil samples.   Because the
    objective of surface soil screening is to estimate the
    mean  contaminant  concentration, the  physical
    "averaging" that  occurs during compositing  is
    consistent with  the intended use  of the  data.
    Compositing allows sampling of a larger number of
    locations while controlling analytical costs, since
    several individual samples  are physically mixed
    (homogenized) and  one  or more subsamples are
    drawn from the mixture and submitted for analysis.

•   Strive to achieve a Type I (false negative) error rate
    of 5 percent (i.e., in only 5 percent of the cases, soil
    contamination is assumed to be below the screening
    level when it is really above the screening level).
    EPA also strives to  achieve a 20 percent Type II
    (false positive) error rate (i.e., in only 20 percent of
    the cases, soil contamination is assumed to be above
    the  screening  level  when it  is really below the
    screening level).  These error rate goals influence
    the  number of samples to be collected  in  each
    exposure area.  For this guidance, EPA has defined
    the  "gray region" as one-half to 2 times the  SSL.
    Thus, the width of the gray region,  also known as
    the shift, A, is equal  to 1.5 times the SSL. Refer to
    Section 2.6 for further discussion.

•   The default sample  size  chosen for this guidance
    (see Exhibit 7) provides adequate coverage for a
    coefficient  of variation  (CV)  based upon 250
    percent variability in contaminant values (CV=2.5).
    (If  a  CV larger than 2.5 is expected, use an
    appropriate sample size from the table in Exhibit 7
    of the User's Guide, or tables in the TBD.)
                                                  2-10

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•   Take six composite samples for each exposure area
    with each composite  sample made  up of four
    individual samples. Exhibit 7 shows other sample
    sizes needed to achieve the decision error rates for
    other CVs. Collect the composites randomly across
    the EA and through the top 15 centimeters of soil,
    which  are of greatest concern  for the external
    exposure and consumption of homegrown produce
    pathways.

•   Analyze  the  six  samples per exposure area to
    determine the  radionuclides present and  their
    concentrations.

For further information on compositing across or within
EA sectors, developing a random sampling strategy, and
determining sample sizes  that control decision  error
rates, refer to the TBD.

Note  that  the  Max  test  requires  a  Data Quality
Assessment (DQA) test following sampling  and analysis
(Section 2.4.2) to ensure that the DQOs (i.e., decision
error rate goals) are achieved. If DQOs are not met,
additional sampling may be required.

2.3.4             Develop    Sampling  and
Analysis Plan for Subsurface  Soils.  The
subsurface and surface soil sampling strategies differ
because the exposure mechanisms differ.  Exposure to
surface contaminants occurs as individuals move around
a residential  lot.  The surface soil sampling strategy
reflects this type  of exposure.

In general, exposure to subsurface contamination occurs
when radionuclides migrate down to an underlying
aquifer.    Thus, subsurface sampling  focuses  on
collecting the data required for modeling the  migration
to ground  water pathway.   Measurements of soil
characteristics and estimates of the area and depth of
contamination   and  the   average  contaminant
concentration in each source area are needed to supply
the data necessary to calculate the migration  to ground
water SSLs.

Source areas are the  decision units for subsurface  soils.
A source area is  defined by the  horizontal extent, and
vertical  extent or depth of contamination. Sites  with
multiple sources should develop separate  SSLs for
each source.
The SAP developed for subsurface soils should specify
sampling and analytical  procedures as well as the
development of QA/QC procedures.  To identify the
appropriate procedures, the SSLs must be known.  If
data are not available to  calculate  site-specific SSLs
(Section 2.5.2), the generic SSLs in Appendix A of the
TBD should be used.

The primary goal of the subsurface sampling strategy is
to estimate the mean  radionuclide  concentration and
average soil characteristics within the source area. As
with the surface soil sampling strategy, the subsurface
soil sampling strategy follows the DQO process (see
Exhibits 5, 6, and 8).  Exhibit 8 provides a summary of
SAP design considerations for subsurface soils. If the
radionuclide of concern is not present in background, the
decision  rule  is  based   on   comparing the  mean
radionuclide  concentration within  each contaminant
source with source-specific SSLs.

Current investigative techniques and statistical methods
cannot accurately determine the mean concentration of
subsurface soils within a contaminated source without a
costly  and  intensive  sampling program that is well
beyond the  level of effort generally appropriate for
screening.  Thus, conservative  assumptions should be
used to develop  hypotheses  on likely contaminant
distributions.
                                                 2-11

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    Exhibit 7:  Designing a Sampling and Analysis Plan for Surface Soils
                     Radionuclide Not Present in Background
 1. Subdivide Site
   Into EAs

                                               A7
2. Divide EA
  Into a Grid
 3. Organize
   Surface
   Sampling
   Program for
   EA
  O
05   O2
                            1
                            o
   O6

  O4
                                      o
                                               Q
                                                    60
                                       For surface soils, the
                                       individual unit for
                                       decision making is an
                                       "EA," or exposure area.
                                       It measures 0.5 acre in
                                       area or less.
                                        This step defines the
                                        number of specimens
                                        (N) that will make up one
                                        composite sample.
a.  Placement of sample locations
   on the grid was developed
   using a default sample size of
   6 (which is based on
   acceptable error rates fora CV
   of 2.5) and a stratified random
   sampling pattern.

b.  Potential for small areas of
   elevated activity determines
   degree of scan coverage.
          If the EA CV is suspected to be greater than 2.5, use the table below to select an
          adequate sample size or refer to the TBD for other sample design options.
                    Probability of Decision Error at 0.5 SSL and 2 SSL Using Max Test
Sample Size"
6
7
8
9
CV=2.5a
E0.5°
C d
E2.0
CV=3.0
E0.5
E2.0
CV=3.5
E0.5
E2.0
CV=4.0
E0.5
E2.0
C = 4 specimens per composite e.
0.21

0.25
0.25
0.28
0.08
0.05
0.04
0.03
0.28
0.31
0.36
0.36
0.11
0.08
0.05
0.04
0.31
0.36
0.42
0.44
0.11
0.09
0.07
0.07
0.35
0.41
0.41
0.48
0.16
0.15
0.09
0.08
     a The CV is the coefficient of variation for individual, uncomposited measurements across the entire EA,
      including measurement error.
     b Sample size (N) = number of composite samples
     c EQ 5 = Probability of requiring further investigation when the EA mean is 0.5 SSL
     d £2 Q = Probability of not requiring further investigation when the EA mean is 2.0 SSL
     e C = number of specimens per composite sample, when each composite consists of points from a stratified
      random or systemic grid sample from across the entire EA.

     NOTE: All decision error rates are based on 1,000 simulations that assume that each composite is representative
     of the entire EA, half the  EAhas concentrations below the limit of detection, and half the EAhas concentrations
     that follow a gamma distribution (a conservative distributional assumption).
                                            2-12

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This guidance bases the decision to investigate a source
area further on the highest mean soil boring contaminant
concentration  within  the  source,  reflecting  the
conservative  assumption  that  the  highest  mean
subsurface soil boring concentration among a  set of
borings taken from the source area represents the mean
of the entire source area.   Similarly, estimates  of
contaminant  depths  should be conservative.   The
investigation  should  include the maximum depth of
contamination encountered within the source without
going below the water table.

For each source, the guidance recommends taking 2 or
3 soil borings located in the areas suspected of having
the highest  contaminant  concentrations  within  the
source. These  subsurface soil sampling locations are
based primarily on knowledge of likely surface soil
contamination patterns (see Exhibit 6) and subsurface
conditions.   However,  buried sources may not  be
discernible at the surface.  Information on past practices
at the site included in the CSM can  help identify
subsurface source areas.

Take  soil cores from the soil boring using either split
spoon sampling or other appropriate sampling methods.
Description and Sampling of  Contaminated Soils: A
Field Pocket  Guide (U.S. EPA, 1991f), and Subsurface
Characterization and Monitoring Techniques: A Desk
Reference Guide, Vol. I&II(U.S. EPA, 1993e), can be
consulted for information on  appropriate subsurface
sampling methods. For radioactive contaminants, core
samples may  also be obtained  and monitored intact in
the field  to  determine if layers of radioactivity are
present.  In addition, the use of a subsurface sampling
technique, which results in a borehole or soil face, may
be "logged" using a gamma scintillation detector. This
enables scanning of the exposed soil surface to identify
radioactive contamination within small fractions of hole
depth, thus facilitating the identification of the presence
and depth distribution of subsurface radioactivity. This
information may be used to direct further core sampling
and laboratory analysis as warranted.

Sampling should  begin  at the  ground surface and
continue until either no contamination is encountered or
the water table is reached.   Subsurface sampling
intervals  can be adjusted at a site to accommodate
site-specific information on subsurface contaminant
distributions and geological  conditions (e.g.,   very
deep water table, very thick uncontaminated unsaturated
zone, user well far beyond edge of site, soils underlain
by karst or fractured rock aquifers).  Sample splits and
subsampling   should  be   performed  according  to
Preparation of Soil Sampling Protocols: Sampling
Techniques and Strategies (U.S. EPA, 1992e).

If each subsurface soil core segment represents the same
subsurface soil interval (e.g., 2  feet),   the  average
concentration  from  the  surface  to the  depth  of
contamination is the simple  arithmetic  average  of
contaminant concentrations measured for core samples
representative  of each of the 2-foot segments from the
surface to the depth of contamination.  However, if the
sample intervals are not all of the same  length (e.g.,
some are 2 feet while others are 1 foot or 6 inches), the
calculation of the average concentration in the total core
must account for the different lengths of the segments.

If Cj is the concentration  measure in a core sample,
representative  of a core interval or segment of length li;
and the n-th segment is considered to be the last segment
sampled in the core (i.e., the n-th segment is at the depth
of contamination), the average concentration in the core
from the surface to the depth of contamination should be
calculated as the following depth-weighted average ( c )•

Alternatively, the average boring concentration can be
determined by adding the  total contaminant activities
together  (from the sample results)  for  all sample
segments to get the total contaminant activity for the
boring. The total contaminant activity is then divided
by the total dry weight of the core (as determined by the
dry bulk density measurements) to estimate average soil
boring concentration.

Finally, the soil investigation for the migration to ground
water pathway should not be conducted independently
of ground water investigations.  Contaminated ground
water may indicate the presence of a nearby source area
that  would leach  contaminants from soil into aquifer
systems.

2.3.5    Develop Sampling and Analysis Plan to
Determine   Soil  Characteristics.     The  soil
parameters necessary for SSL calculations  are soil
texture, dry bulk density,  and pH.  Although laboratory
measurements of these parameters cannot be obtained
under Superfund's Contract Laboratory Program (CLP),
independent soil testing laboratories across the country
can perform these tests at a relatively low cost.
                                                  2-13

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To appropriately apply the migration-to-ground water
models, average or typical soil properties should be used
for a source in the SSL equations (see Step 5). Take
samples for measuring soil parameters with samples for
measuring contaminant  concentrations.  If possible,
consider splitting single  samples for contaminant and
soil parameter measurements. A number of  soil testing
laboratories can handle and test radioactive samples.
However, if testing contaminated samples  for  soil
parameters is a problem, samples may be obtained from
clean areas of the site as long as they represent the same
soil texture and are taken from approximately the same
depth as the contaminant concentration samples.

Soil Texture.  Soil texture class (e.g., loam, sand, silt
loam) is necessary to estimate  average soil moisture
conditions and to apply the Hydrological Evaluation of
Landfill  Performance (HELP) model  to  estimate
infiltration rates (see Attachment A).  The appropriate
texture classification is determined by a particle  size
analysis  and  the  U.S.  Department of  Agriculture
(USDA) soil textural triangle shown in Exhibit 9. This
classification system is based on the USDA soil particle
size classification.

The particle size analysis method in Gee and Bauder
(1986) can provide this particle size distribution. Other
methods  are  appropriate as long as they provide  the
same particle size breakpoints for sand/silt (0.05 mm)
and  silt/clay (0.002  mm).   Field  methods  are  an
alternative for determining soil textural class. Exhibit 9
presents an example from Brady (1990).

Dry Bulk Density.  Dry soil bulk density  (pb) is used
to calculate total soil porosity and can be determined for
any soil horizon by weighing a thin-walled tube soil
sample  (e.g.,  Shelby tube)  of known  volume  and
subtracting  the  tube  weight [American Society  for
Testing  and Materials (ASTM)  D 2937].   Determine
moisture content (ASTM 2216)  on a subsample of the
tube sample to adjust field  bulk density to dry bulk
density.  The other methods (e.g., ASTM  D 1556, D
2167, D 2922) are generally applicable only to surface
soil horizons and  are not  appropriate for  subsurface
characterization. ASTM soil testing methods are readily
available in  the Annual Book  of ASTM  Standards,
Volume 4.08, Soil and Rock; Building Stones, available
from  ASTM,   100  Barr   Harbor   Drive,  West
Conshohocken, PA, 19428.
pH.   Soil pH is used to select site-specific partition
coefficients. This simple measurement is made with a
pH meter in a soil/water slurry (McLean, 1982) and may
be measured in the field using a portable pH meter.

2.3.6    Determine Analytical Methods and
Establish QA/QC Protocols. Assemble a list of
feasible sampling and analytical survey methods during
this step.

Routinely, radiological soil surveys are conducted using
a mix of three types of radiation measurement methods:
1) scans, 2) direct measurements, and 3) sampling and
laboratory analysis. Based on the potential radionuclide
contaminants and  their  associated  radiations,  the
detection  sensitivities  of  various  instruments  and
techniques are determined  and documented.  Methods
must not only be chosen based on their reliability and
suitability to the physical and environmental conditions
at  the site, but they must be capable  of detecting the
radionuclides of concern to the  appropriate minimum
detectable concentration (MDC). During survey design,
it  is generally considered good practice to select a
measurement system with an MDC between 10-50% of
the SSL.

For  soil  screening   purposes,   most   SSLs   for
radionuclides are too low to be detected using scans and
direct  measurements.     Therefore,   sampling  and
laboratory analysis must be the primary means of soil
screening for the majority of radionuclides.  Once the
survey design and  sampling methods are  selected,
appropriate  standard  operating procedures  (SOPs)
should be developed and documented.  Both sample
depth and area are  considerations  in determining
appropriate sample volume, and sample volume is a key
consideration for determining the laboratory MDC. The
depth should also correlate with the CSM developed for
the site.

Field  methods will be useful  in defining  the study
boundaries (i.e., areaand depth of contamination) during
both site reconnaissance and sampling. The design and
capabilities of field portable instrumentation are rapidly
evolving. Documents describing the standard operating
procedures for field instruments are available though the
National Technical Information Service (NTIS).

Additionally, MARSSIM provides further information
on  field  (Chapter  6) and laboratory  (Chapter  7)
                                                 2-14

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measurement  methods  and  instrumentation   for
radionuclides.  Appendix H of MARSSIM describes
typical field and laboratory equipment plus associated
cost and instrument sensitivities.   MARSSIM  also
discusses the  concept of  detection sensitivity and
provides guidance on  determining  sensitivities and
selecting appropriate measurement methods.

SAP quality control may be thought of in three parts: 1)
determining the type of QC samples needed to detect
precision or bias; 2) determining the number of samples
as part of the survey design; and 3) scheduling sample
collections throughout the survey process to identify and
control sources of error and uncertainties.

Because a great amount of variability and bias can exist
in the collection, subsampling, and analysis of soil
samples, some effort should be made to characterize this
variability and bias. A Rationale for the Assessment of
Errors in  the Sampling of Soils  (U.S. EPA, 1990c)
outlines an approach that advocates the use of a suite of
QA/QC samples to assess variability and bias.  Field
duplicates and splits are some of the best indicators of
overall  variability in  the  sampling and  analytical
processes.  At least 10 percent of both the discrete
samples and the composites  should be split and sent to
a  laboratory  for confirmatory   analysis.  (Quality
Assurance for Superfund Environmental Data Collection
Activities, U.S. EPA, 1993c).

Regardless  of whether surface or subsurface soils are
sampled, the Superfund  quality  assurance  program
guidance (U.S. EPA, 1993c) should  be consulted.  In
addition, Specifications and Guidelines for  Quality
Systems for Environmental  Data  Collection  and
Environmental Technology  Program  (ANSI/ASCQ,
1994)  describes  a basic set  of specifications  and
guidelines by which a quality system  for programs
involving   environmental   data   collection   and
environmental technology can be planned, implemented,
and assessed. Standard limits on the precision and bias
of sampling and analytical operations  conducted during
sampling do apply and should be followed  to  give
consistent and defensible results.

2.4  Step 4:  Sampling and Analyzing
                Site Soils & DQA

Once the sampling strategies have been developed and
implemented, the samples should be analyzed according
to the analytical laboratory and field methods specified
in the SAP. Results of the analyses should identify the
concentrations of potential radionuclides of concern for
which site-specific SSLs will be calculated.

2.4.1    Delineate Area and Depth of Source.
Both  spatial  area  and  depth data,  as  well  as soil
characteristic data, are needed to calculate site-specific
SSLs for the external exposure and migration to ground
water pathways. Site information from the CSM or prior
surveys can be used to estimate the areal extent of the
sources.

2.4.2    Perform    DQA    Using    Sample
Results.   Data  Quality  Assessment  (DQA)  is a
scientific and statistical evaluation that determines if the
data are of the right type, quality, and quantity  to
support their intended use. The  nature of the  DQA is
dependent upon whether the radionuclide of concern is
present in background.  For guidance for performing
DQA  when the radionuclide of concern is present  in
background, refer to the  TBD.  The following is a
discussion  of DQA for radionuclides not present  in
background.

Radionuclide Not Present in Background. After
sampling  has  been completed, a DQA  should be
conducted if all composite samples are less than 2 times
the  SSL. This is necessary to determine if the  original
CV estimate (2.5),  and  hence the number of  samples
collected (6), was adequate for screening surface soils.
                                                2-15

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     Exhibit 8:  Designing a Sampling and Analysis Plan for Subsurface Soils
                       Radionuclide Not Present in Background
 1.    Delineate Source Area

 2.     Choose
       Subsurface
       Soil Sampling
       Locations
 3.     Design Subsurface
       Sampling and Analysis
       Plan
        Lab/Field
     Analysis for soil
       parameters
       Soil Boring
(depth below grou nd surface in feet)
                              For screening purposes, EPA
                              recommendsdrilling 2 to 3
                              boringspersourcearea and
                              an equivalent number in a
                              backg-ound reference aiea
                              (when radionucide ispresent
                              in background) in a re as of
                              highestsuspected
                              concentraions. Soil sampling
                              should not extend pastv\ater
                              table or saturated zone.
 Lab Analysis for soil
contaminants in source
 area and background
 reference area (when
radionuclide is present
    in background)
                                                           10
 Pictire depictsa contiruous borirg with 2foot segments.  Forinformatbn on other methodssuch asinterval sampling and
 depthweighted analyss, pleaserefer b 2.3.3 cf the User's Guice or 4.2of the TBD.

b Soil Texture, Dry Bulk Density , Soil Orgaric Carbon Moisture Content, pH. Retain samples for possibe discrete contamhant
 samplhg.
                                           2-16

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               Exhibit 9: U.S. Department of Agriculture soil texture classification
                                             100
               Percent Clay
                                                                          Percent Silt
                                                                         \ 70
                                                                                        100
         100
90
80
70
60     50      40
    Percent Sand
    30
20
                                                                              10
Criteria Used with the Field Method for Determining Soil Texture Classes
                                                                    (Source: Brady, 1990)
 Criterion
  Sand
     Sandy loam
             Loam
Silt loam
     Clay loam
                                                    Clay
1. Individual grains Yes Yes Some Few
visible to eye


2. Stability of dry Do not form Do not form Easily Moderately
clods
No

Hard and
broken easily broken stable
3. Stability of wet Unstable Slightly stable Moderately Stable
clods
stable

Very stable

No

Very hard
and stable
Very stable

4. Stability of Does not Does not form Does not formBroken appearance Thin, will break Very long,
"ribbon" when form
wet soil rubbed
between thumb
and fingers




Particle Size,



mm
0.002 0.05 0.10 0.25
U.S.
Department C
of Agriculture

ay Silt

Very Fine Fine M






0.5 1.0
ed. Coarse Very Co

Sand
flexible




2.0
arse
Gravel

                                            Source: USDA.
                                                  2-17

-------
To conduct the DQA for a composite sample whose
mean is below 2 SSL, first calculate the sample CV for
the  EA in question from the  sample mean ( ^), the
number of specimens per composite sample (C), and
sample standard deviation(s) as follows:
                            * s
Use the sample size table in Exhibit 7 to check, for this
CV, whether the sample size is adequate to meet the
DQOs for the sampling effort.  If sampling DQOs are
not met,  supplementary sampling may be  needed to
achieve DQOs.

However, for EAs with small sample means (e.g., all
composites are  less than the  SSL), the sample CV
calculated using the equation  above may not be a
reliable estimate of the population  CV (i.e., as  %
approaches zero, the sample CV will approach infinity).
To protect against unnecessary additional sampling in
such cases, compare all composites against the formula
SSL^-y'C.  If  the   maximum  composite  sample
concentration is below the value given by the equation,
then the sample size may be assumed to be adequate and
no further DQA is  necessary.  In other words, EPA
believes that the default sample size will adequately
support walk-away decisions when all composites are
well  below the  SSL.   The  TBD  describes  the
development of this formula and provides additional
information on implementing the DQA process.

2.4.3    Revise the  CSM. Because these analyses
reveal new information about the site, update the CSM
accordingly. This revision could include identification
of site areas that exceed the generic SSLs.

2.5   Step 5:  Calculating  Site-
                  specific SSLs

With the  soil properties data collected in Step 4 of the
screening process, site-specific soil screening levels can
now be calculated using the equations presented in this
section. For a description of how these equations were
developed, as well as background on their assumptions
and limitations, consult the TBD.
In the SSG for chemicals, SSLs are expressed in mass
units of mg/kg (i.e., mg of chemical per kg of soil). The
concentrations of radioactive material in soil could also
be expressed in units of mass.  Instead,  they  are
expressed in the traditional radiological units of pCi/g
(i.e., picograms of activity per gram of soil).  These
units  reflect  the  number of atoms of the isotope
undergoing radioactive transformation (referred to as
radioactive decay) per unit time.  For more information
concerning activity and mass, refer to appendix B of the
TBD.

All SSL equations were developed to be consistent with
RME in the residential setting. The Superfund program
estimates the RME  for chronic exposures on a site-
specific basis by combining an average exposure-point
concentration with reasonably conservative values for
intake and duration (U.S. EPA, 1989a; RAGS HHEM,
Supplemental Guidance:  Standard Default Exposure
Factors, U.S. EPA, 1991a, Exposure Factors Handbook,
U.S. EPA, 1997a).  Thus, all site-specific parameters
(soil,  aquifer, and meteorologic parameters) used to
calculate SSLs should reflect average or typical  site
conditions in  order to  calculate average  exposure
concentrations at the site.

Equations for calculating SSLs are presented for surface
and subsurface soils in the following sections. For each
equation,  site-specific   input  parameters   are
highlighted in bold and default values are provided
for use when site-specific data are not available.
Although these defaults  are not worst case, they  are
conservative. At most sites, higher, but still protective
SSLs can be calculated using site-specific data.  The
TBD describes development of these default values and
presents  generic SSLs calculated using the default
values.

Attachment  D provides  toxicity  criteria  for  60
radionuclides commonly found at NPL sites.  These
criteria  were  obtained   from  the  Health  Effects
Assessment  Summary Tables  (HEAST),  which is
regularly updated.  Prior to calculating SSLs at a site,
check all relevant - radionuclide-specific values in
Attachment D against values from HEAST at  the
following internet webpage
http://www.epa.gov/superfund/programs/risk/calctool.
htm. Only the most current values should be used to
calculate SSLs.
                                                2-18

-------
Where toxicity values have been updated, the generic
SSLs should also be recalculated with current toxicity
information.

2.5.1    SSL   Equations-Surface    Soils.
Exposure  pathways addressed  in  the  process  for
screening surface soils include direct ingestion of soil,
inhalation of fugitive dusts, ingestion of contaminated
ground water, external radiation exposure, and ingestion
of homegrown produce.

Direct  Ingestion of  Soil.   The  Soil  Screening
Guidance for Radionuclides addresses chronic exposure
to  radionuclides  through  direct   ingestion   of
contaminated soil in a residential setting.

A number of studies  have  shown that inadvertent
ingestion of soil  is common among children age 6 and
younger (Calabrese et al., 1989; Davis et al.,  1990: Van
Wijnen et al., 1990). In some cases, children may ingest
large  amounts of soil (i.e., 3 to 5 grams) in  a single
event. This behavior, known as pica, may result in
relatively high short-term exposures to radionuclides in
soil.

Default values are used for all input parameters in the
direct ingestion equations.  The amount of data required
to derive site-specific values  for these parameters (e.g.,
soil ingestion rates, chemical-specific bioavailability)
makes their  collection  and  use impracticable  for
screening. Therefore, site-specific data are not generally
available for this  exposure route. The generic ingestion
SSLs presented   in Appendix A of  the  TBD  are
recommended for all NPL sites.

However,  for  radionuclides, both the magnitude and
duration of exposure are important. Duration is critical
because the toxicity criteria are based on "lifetime
average daily dose."   Therefore, the total   intake,
whether it be over 5 years or 50 years, is averaged over
a lifetime of 70 years. To be  protective of exposures to
radionuclides  in the  residential setting,  Superfund
focuses on exposures to individuals who may live in the
same  residence for a high-end period of time (e.g., 30
years) because  exposure to  soil  is  higher  during
childhood and decreases with age. Equation  1 uses a
time-weighted average soil ingestion rate for children
and adults. The derivation of this time-weighted average
is presented in U.S. EPA, 1991c.
Equation 1: Screening Level Equation for Ingestion of
Radionuclides in Residential Soil
cc; _ TR
^^L soil ing 3
Parameter/Definition (units)
TR/target cancer risk (unitless)
SFs/soil ingestion slope factor
(pci)-1
IRs/soil ingestion rate (mg/d)
1x10"3/conversion factor (g/mg)
EF/exposure frequency (d/yr)
ED/exposure duration (yr)
Default
ID'6
See Attachment D
120 (age-averaged)
350
30
Inhalation of Fugitive Dusts. Inhalation of fugitive
dusts is a consideration in surface soils.

Equation 2 is used to calculate  fugitive dust SSLs for
radionuclides.  This equation requires calculation of a
particulate emission factor (PEF,  Equation 3) that relates
the  concentration of contaminant  in  soil to  the
concentration  of dust particles in  air.   This PEF
represents an annual average emission rate based on
wind erosion that should be compared  with chronic
health criteria.  It is not appropriate for evaluating the
potential for more acute exposures.

Both the emissions portion and  the dispersion portion
(Q/C) of the PEF equation have been updated since the
first publication of RAGS HHEM, Part B, in 1991.  As
in Part B, the emissions part of the  PEF  equation is
based on the "unlimited reservoir" model developed to
estimate particulate  emissions  due to wind erosion
(Cowherd et al., 1985).   The  box model in RAGS
HHEM, Part B has  been replaced with a Q/C term
derived from the modeling exercise using the AREA-ST
model  incorporated  into EPA's  Industrial Source
Complex Model (ISC2) platform. The AREA-ST model
was run with a full year of meteorological  data for 29
U.S. locations selected to be representative of a range of
meteorologic conditions across the nation (EQ, 1993).
The results  of these modeling  runs  are presented in
Exhibit 10 for square area sources of 0.5 to 30 acres in
size.

When developing a site-specific  PEF for the inhalation
pathway, place the  site  into  a  climatic  zone  (see
Attachment B). Then select a Q/C value from Exhibit
10  that best represents a site's size and meteorological
                                                  2-19

-------
conditions.

Additional  information on  the update  of the  PEF
equation is provided in the TBD. Cowherd etal. (1985)
present methods for site-specific measurement of the
parameters necessary to calculate a PEF.

The default PEF for radionuclides presented in Equation
2 is the same as the one given in the SSG for chemicals.
The default parameter values shown in Equation 3 have
been  chosen  using the guidance  of Cowherd  et  al.
(1985), based upon the assumption of a family garden.
The calculated PEF thus accounts for the increase in the
fugitive dust concentration anticipated with an area of
tilled soils.
 Equation 2:  Screening Level Equation for Inhalation
              of Radioactive Fugitive Dusts from
              Residential Soil
     SSL,,
                             TR
SF -
                      )xlx;o*3x£7?x£T)x[£T + (£T x DP)]
                      }             L   ° ^  '   '"
 Parameter/Definition (units)

 TR/target cancer risk (unitless)
 SF,/inhalation slope factor (pCi~1)
 IR,/inhalation rate (m3/d)
 PEF/particulate emission
    factor (m3/kg)
 1x10+3/conversion factor (g/kg)
 EF/exposure frequency (d/yr)
 ED/exposure duration (yr)
 ETo/exposure time fraction,
    outdoor (unitless)
 ET/exposure time fraction,
    indoor (unitless)
 DF/dilution factor for indoor
    inhalation, (unitless)
                     Default

                     10-6
                     See Attachment D
                     20
                     1.32x10+9
                     (Equation 3)

                     350
                     30
                     0.073

                     0.683

                     0.4
                                             Equation 3:  Derivation of the Particulate Emission
                                                         Factor
                                                PEF = QIC
                                                                          3600
                                                             0.036 x (1  - V) x (UJUf x p(x)
                                             Parameter/Definition (units)

                                             PEF/particulate emission factor
                                                (m3/kg)
                                             Q/C/inverse of mean cone, at
                                                center of a 0.5-acre-square
                                                source (g/m2-s per kg/m3)
                                             V/fraction of vegetative cover
                                                (unitless)
                                             Um/mean annual windspeed  (mis)
                                             11,/equivalent threshold value of
                                                windspeed at 7 m (mis)
                                             F(x)/function dependent on Um/U,
                                               derived using Cowherd et al.
                                               (1985) (unitless)
Default

 1.32x10+g

90.80


0.5 (50%)

4.69
11.32

 0.194
                                                    2-20

-------
Exhibit 10 . QIC Values by Source Area, City, and Climatic Zone

Zone I
Seattle
Salem
Zone II
Fresno
Los Angeles
San Francisco
Zone III
Las Vegas
Phoenix
Albuquerque
Zone IV
Boise
Winnemucca
Salt Lake City
Casper
Denver
Zone V
Bismark
Minneapolis
Lincoln
Zone VI
Little Rock
Houston
Atlanta
Charleston
Raleigh-Durham
Zone VII
Chicago
Cleveland
Huntington
Harrisburg
Zone VIM
Portland
Hartford
Philadelphia
Zone IX
Miami

0.5 Acre

82.72
73.44

62.00
68.81
89.51

95.55
64.04
84.18

69.41
69.23
78.09
100.13
75.59

83.39
90.80
81.64

73.63
79.25
77.08
74.89
77.26

97.78
83.22
53.89
81.90

74.23
71.35
90.24

85.61

1 Acre

72.62
64.42

54.37
60.24
78.51

83.87
56.07
73.82

60.88
60.67
68.47
87.87
66.27

73.07
79.68
71.47

64.51
69.47
67.56
65.65
67.75

85.81
73.06
47.24
71.87

65.01
62.55
79.14

74.97
QIC (g/m2-s
2 Acre

64.38
57.09

48.16
53.30
69.55

74.38
49.59
65.40

53.94
53.72
60.66
77.91
58.68

64.71
70.64
63.22

57.10
61.53
59.83
58.13
60.01

76.08
64.78
41.83
63.72

57.52
55.40
70.14

66.33
per kg/m3)
5 Acre

55.66
49.33

41.57
45.93
60.03

64.32
42.72
56.47

46.57
46.35
52.37
67.34
50.64

55.82
61.03
54.47

49.23
53.11
51.62
50.17
51.78

65.75
55.99
36.10
55.07

49.57
47.83
60.59

57.17

10 Acre

50.09
44.37

37.36
41.24
53.95

57.90
38.35
50.77

41.87
41.65
47.08
60.59
45.52

50.16
54.90
48.89

44.19
47.74
46.37
45.08
46.51

59.16
50.38
32.43
49.56

44.49
43.00
54.50

51.33

30 Acre

42.86
37.94

31.90
35.15
46.03

49.56
32.68
43.37

35.75
35.55
40.20
51.80
38.87

42.79
46.92
41.65

37.64
40.76
39.54
38.48
39.64

50.60
43.08
27.67
42.40

37.88
36.73
46.59

43.74
2-21

-------
External  Exposure  to  Radionuclides in Soil.   An
individual residing on  a  contaminated site will be
exposed to radiation emitted by radionuclides present in
the soil. In modeling external exposure to contaminated
soil, the RAGS/HHEM Part B model (U.S. EPA, 1991c)
does not account for the following processes:

    radioactive decay and progeny (i.e., radioactive
    daughters) ingrowth;
    correction  factors  for   the  geometry of  the
    contaminated soil;
    depletion  of the  contaminated soil  horizon by
    environmental processes, such as leaching, erosion,
    or plant uptake; and
    corrections for shielding by clean cover material.

The RAGS/HHEM Part B  model does not provide any
corrections for radioactive decay. When ingrowth of
progeny is expected to be of importance, the progeny are
included at the outset of the SSL calculations.

The  RAGS/HHEM  Part  B  model  assumes that an
individual is exposed to  a  source  geometry that is
effectively an infinite slab. The concept of an "infinite
slab" means that the thickness of the contaminated zone
and its aerial extent are so large that it behaves as if it
were infinite in its physical dimensions. In practice, soil
contaminated to a depth greater than about 15 cm and
with an aerial extent greater than about 1,000 m2 will
create a radiation field comparable to that of an infinite
slab.

To accommodate  the fact that  in most residential
settings the assumption of an infinite slab source will
result in overly conservative SSLs, an adjustment for
source  area  is  considered to be   an important
modification to the RAGS/HHEM Part B model. Thus,
an area correction factor, ACF, has been added to the
calculation of SSLs.

No soil depletion processes are assumed to take place.
Accordingly,  the  SSL   model  assumes  that  the
contaminated zone is  a constant, non-depleting source
of radioactivity.  This assumption provides an upper
bound estimate of exposure to radionuclides in soil.

For the purposes of this report,  adjustments for clean
cover are  not needed since, in all cases, it is assumed
that the contaminated soil  extends to the surface.  The
SSL model provides adjustments for indoor occupancy
and  associated   shielding  effects  by  the  simple
application of a gamma shielding factor and indoor
occupancy time adjustment.
Equation 4: Screening Level Equation for External
Exposure to Radionuclides in Soil
ssr - TR
EXT T^TJ
SFe*(—)*ED* ACF x [ETo + (ETi x GSF)]
Parameter/Definition (units)
TR/target cancer risk (unitless)
SFe/external exposure slope factor
(g/pCi/yr)
EF/exposure frequency (d/yr)
ED/exposure duration (yr)
ACF/area correction factor
ET0/exposure time fraction, outdoor
(unitless)
ET/exposure time fraction, indoor
(unitless)
GSF/gamma shielding factor
Default
1Q-6
See Attachment D
350
30
0.9
0.073
0.683
0.4
With the exception of the area correction factor, default
values are used for all input parameters in Equation 4 to
calculate external exposure SSLs.  The amount of data
required to  derive  site-specific  values  for  these
parameters makes their collection and use impracticable
for calculation of simple site-specific SSLs.  Therefore,
site-specific data are generally not available for this
exposure pathway. Alternative area correction factors,
for use when  site-specific  data are  available,  are
discussed in the TBD.  The generic SSLs presented in
Appendix A of the TBD are recommended for all sites.

Ingestion of Homegrown Produce. Persons living
on a contaminated site may ingest radioactive material
by consumption of plants grown in a family garden.  In
this model, the fruits and vegetables primarily become
contaminated by root uptake of radionuclides contained
in the pore water of the soil in which the plants  are
growing.

The following factors  have  been added/changed  for
exposure through this  pathway for radionuclides  as
compared to  chemicals:

    soil-plant transfer  factors used to estimate root
    uptake  from soil assume that the  roots  are wholly
    exposed to contaminated soil;
                                                 2-22

-------
•   air deposition, rain splash, and irrigation are not
    included;
•   environmental equilibria  assumed to  exist for
    estimating concentrations of 3H and 14C in plants;
    and
•   no more than 50% of produce is  assumed to be
    homegrown (i.e., contaminated plant fraction < 0.5),
    with adjustment for small site areas (i.e., <2,000
    m2).

The model accounts for that uptake with a simple soil-
to-plant transfer  factor.  These soil-to-plant transfer
factors have been developed based upon the assumption
that the entire plant root system is wholly exposed to
contaminated soil.

If the plant roots extend to a depth of  100 cm but the
radionuclide contaminants are confined to the upper 15
cm, an initial assumption may be that only 15% of the
root system is active in accumulating contaminants and
that the reported soil-to-plant transfer factors should be
reduced by a correction factor of 0.15.  However, the
equation for calculation of SSLs for this pathway does
not apply  any  reduction to the soil-to-plant transfer
factors. The basis for this assumption is as follows.

Most plant root systems are in fact very active in the
upper soil horizon, especially in the upper 15 cm of soil.
This  point is illustrated in a number of ways: 1) by
illustrations of root morphology and growth habit, 2)
positive physiological factors including the availability
of water, oxygen and nutrients near the soil surface, 3)
negative physiological or agronomic factors—including
subsurface soil compaction, subsurface zones of acidity,
perched water tables, hypoxia, etc., 4) interactions with
soil microbes—with  a special focus on  mychorrizal
fungi, and 5) split root studies.  Thus, roots commonly
proliferate  in the upper layers of soil.  If one assumes
that a plant is  actively  growing, then  ion uptake
characteristics and lateral root growth strongly suggest
that simply attributing 15% of root uptake activity to the
upper 15 cm of the  soil  is not  a  sound approach.
Environmental forces may influence root growth to one
or more meters in depth, but more so for obtaining water
than nutrients.  In reality, the upper 15  cm of soil may
include 50% or more of the root system—and thus 50%
or more of the ion uptake (SC&A, 1994).

The decision to not include air deposition or rain-splash
does not affect any radionuclides because the increase in
concentration from this route is not significant or is
markedly reduced when peeling, washing, cooking, and
other  food preparation  processes  are  taken  into
consideration (U.S. EPA, 1994d). The decision to not
include the irrigation pathway is only an issue when
there is medium to heavy irrigation using contaminated
water for a radionuclide with a long half-life, a low Kd
value,  and an insignificant contribution from external
exposure.   The  model  also  makes  a  conservative
assumption to ignore the  decay between harvest and
ingestion and any removal during food processing.

The model does not include any special calculations for
estimating concentrations of 3H and 14C in plants.  Such
calculations assume that a state  of equilibrium exists
among  the  concentrations of  3H  and  14C in  all
environmental media—air, water, food products, and
body  tissues.    This  assumption may be  overly
conservative for a radioactively contaminated site with
a finite area, but may be appropriate for an individual
pathway, such  as soil-to-plant pathway.  For these
calculations,  the   3H concentration  in the  plant  is
assumed to be  the same as that in the contaminated
water to which the plant is exposed.   Similarly, the
specific activity of 14C in the plant (i.e., pCi/g of 14C per
gram of carbon in  the plant) is the same as that of the
ambient CO2.

The  model provides a factor, the Contaminated Plant
Fraction (CPF), to adjust for the fraction of fruits and
vegetables  obtained   from  the   contaminated  site
(assuming that the family living on the site obtains a
portion  of  their  fruits  and  vegetables   from
uncontaminated sources). The ingestion rate used in the
calculation thus represents a total ingestion rate, which,
when multiplied by the CPF, gives the ingestion rate of
contaminated fruits and vegetables.

The  CPF is dependent upon the surface area of the
contaminated zone in m2, As, and is calculated using the
following equation.

    CPF = A, / 4,000  0  < A,  < 2,000 m2
    CPF = 0.5
A, > 2,000 m2
For an  area greater than 2,000 m2 (i.e., the default
contaminated site surface area), the CPF is set at an
upper bound of 0.5 (i.e., site residents acquire no more
than one-half of their fruits and vegetables from onsite).
                                                  2-23

-------
The  factor  decreases linearly  as the  size  of the
contaminated area decreases below 2,000 m2 (one-half
acre).
 Equation 5:  Screening Level Equation for Ingestion
             of Radionuclides in Homegrown
             Produce
    SSL =
                           TR
          SF x (m  + JR. ) x 1x10+3 x CPF x-TF  x-ED
             p  ^  vf   lv>                p
 Parameter/Definition (units)

 TR/target cancer risk (unitless)
 SFp/produce ingestion slope factor
    (pCi)-1
 I Rvf/vegetable and fruit ingestion
    rate (kg/yr)
 IR,v/leafy vegetables ingestion rate
   (kg/yr)
 1x10+3/conversion factor (g/kg)
 CPF/contaminated plant fraction
    from the site (unitless)
 TFp/soil-to-plant transfer factor
    (pCi/g plant per pCi/g soil)
 ED/exposure duration (yr)
Default

1Q-6
See Attachment D

42.7

4.66


0.5

See Attachment C

30
pathway when the size (i.e., area and depth) of the
contaminated  soil  source  is  known  or  can  be
estimated with confidence.

Attachment D  provides  the  toxicity criteria  and
regulatory benchmarks for 60 radionuclides commonly
found at NPL sites.  These criteria were obtained from
HEAST (U.S. EPA,  1995a),  and Drinking  Water
Regulations and Health Advisories (U.S. EPA, 1995c),
which are regularly updated. Prior to calculating SSLs
at a site, all relevant radionuclide-specific values in
Attachment D should be checked against the most
recent version of their sources to ensure that they are
up to date.

Site-specific parameters necessary to calculate SSLs for
subsurface soils are  listed on Exhibit 11, along with
recommended sources and measurement methods.  In
addition to the soil parameters described in Step 3, other
site-specific input parameters include soil moisture,
infiltration rate, and aquifer parameters.  Guidance for
collecting or estimating these other parameters at a site
is provided on Exhibit 11 and in Attachment A.
Default values are  used for all input parameters in
Equation 5 to calculate SSLs for this pathway. With the
exception of the contaminated site surface area, As, the
amount of data required to derive site-specific values for
these parameters  makes  their collection  and  use
impracticable for calculation  of simple site-specific
SSLs.  Therefore, site-specific data are generally not
available for this exposure pathway.  The generic SSLs
presented in the TBD are recommended for all sites,
except for very small sites with As< 2,000m2 (i.e., <0.5
acre).

2.5.2          SSL   Equations-Subsurface
Soils. The Soil Screening Guidance for Radionuclides
addresses only one exposure pathway for subsurface
soils: ingestion of ground  water contaminated by the
migration of contaminants through soil to an underlying
potable aquifer.  Because the equations developed to
calculate SSLs for these pathways assume  an infinite
source, they can violate mass-balance considerations,
especially for small sources.

To  address  this concern, the guidance also includes
equations for calculating mass-limit SSLs for   this
                                                  2-24

-------
Exhibit 11. Site-specific Parameters for Calculating Subsurface SSLs
SSL Pathway
Migration to
Parameter ground water
Source Characteristics
Source area (A) •
Source length (L) •
Source depth • •
Soil Characteristics
Soil texture O
Dry soil bulk density (pb) O
Soil moisture content (w) O
Soil pH 00
Moisture retention exponent O
(b)
Saturated hydraulic O
conductivity (Ks)
Avg. soil moisture content (6W) • O
Meteorological Data
Air dispersion factor (Q/C)
Hydrogeologic Characteristics (DAF)
Hydrogeologic setting O
Infiltration/recharge (I) •
Hydraulic conductivity (K) •
Hydraulic gradient (i) •
Aquifer thickness (d) •
Data source

Sampling data
Sampling data
Sampling data

Lab measurement
Field measurement
Lab measurement
Field measurement
Look-up
Look-up
Calculated

Q/C table (Table 5)

Conceptual site
model
HELP model;
Regional estimates
Field measurement;
Regional estimates
Field measurement;
Regional estimates
Field measurement;
Regional estimates
Method

Measure total area of contaminated soil
Measure length of source parallel to ground water flow
Measure depth of contamination or use conservative
assumption

Particle size analysis (Gee & Bauder, 1986) and USDA
classification; used to estimate 6W & I
All soils: ASTM D 2937; shallow soils: ASTM D 1556,
ASTM D 2167, ASTM D 2922
ASTM D 2216; used to estimate dry soil bulk density
McLean (1982); used to select pH-specific K,, (metals)
Attachment A; used to calculate 6W
Attachment A; used to calculate 6W
Attachment A

Select value corresponding to source area, climatic
zone, and city with conditions similar to site

Place site in hydrogeologic setting from Aller et al.
(1987) for estimation of parameters below (see
Attachment A)
HELP (Schroeder et al., 1984) may be used for site-
specific infiltration estimates; recharge estimates also
may be taken from Aller et al. (1987) or may be
estimated from knowledge of local meteorologic and
hydrogeologic conditions
Aquifer tests (i.e., pump tests, slug tests) preferred;
estimates also may be taken from Aller et al. (1987) or
Newell et al. (1990) or may be estimated from
knowledge of local hydrogeologic conditions
Measured on map of site's water table (preferred);
estimates also may be taken from Newell et al. (1990)
or may be estimated from knowledge of local
hydrogeologic conditions
Site-specific measurement (i.e., from soil boring logs)
preferred; estimates also may be taken from Newell et
al. (1990) or may be estimated from knowledge of local
hydrogeologic conditions
• Indicates parameters used in the SSL equations.
O Indicates parameters/assumptions needed to estimate SSL equation parameters.
2-25

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Migration  to Ground  Water SSLs.   The Soil
Screening Guidance for Radionuclides uses a simple
linear equilibrium soil/water partition equation or a
leach test  to  estimate  contaminant  release in soil
leachate. It also uses a simple water-balance equation to
calculate a dilution factor to account for reduction of
soil leachate concentration from mixing in an aquifer.

The methodology for developing SSLs for the migration
to ground water pathway was designed for use during
the early stages of a site evaluation when information
about subsurface conditions may be limited. Hence, the
methodology is based on rather conservative, simplified
assumptions  about  the   release and  transport  of
contaminants in the subsurface (Exhibit 12).  These
assumptions are inherent in the  SSL equations and
should be reviewed for consistency with the conceptual
site model (see Step 2) to determine the applicability of
SSLs to the migration to ground water pathway.

To calculate SSLs for the migration to ground water
pathway,  multiply  the   acceptable   ground  water
concentration by the dilution factor  to obtain a target
soil leachate concentration. For example, if the dilution
factor is 10 and the acceptable  ground water concen-
tration is 10 pCi/L, the target soil/water leachate concen-
tration would be lOOpCi/L. Next, the partition equation
is used  to calculate the total soil concentration (i.e.,
SSL) corresponding to this soil leachate concentration.
Alternatively, if a leach test is used, compare the target
soil  leachate concentration to extract concentrations
from the leach tests.

SoilAA/ater Partition  Equation.    The  soil/water
partition equation (Equation 6) relates concentrations of
contaminants adsorbed to soil organic carbon to soil
leachate concentrations in the zone of contamination.  It
calculates SSLs corresponding to target soil leachate
contaminant concentrations (Cw).  An adjustment has
been added  to  the  equation  to   relate   sorbed
concentration  in  soil  to the  measured  total soil
concentration. This adjustment assumes that soil-water
and solids are conserved during sampling.
 Exhibit 12: Simplifying Assumptions for the SSL
 Migration to Ground Water Pathway

 •  The source is infinite (i.e., steady-state
    concentrations will be maintained in ground
    water over the exposure period of interest)
 •  Contaminants are uniformly distributed
    throughout the zone of contamination
 •  Soil contamination extends from the surface to
    the water table (i.e., adsorption sites are filled in
    the unsaturated zone beneath the area of
    contamination
 •  There is no chemical or biological degradation in
    the unsaturated zone
 •  Equations in this document do not account for
    decay, however an electronic version of these
    equations will account for decay in the
    unsaturated zone
 •  Equilibrium soil/water partitioning is
    instantaneous and linear in the contaminated
    soil
 •  The receptor well is at the edge of the source
    (i.e., there is no dilution from recharge
    downgradient of the site) and is screened within
    the plume
 •  The aquifer is unconsolidated and unconfined
    (surficial)
 •  Aquifer properties are homogenous and
    isotropic
 •  Chelating  or complexing agents not present

 •  No facilitated transport (e.g., colloidal transport
    of inorganic contaminants in aquifer
The use of the soil/water partition equation to calculate
SSLs assumes  an  infinite  source (steady-state)  of
contaminants that extend to the water table.   More
detailed models may be used to calculate higher SSLs
that are still protective in some situations. For example,
contaminants at  sites  with  shallow  sources, thick
unsaturated   zones,  degradable   contaminants,   or
unsaturated zone characteristics (e.g., clay layers) may
attenuate before they reach ground water. Part 3 of the
TBD provides information on the  use  of unsaturated
zone models for soil screening. The decision to use such
models  should be based on balancing the  additional
investigative and modeling costs required to apply the
more complex models against the cost savings that will
result from higher SSLs.
                                                  2-26

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 Equation 6 :  Soil Screening Level Partitioning
             Equation for Migration to Ground Water
SSL = C
\xlO -
                              ( K + — )
                                    Pi
 Parameter/Definition (units)
 SSL/ Screening Level in Soil (pCi/g)
 Cw/target soil leachate concentration
   ( pCi/L)
 1x10~3/conversion factor (kg/g)
 Kd/soil-water partition coefficient
 (L/kg)
 e^water-filled soil porosity
   C-wate/'-soil)
 n/soil porosity (Lpore/Lsoil)
 pb/dry soil bulk density (kg/L)
 Ps/soil particle density (kg/L)
           Default
           MCL ax dilution
          factor
          chemical specific

          0.3
           1.5
           2.65
a Radionuclide -specific (see Attachment D).
b See Attachment C.

Leach Test.  A leach test may be used instead of the
soil/water partition equation.  If a leach test is  used,
compare the target soil leachate concentration (MCL x
Dilution Factor) to extract concentrations from the leach
tests.  In some instances, a leach test may be more useful
than  the partitioning  method,  depending  on  the
constituents of concern and the possible presence of
RCRA wastes.  If this option is chosen, soil parameters
are not needed for this pathway.  However, a dilution
factor must still be calculated. This guidance suggests
using  the   EPA  Synthetic   Precipitation  Leaching
Procedure (SPLP, EPA  SW-846 Method 1312,  U.S.
EPA, 1994e).  The SPLP was developed to model an
acid  rain  leaching  environment  and  is  generally
appropriate for a contaminated soil scenario.  Like most
leach tests, the SPLP may not be appropriate for  all
situations (e.g., soils contaminated with oily constituents
may not  yield suitable results).  Therefore, apply the
SPLP with discretion.

EPA is aware that many leach tests are available for
application at hazardous waste sites, some of which may
be appropriate in specific situations (e.g., the Toxicity
Characteristic  Leaching Procedure (TCLP)  models
leaching  in  a municipal landfill  environment).   It is
beyond the scope of this document to discuss in  detail
leaching procedures and the appropriateness of their use.
Stabilization/Solidification of CERCLA  and  RCRA
Wastes (U.S. EPA, 1989b) and the EPA SAB's  review
of  leaching  tests  (U.S.  EPA,  1991c)  discuss  the
application of various  leach tests to various waste
disposal scenarios. Consult these documents for further
information.

See Step 3 for guidance on collecting subsurface soil
samples that can be used for leach tests.  To  ensure
adequate precision of leach test  results, leach tests
should be conducted in triplicate.

Dilution Factor Model.  As soil leachate moves through
soil and ground water, contaminant concentrations are
attenuated  by  adsorption and degradation.    In  the
aquifer, dilution by clean ground water further reduces
concentrations  before  contaminants   reach  receptor
points (i.e., drinking water wells).  This reduction in
concentration can be expressed by a dilution attenuation
factor (DAF),  defined  as the ratio  of soil  leachate
concentration to  receptor point concentration.  The
lowest possible DAF is 1, corresponding to the situation
where there  is  no  dilution  or  attenuation  of  a
contaminant (i.e., when the concentration in the receptor
well is equal to the soil leachate concentration).  On the
other hand, high DAF  values correspond to a large
reduction  in contaminant  concentration from  the
contaminated soil to the receptor well.

The  Soil  Screening  Guidance  for Radionuclides
addresses  only  one  of these  dilution-attenuation
processes:  contaminant dilution in ground water.  A
simple mixing zone equation derived from  a  water-
balance relationship (Equation 7) is used to calculate a
site-specific  dilution factor.  Mixing-zone  depth  is
estimated from Equation  8, which relates it to aquifer
thickness along with the other parameters from Equation
7.  Mixing  zone depth  should not  exceed aquifer
thickness (i.e., use aquifer thickness as the upper limit
for mixing zone depth).

Because  of the uncertainty resulting  from the wide
variability  in   subsurface   conditions   that  affect
contaminant migration in ground water, defaults  are not
provided for  the dilution model equations. Instead, a
default DAF  of 20 has been selected  as protective for
contaminated soil  sources  up to  0.5 acre  in size.
Analyses using the mass-limit models described in the
SSG for chemicals  suggest that a DAF of 20 may be
protective  of larger sources  as well; however, this
                                                   2-27

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hypothesis should be evaluated on a site-specific basis.
A discussion of the  basis for the default DAF and a
description of the mass-limit analysis is found in Part
2.6.4 of the TBD. However, since migration to ground
water SSLs are most  sensitive to the DAF, site-specific
dilution factors should be calculated.
Equation 7: Derivation of Dilution Factor
_ Kx/xd
w /XL
Parameter/Definition (units)
DF^/dilution factor (unitless)
K/aquifer hydraulic conductivity
(m/yr)
i/hydraulic gradient (m/m)
I/infiltration rate (m/yr)
d/mixing zone depth (m)
L/source length parallel to ground
water flow (m)
Default
20 (0.5-acre
source)
 Equation 8:    Estimation of Mixing Zone Depth
        d = (0.0112Z,2)0-5 + dax [1   exp(
                                   Lxl
 Parameter/Definition (units)

 d/mixing zone depth (m)
 L/source length parallel to ground water flow (m)
 I/infiltration rate (m/yr)
 K/aquifer hydraulic conductivity (m/yr)
 i/hydraulic gradient (m/m)
 da/aquifer thickness (m)	
Mass-Limit SSLs. Use of infinite source models to
estimate  migration to ground water can violate mass
balance considerations, especially for small sources. To
address this  concern, the Soil  Screening Guidance
includes models for calculating mass-limit SSLs for this
pathways  (Equation 9) that provide a lower limit to
SSLs when the area and depth (i.e., volume) of the
source are known or can be estimated reliably.

A mass-limit SSL represents the level of radionuclide in
the subsurface that is still protective when the entire
volume of contamination leaches  over the  30 year
exposure duration and the level of radionuclide at the
receptor does not exceed the health-based limit.

To use mass-limit SSLs, determine the area and depth of
the source, calculate both standard and mass-limit SSLs,
compare them for each radionuclide  of concern and
select the higher of the two values.

Note   that  Equation  9  requires   a  site-specific
determination of the average depth of contamination in
the source. Step 3 provides guidance for conducting
subsurface sampling to determine source depth. Where
the actual average depth of contamination is uncertain,
a  conservative estimate   should  be  used (e.g., the
maximum possible depth in the unsaturated zone). At
many sites, the average water table depth may be used
unless there is reason to believe that contamination
extends below the water table. In this case SSLs do not
apply and further investigation of the source in question
is needed.
Equation 9: Mass-Limit Soil Screening Level for
Migration to Ground Water
C x/xEDx \xiQ-3
SSL - w
Pbxds
Parameter/Definition (units)
SSL/ Soil Screening Level in Soil
(pCi/g)
Cw/target soil leachate concentration
(pCi/L)
I/infiltration rate (m/yr)
ED/exposure duration (yr)
1x10~3/conversion factor (kg/g)
pb/dry soil bulk density (kg/L)
dj/depth of source (m)
Default

( MCL, f *
dilution factor
site-specific
70
-
1.5
site-specific
a Radionuclide -specific, see Attachment D.

2.5.3    Address   Exposure  to   Multiple
Radionuclides . The SSLs generally correspond to
a 10~6  lifetime cancer risk level.   The potential for
additive effects has  not been "built in" to the SSLs
through apportionment. While the pathways included in
the  analysis  are  considered to  represent those  a
residential setting, SSLs are not calculated for a specific
scenario  (i.e., SSLs are not summed  over a set of
pathways). For radionuclides, EPA believes that setting
a 10~6  risk level for individual   radionuclides  and
pathways generally will lead to cumulative site risks
within the 10~4 to 10~6 risk range for the combinations of
radionuclides typically found  at NPL sites.
                                                  2-28

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SSLs and the Use of Surrogate Measurements.
For sites with multiple radionuclides, it may be possible
to measure just one of the radionuclides and still be able
to demonstrate compliance (with the target risk level of
10~6) for the radionuclides present through the use of
surrogate measurements.  Both time and resources can
be saved if the analysis of one radionuclide is simpler
than the analysis of the other. For example, using the
measured  137Cs concentration as a surrogate  for  90Sr
reduces the analytical costs because the wet chemistry
separations do not have to be performed for 90Sr on
every sample. In using one radionuclide to estimate the
presence   of   others,   a  sufficient  number  of
measurements, spatially separated throughout the EA,
should be made to  establish  a consistent ratio.  The
number of measurements needed to determine the ratio
is selected using the DQO process and based on the
chemical,  physical, and radiological characteristics of
the nuclides and the site.

The potential for shifts or variations in the radionuclide
ratios means that the surrogate method should be used
with caution. Physical or chemical differences between
the radionuclides may produce different migration rates,
causing the radionuclides to separate and changing the
radionuclide ratios.  Remediation activities have a
reasonable potential  to  alter  the  surrogate  ratio
established prior to  remediation. When  the ratio  is
established  prior  to  remediation,  additional  post-
remediation samples should be collected to ensure that
the data used to establish the ratio are still appropriate
and representative of the existing site condition. If these
additional post-remediation samples are not consistent
with the pre-remediation data, surrogate ratios should be
re-established.

2.6    Step 6: Comparing Site Soil
                  Radionuclide
                  Concentrations to
                  Calculated SSLs

Nowthatthe site-specific SSLs have been calculated for
the  potential radionuclides of concern, compare  them
with the site radionuclide concentrations.  At this point,
it is reasonable to review the CSM with the actual site
data to confirm its accuracy and the overall applicability
of the Soil Screening Guidance for Radionuclides.
In theory, an exposure area would be screened from
further  investigation  when the true mean  of the
population of radionuclide  concentrations falls below
the established  screening  level.    However,  EPA
recognizes that  data obtained from sampling  and
analysis are never perfectly representative and accurate,
and that the cost of trying to achieve perfect results
would be quite high. Consequently, EPA acknowledges
that some uncertainty in data must be tolerated, and
focuses on controlling the uncertainty which affects
decisions  based  on  those  data.  Thus, in the  Soil
Screening  Guidance  for  Radionuclides,  EPA  has
developed an approach for surface soils to minimize the
chance of incorrectly deciding to:

•     Screen out areas when the correct decision would
      be to investigate further (Type I error); or

•     Decide to  investigate  further when the correct
      decision would be to screen out the area (Type II
      error).

The approach sets limits on the probabilities of making
such decision errors, and acknowledges that there is a
range (i.e., gray region) of radionuclide concentrations
around the screening level where the variability in the
data will make it difficult to determine whether the
exposure area average concentration is actually above or
below the screening level.  The Type I and Type II
decision error rates have been set at 5 percent and 20
percent, respectively, and the gray region has been set
between one-half and two times the SSL.  By specifying
the upper edge of the gray region as twice the SSL, it is
possible that exposure areas with mean radionuclide
concentration values slightly above the  SSL may be
screened from further study.

2.6.1    Evaluation of Data for Surface Soils.
Thus, for surface soils, the radionuclide concentrations
in each composite sample from an exposure area are
compared to two  times  the SSL.   Under the  Soil
Screening Guidance DQOs, areas are screened out from
further study when radionuclide concentrations in all of
the composite samples are less than two times the SSLs.
Use  of this decision  rule  (comparing  radionuclide
concentrations to twice the  SSL) is appropriate only
when the quantity and quality of data are comparable to
the levels discussed in this guidance.
                                                 2-29

-------
For existing data sets that may be more limited than
those discussed in this guidance, the 95 percent upper-
confidence  limit  on  the arithmetic  mean of the
radionuclide concentrations in surface soils (i.e., the
Land method as described in the Supplemental Guidance
to RAGS: Calculating the Concentration Term (U.S.
EPA, 1992c) should be compared to the SSL. If the 95
percentile on the arithmetic mean is less than the SSL,
the exposure area may be screened out.

The  TBD discusses the  strengths and  weaknesses of
using the Land method for making screening decisions.
As an alternative to the  Max test, the TBD provides
guidance  on  performing  the Sign  test  when  the
contaminant is not present in background.

2.6.2    Evaluation of Data for  Subsurface
Soils.   In this guidance, fewer samples are collected
for subsurface soils than for  surface soils; therefore,
different decision rules apply.

Since subsurface soils are not characterized as well as
surface   soils, there is  less confidence  that  the
concentrations measured are representative of the entire
source.    Thus,  a more  conservative approach to
screening is warranted. Because it may not be protective
to allow for comparison to values above the SSL, mean
radionuclide concentrations from each soil boring taken
in a source area are compared with the calculated SSLs.
Source areas with any mean soil boring radionuclide
concentration greater than the SSLs generally warrant
further consideration.  On the other hand,  where the
mean soil boring radionuclide  concentrations within a
source  are all less than the SSLs,  that source area is
generally screened out.

2.7    Step 7:  Addressing Areas
                  Identified for Further
                  Study

The  radionuclides, exposure pathways, and areas that
have been identified for further study become a subject
of the RI/FS. The results of the baseline risk assessment
conducted as part of the RI/FS will establish the basis
for taking remedial action.  The threshold for taking
action differs from the criteria used for screening. As
outlined  in Role of the Baseline Risk Assessment in
Superfund Remedy Selection Decisions  (U.S.  EPA,
199Id),  remedial action at  NPL sites is generally
warranted where cumulative risks for current or future
land use exceed 1x10"4.  The data collected for soil
screening are  useful  in the RI and baseline  risk
assessment.  However, additional data will probably
need to be collected during future site investigations.

Once the decision has been made to initiate remedial
action,  the  SSLs  can  then serve  as  preliminary
remediation goals. This process is referenced in Section
1.2 of this document.

       FOR FURTHER INFORMATION

More detailed discussions of the  technical background
and assumptions supporting the development of the Soil
Screening Guidance are presented in the Soil Screening
Guidance for Radionuclides: Technical Background
Document (U.S. EPA,  1999). For additional copies of
this  guidance document, the Technical Background
Document, or other EPA documents, call the National
Technical Information Service (NTIS) at (703) 605-6000
or  1-800-553-NTIS (6847).  Copies may  also be
downloaded from the internet at:
http: //www. epa. gov/superfund/re source s/radiation/rad
risk.htm.
                                                2-30

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  EvaluationManual(HHEM), PartB, Development
  of Risk-Based  Preliminary  Remediation Goals.
  Office of Emergency and Remedial Response,
  Washington,   DC.  Publication  9285.7-01B.
  EPA/540/R-92/003. NTIS PB92-963333.
U.S. EPA, 1991e. Description  and Sampling  of
  Contaminated Soils: A Field Pocket Guide.  Office
  of   Environmental   Research  Information,
  Cincinnati, OH. EPA/625/12-91/002.

U.S. EPA. 1992a.  Considerations in Ground-Water
  Remediation  at Superfund  Sites  and  RCRA
  Facilities—Update.  Office  of Emergency and
  Remedial Response, Washington, DC. Directive
  9283.1-06. NTIS PB91-238584/CCE.

U.S.  EPA.   1992b.   Estimating   Potential for
  Occurrence ofDNAPL at Superfund Sites.  Office
  of   Emergency  and   Remedial   Response,
  Washington, DC. Publication 9355.4-07FS.  NTIS
  PB92-963338.

U.S. EPA. 1992c. Supplemental Guidance to RAGS,
  Calculating the Concentration Term. Volume  1,
  Number 1, Office  of Emergency and Remedial
  Response, Washington, DC. NTIS PE92-963373

U.S. EPA. 1992d. Preparation  of Soil Sampling
  Protocols: Sampling Techniques and Strategies.
  Office of Research and Development, Washington,
  DC. EPA/600/SR-92/128.

U.S. EPA. 1993a. Data  Quality  Objectives for
  Superfund: Interim Final Guidance. Publication
  9255.9-01. Office  of Emergency and Remedial
  Response, Washington, DC. Directive 9355.9-01.
  EPA 540-R-93-071. NTIS PB94-963203.

U.S. EPA.  1993b. Guidance for Evaluating Technical
  Impracticability  of Ground-Water Restoration.
  EPA/540-R-93-080. Office  of Emergency and
  Remedial Response, Washington, DC. Directive
  9234.2-25.

U.S. EPA. 1993c.  Quality Assurance for Superfund
  Environmental Data Collection Activities.  Quick
  Reference Fact Sheet.  Office of Emergency and
  Remedial Response, Washington, DC.  Directive
  9200.2-16FS. NTISPB93-963273.
                                               R-2

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U.S. EPA, 1993d. Subsurface Characterization and
  Monitoring Techniques: A Desk Reference Guide.
  Vol. I & II . Environmental Monitoring Systems
  Laboratory, Office of Research and Development,
  Las Vegas, NV. EPA/625/R-93/003a. NTISPB94-
  131497.
  EPA/540/R-96/018. NTIS PB96-9635505.

U.S. EPA. 1996b. Soil Screening Guidance: Technical
  Background Document. Office of Emergency and
  Remedial Response, Washington, DC. Directive
  9355.4-17A. EPA/540/R95/128.
U.S. EPA.  1994a.   Radon Mitigation Standards.
   Office of Air and Radiation, Washington, DC. EPA
   402-R-93-078.

U.S. EPA. 1994b. Guidance for the Data Quality
   Objectives  Process.   Quality  Assurance
   Management   Staff,  Office  of  Research and
   Development, Washington, DC. EPA QA/G-4.

U.S. EPA.   1994c.  Methods for  Evaluating  the
   Attainment of Cleanup  Standards—Volume  3:
   Reference-Based Standards for  Soils  and Solid
   Media. Environmental Statistics  and Information
   Division,   Office  of  Policy,  Planning,  and
   Evaluation, Washington, DC. EPA 230-R-94-004.

U.S.  EPA.   1994d.    Radiation   Site  Cleanup
   Regulations: Technical Support Document for the
   Development ofRadiation Cleanup Levels for Soil -
   Review Draft.   Office  of  Air  and  Radiation,
   Washington, DC.  EPA 402-R-96-011A.

U.S. EPA. 1994e. Test Methods for Evaluating  Solid
   Waste, Physical/Chemical Methods  (SW-846),
   Third Edition, Revision 2. Washington, DC.

U.S.  EPA.   1995a. Health Effects Assessment
   Summary   Tables  (HEAST): Annual  Update,
   FY1993. Environmental Criteria  and Assessment
   Office,  Office of  Health  and  Environmental
   Assessment, Office of Research and Development,
   Cincinnati, OH. EPA/540/R-95/036.

U.S. EPA. 1995b. Integrated Risk Information System
   (IRIS). Cincinnati, OH.

U.S. EPA. 1995c. Drinking  Water Regulations and
   Health Advisories. Office of Water, Washington,
   DC. EPA/822/R-95/001

U.S. EPA. 1996a. Soil  Screening Guidance: User's
   Guide.  Office of  Emergency  and  Remedial
   Response, Washington,  DC. Directive 9355.4-23.
U.S. EPA.  1997a.   Exposure Factors Handbook.
   Office of Research and Development, Washington,
   DC. EPA/600/P-95/002Fa.

U.S. EPA. 1997b. Multi-Agency Radiation Survey
   and Site Investigation Manual (MARSSIM). Office
   of  Radiation and Indoor Air, Washington, DC.
   EPA402-R-97-016.

U.S. EPA. 1997c.  Establishment of Cleanup Levels
  for CERCLA Sites with Radioactive Contamination.
   Office of Emergency and Remedial  Response,
   Washington, DC.  OSWER Directive 9200.4-18.
   EPA/540/7-97/003, NTIS PB97-963210.

U.S. EPA. 1998a.  Use of Cleanup Criteria in 40 CFR
   192 as Remediation Goals for  CERCLA Sites.
   OSWER  Directive  9200.4-25.    Office   of
   Emergency and Remedial Response, Washington,
   DC.

U.S. EPA  1998b.   Uranium Issues Workshop.
   Washington, DC. June 23-24, 1998.

U.S. EPA.  1999a.  Health Risks from Low-Level
   Environmental Expo sure to Radionuclides, Federal
   Guidance Report No. 13,, Office ofRadiation and
   Indoor Air, Washington, DC. EPA 402-R-90-001.

U.S. EPA.  1999b,  Understanding  Variation  in
   Partition  Coefficient,  Kd Values,  Volume I  &
   Volume II, Office of Radiation  and Indoor Air,
   EPA-402-R-99-004A&B.

U.S.  EPA  2000a.    Remediation   Goals  for
   Radioactively Contaminated CERCLA Sites Using
   the Benchmark Dose Cleanup Criteria in 10 CFR
   Part 40 Appendix A, I,  Criterion 6(6). Office  of
   Emergency and Remedial Response, Washington,
   DC. OSWER Directive 9200.4-35P

U.S. EPA. 2000b. Soil Screening Guidance: Technical
   Background Document. Office of Emergency and
                                               R-3

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   Remedial Response, Washington, DC. OSWER
   Directive 9355.4-16.  EPA/540-R-00-006, NTIS
   PB2000 963306.

Van Wijnen, J.H., P. Clausing, and B.  Brunekreef.
   1990.    Estimated  soil  ingestion by children.
   Environ Research 51:147-162.
                                                R-4

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        Attachment A




Conceptual Site Model Summary

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                                       Attachment A

                            Conceptual Site Model Summary

Step 1 of the Soil Screening Guidance for Radionuclides: User's Guide describes the development of a
conceptual site model (CSM) to support the application of soil screening levels (SSLs) at a site. The CSM
summary forms at the end of this attachment contain the information necessary to:

       •       Determine the applicability of SSLs to the site

       •       Calculate SSLs.
By identifying data gaps, these summary forms will help focus data collection and evaluation on the site-
specific development and application of SSLs. The site investigator should use the summary forms during
the SSL sampling effort to collect site-specific data and continually update the CSM with new information
as appropriate.

The CSM summary forms indicate the information required for determining the applicability of the soil
screening process to the site. Forms addressing source characteristics may be photocopied if more than one
source is present at a site.

A site map showing contaminated soil sources and exposure areas (EAs) should be attached to the summary.
If available, additional pages of other maps,  summaries of analytical results, or more detailed descriptions
of the site may be attached to the summary.

Form 1. General Site Information

The information included in this form is identical to the first page of the Site Inspection (SI) Data Summary
form (page B-3 in Guidance for Performing Site Inspections Under CERCLA, U.S. EPA, 1992). However,
the form should be updated to reflect any site activities conducted since the  SI was completed.

Form 2.  Site Characteristics

Form 2 indicates the information necessary to address the migration to ground water pathway and identify
subsurface conditions that may limit the applicability of SSLs.

A hydrogeologic setting is defined  as a unit with common hydrogeologic characteristics and therefore
common vulnerability to contamination. Each setting provides a composite description of the hydrogeologic
factors that control ground water movement and recharge. These factors can be used to make generalizations
in the CSM about ground water conditions.

After placing the site into one of Heath's ground water regions (Heath,  1984), consider geologic and
geomorphic features of the site and select a generic hydrogeologic setting from Aller et al. (1987) that is
most similar to the site.  If existing site information is not sufficient to definitively place the site in a setting,
it should be possible to narrow the choice to two or three settings that will reduce the range of values
necessary to develop SSLs. A copy of the setting diagram from Aller et al. (1987) should be attached to the
CSM checklist to provide a general picture of subsurface site conditions.

Ground Water Flow Direction. The direction of ground water flow in the uppermost aquifer underlying
each source is needed to determine source length parallel to that flow.  If ground water flow direction is
unknown or uncertain, assume it is parallel to the longest source dimension.
                                             A-l

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Aquifer Parameters.  Aquifer parameters needed to estimate a site-specific dilution factor include
hydraulic conductivity (K), hydraulic gradient (i), and aquifer thickness (da). Site-measured values for these
parameters are the preferred alternative.  Existing site documentation should be reviewed for in situ
measurements of aquifer conductivity (i.e., from pump test data), water table maps that can be used to
estimate hydraulic gradient, and boring logs that indicate the thickness of the uppermost aquifer.  Detailed
information on conducting and interpreting aquifer tests can be found in Nielsen (1991).

If site-measured values are not available, hydrogeologic knowledge of regional geologic conditions or
measured values in the  literature may be sources of reasonable estimates. Values from a similar site in the
same region and hydrogeologic setting also may be used, but must be carefully reviewed to ensure that the
subsurface conceptual models for the two sites show reasonable agreement. For all of these options, it is
critical that the estimates and sources be reviewed by an experienced hydrogeologist knowledgeable of
regional hydrogeologic conditions.

A third option is to obtain parameter estimates for the site's hydrogeologic setting from Aller et al. (1987)
or from the American Petroleum Institute's (API's) hydrogeologic database (HGDB) (Newell et al., 1989,
1990). Aller et al. (1987) present ranges of values for K and i by hydrogeologic setting. The HGDB contains
measured values for these parameters and aquifer depth for a number of sites in each hydrogeologic setting.
If HGDB data are used, the median value presented for each setting should be used unless site-specific
conditions indicate otherwise. Aquifer parameter values from these sources also can serve as a check of the
validity of site-measured values or estimates obtained from other sources.

If outside sources such as Aller et al.  (1987) are used to characterize site hydrogeologic conditions, the
appropriate references and diagrams should be attached to the CSM checklist.

Infiltration Rate. Infiltration rate is used to calculate SSLs for subsurface soils (see Step 5). The simplest
way to estimate  infiltration rate (I) is to assume that infiltration is equal to  recharge and obtain  recharge
estimates for the site's hydrogeologic setting from Aller et al. (1987). When using the Aller et al. (1987)
estimates the user should recognize that these are estimates of average recharge conditions throughout the
setting and site-specific values may differ to some extent. For example, areas within the setting with steeper
than average slopes will tend to have lower infiltration rates and areas with flatter than average slopes will
tend to have higher infiltration than average.  An alternative is to use infiltration rates determined for a
better-characterized site in the same hydrogeologic setting and with similar meteorological conditions as the
site in question.

A third alternative is use the HELP model. Although HELP was originally written for hydrologic evaluation
of landfills (Schroeder et al.,  1984), inputs to the HELP program can be modified to estimate infiltration in
undisturbed soils in natural settings. The most recent version of HELP and the most recent user's guide and
documentation can be obtained by sending an address and two double-sided, high-density, DOS-formatted
disks to:

        attn. Eunice Burk
        U.S. EPA
        5 995 Center Hill Ave.
        Cincinnati, OH  45224
        (513)569-7871.

Meteorologic Parameters. Select a site-specific Q/C value from in the guidance for the particulate
emission factor (PEF) equation to  place the site in a climatic zone (Figure A-l).
                                               A-2

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Several site-specific parameters are required to calculate a PEF if fugitive dusts are of concern at the site (see
Step 5 for surface soils). The threshold windspeed at 7 meters above ground surface (Ut 7) is calculated from
source area roughness height and the mode soil aggregate size as described in Cowherd et al. (1985). Mode
soil aggregate size refers to the mode diameter of aggregated soil particles measured under field conditions.

Other site-specific variables necessary for calculating the PEF include fraction vegetative cover (V) and the
mean annual windspeed (Um).  Fraction vegetative cover is estimated by visual observations of the surface
of known or suspected source areas at the site. Mean annual windspeed can be obtained from the National
Weather Service surface station nearest to the site.

Form 3. Exposure Pathways and Receptors

Form 3 includes information necessary to determine the applicability of the Soil Screening Guidance for
Radionuclides to a site (see Step 2 of the User's Guide).  This form summarizes the  site information
necessary to identify and characterize potential exposure pathways and receptors at the  site, such as site
conditions, relevant exposure scenarios, and the properties of soil contaminants listed on Form 4. Table A-l
provides an example of exposure pathways that are not addressed by the guidance, but have relevance to
CSM development.
  Table A-1. Example Identification of Radiological Exposure Pathways Not Addressed by SSLs
 Receptors/
 Exposure Pathways
Contaminant
Characteristics
Site Conditions
 Human / Direct Pathways
         inhalation - radon
         inhalation -volatile
         radionuclides
chronic health effects
chronic health effects
elevated levels of radium in soils
radionuclides bound chemically to
volatile organic compounds or "special
case" radionuclides (e.g., 3H, 14C,
222Rn)
 Human / Indirect Pathways
   consumption of meat or dairy
   products
   fish consumption
bioaccumulation,
biomagnification
biomagnification
nearby meat or dairy production

nearby surface waters with
recreational or subsistence fishing
 Ecological Pathways
   aquatic
   terrestrial
aquatic toxicity
toxicity to terrestrial organisms
(e.g., DDT, Hg)
nearby surface waters or wetlands
sensitive species on or near site
                                               A-3

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Figure A-l. U.S. climatic zones




             A-4

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Form 4. Soil Contaminant Source Characteristics

This form prompts the investigator to provide information on source characteristics, including soil contaminant levels
and the physical and chemical parameters of site soils needed to calculate SSLs. One form should be completed for
each contaminated soil source.  Initially, the form should be filled out to the greatest extent possible with existing
site information collected during CSM development (see Step 1 of the User's Guide).  The forms should be updated
after the SSL sampling effort is complete.

Measurement of contaminant levels and the soil parameters listed on this form is described in Step 3 of this guidance.

Average soil  moisture  content (6J defines the fraction of total soil porosity that is filled by water and air.
These parameters are necessary to apply the soil/water partition equation. It is important that the moisture content
used to calculate these  parameters represent the  annual average  soil  moisture  conditions.   Moisture content
measurements on discrete soil samples should not be used because they are affected by preceding rainfall events and
thus may not represent average conditions. Volumetric average soil water content may be estimated by the following
relationship developed by Clapp and Hornberger (1978) and presented in the Superfund Exposure Assessment Manual
(U.S. EPA, 1988):
where

        n  = total soil porosity (Lpore/Lsoll)
        I  = infiltration rate (m/yr)
       Ks  = saturated hydraulic conductivity (m/yr)
        b  = soil-specific exponential parameter (unitless).

Total soil porosity (n) is estimated from dry soil bulk density (pb) as follows:

                                             n = 1 - (Pb/Ps)
where

       ps  = soil particle density = 2.65 kg/L.

Site-specific values for infiltration rate (I) may be estimated using the HELP model or may be assumed to be
equivalent to recharge (see Form 2).

Values for Ks and the exponential term l/(2b+3) are shown in Table A-2 by soil texture class.  Soil texture class can
be determined using a particle size analysis and the U.S. Department of Agriculture (USDA) soil textural triangle
shown as Exhibit 9 in the User's Guide. The particle size analysis method described in Gee and Bauder (Gee, G.W.,
and J.W. Bauder, Particle size analysis, A. Clute (ed.), Methods of Soil Analysis. Part 1.  Physical andMineralogical
Methods.   2nd Edition, 9(1):383-411, American Society of Agronomy, Madison, WI, 1986)  can provide the
appropriate particle size distribution.  Other methods are appropriate as long as they provide the same particle
breakpoints for sand/silt (0.05 mm) and silt/clay (0.002 mm). Field methods are an alternative for determining soil
textural class.  Table A.3 Presents an example from Brady (Brady, N.C., The Nature  and Properties of Soils,
Macmillan Publishing Company, New York, NY, 1990).
                                                  A-5

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                  Table A-2. Parameter Estimates for Calculating Average Soil
                                      Moisture Content (6J
                          Soil texture
Ks(m/yr)
1/(2b+3)
Sand
Loamy sand
Sandy loam
Silt loam
Loam
Sandy clay loam
Silt clay loam
Clay loam
Sandy clay
Silt clay
Clay
1,830
540
230
120
60
40
13
20
10
8
5
0.090
0.085
0.080
0.074
0.073
0.058
0.054
0.050
0.042
0.042
0.039
                          Source: U.S. EPA, 1988.
       Table A.3 Criteria Used with the Field Method for Determining Soil Texture Classes
Criterion
Individual grains
visible to eye
Stability of dry clods
Stability of wet clods
Stability of "ribbon"
when wet soil rubbed
between thumb and
fingers
Sand
Yes
Do not form
Unstable
Does not
form

Sandy Loam
Yes
Do not form
Slightly
stable
Does not
form

Loam
Some
Easily
broken
Moderately
stable
Does not
form

Silt Loam
Few
Moderately
easily
broken
Stable
Broken
appearance

Clay Loam
No
Hard and
stable
Very stable
Thin, will
break

Clay
No
Very hard
and stable
Very stable
Very long,
flexible

 Source: Brady, 1990.

Worksheets

The worksheets following Forms 1 through 4 provide a convenient means of assembling radionuclide-specific
parameters necessary to calculate  SSLs for the contaminants of concern (Worksheet 1), existing site data on
contaminant concentrations collected during CSM development or the SSL sampling effort (Worksheet 2), and SSLs
calculated for EAs (Worksheet 3) or contaminant sources (Worksheet 4) of concern at the site.

CSM Diagram

The CSM diagram is a product of CSM development that represents the linkages among contaminant sources, release
mechanisms, exposure pathways and routes, and receptors to summarize the current understanding of the soil
contamination problem (see Step 1 of the guidance). An example SSL CSM diagram, Figure A-2 (U.S. EPA, 1989),
and a site sketch, Figure A-3 (U.S. EPA, 1987) are provided following the Worksheets.
                                               A-6

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                                           References

Aller, L., T. Bennett, J.H. Lehr, R.J. Petty, and G. Hackett. 1987. DRASTIC: A Standardized System for Evaluating
       Ground Water Pollution Potential Using Hydrogeologic Settings. Prepared for U.S. EPA Office of Research
       and Development, Ada, OK. National Water Well Association, Dublin, OH. EPA-600/2-87-035.

Brady, N.C. 1990. The Nature and Properties of Soils. Macmillan Publishing Company, New York, NY.

Clapp, R.B., and G.M. Hornberger. 1978. Empirical equations for some soil hydraulic properties. Water Resources
       Research, 14:601-604.

Cowherd,  C., G. Muleski,  P.  Engelhart, and D. Gillette. 1985.  Rapid Assessment of Exposure to Paniculate
       Emissions from Surface Contamination. Prepared for Office of Health and Environmental Assessment, U.S.
       EPA, Washington, DC. NTIS PB85-192219 7AS. EPA/600/8-85/002.

Gee, G.W., and J.W. Bauder, 1986. Particle size analysis. A. Klute (ed.). Methods of Soil Analysis, Parti, Physical
       and Mineralogical Methods, 2nd Edition, 9(1):383-411, American Society of Agronomy, Madison, WI.

Heath, RC. 1984. Ground-Water Regions of the United States. USGS Water Supply Paper 2242. U.S. Geological
       Survey, Reston, VA.

Newell, C.J., L.P. Hopkins, and P.B. Bedient. 1989. Hydrogeologic Database for Ground Water Modeling. API
       Publication No. 4476. American Petroleum Institute, Washington, DC.

Newell, C.J., L.P. Hopkins, and P.B. Bedient. 1990. A hydrogeologic database for ground water- modeling. Ground
       Water, 28(5):703-714.

Nielsen, D.M. (ed.). 1991. Practical Handbook of Ground-Water Monitoring. Lewis Publishers, Chelsea, MI.

Schroeder, P.R., A.C. Gibson, and M.D. Smolen. 1984. Hydrological Evaluation of Landfill Performance (HELP)
       Model; Volume 2: Documentation for Version 1. NTIS PB85-100832. Office of Research and Development,
       U.S. EPA, Cincinnati, OH. EPA/530-SW-84-010.

U.S. EPA.  1987.  Data Quality Objectives for Remedial Response Activities. Example Scenario: RI/FS Activities at
       a Site with Contaminated Soil and Groundwater.  Office of Emergency  and Remedial Response,
       Washington, DC. NTIS PB88-13188.

U.S. EPA 1988. Superfund Exposure Assessment Manual. OSWER Directive 9285.5-1. Office of Emergency and
       Remedial Response, Washington, DC. EPA/540/1-88/001. NTIS PB89-135859.

U.S. EPA.  1989. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA.
       EPA/540/G-89/004. OSWER  Directive  9355.3-01. Office of Emergency  and Remedial Response,
       Washington, DC. NTIS PB89-184626.

U.S. EPA.  1992. Guidance for Performing Site Inspections  Under CERCLA. EPA/540-R-92-0021. Office  of
       Emergency and Remedial Response, Washington, DC. NTIS PB92-963375.
                                                A-7

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                                Soil Screening Guidance for Radionuclides
                                 Conceptual Site Model Summary Forms
Form 1: General Site Information                Site Name  	
EPA Region  	Date	
Contractor Name and Address:  	
State Contact:
1.   CERCLIS ID No	
    Address	City	
    County	State  	  Zip Code	         Congressional District
2.   Owner Name	Operator Name  	
    Owner Address 	Operator Address  	
    City  	State	City	State
3.   Type of ownership (check all that apply):
    D Private   D Federal Agency	D State         D County       D Municipal
    Other	Ref	
4.   Approximate size of property	  acres                   Ref.

5.   Latitude	° •  • I	"   Longitude  .... o ... |	"  Ref.
6.   Site status  D Active    D Inactive     D Unknown                   Ref.

7.   Years of operation    From  	  To 	     D Unknown    Ref.

8.   Previous investigations
        Type               Agency/State/Contractor          Date
	    Ref.
	    Ref.
	    Ref.
	    Ref.
	    Ref.
	    Ref.
Ref. = reference(s) on information source

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                                 Soil Screening Guidance for Radionuclides
                                   Conceptual Site Model Summary Forms
Form 2: Site Characteristics                                  Site Name	
Hydroqeoloqic Characteristics (migration to ground water pathway)
Is ground water of concern at the site?  Dyes  D no (if no,  move to Infiltration Rate below).
Heath region 	  Hydrogeologic setting 	
(attach setting diagram)
Check setting characteristics that apply:  D  karst  D  fractured rock            D solution limestone
Describe the stratigraphy and hydrogeologic characteristics of the site. (Attach available maps and cross-sections.




Ref	
Identify and describe nearby sites in similar settings that have already been characterized.




Ref	
    Aquifer Parameters      Unit    Typical    Min.    Max.              Reference or Source
 hydraulic conductivity (K)     m/y
 hydraulic gradient (i)         m/m
 thickness (da)               m

General direction of ground water flow across the site (e.g., NNE, SW):  	
(attach map.) Ref	

Infiltration rate (I)  	  m/yr          Method	

Meteorological Characteristics (inhalation pathway)
climatological zone:  	  (zone#, city)   Q/C  	  (g/m2-s per kg/m3
fract. vegetative cover (V)	  (unitless)      Reference  	
mean annual windspeed (Um)	  m/s           Reference  	
equivalent threshold value of windspeed at 7 m (Ut)  	m/s
fraction dependent on Um/U,	(unitless)
Comments:	
                                                      A-9

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                                 Soil Screening Guidance for Radionuclides
                                   Conceptual Site Model Summary Forms
Form 3: Exposure Pathways and Receptors
Land Use Conditions
                Site Name
Current site use:
	residential
	industrial
	commercial
	agricultural
	recreational
   other
Surrounding land use:
	residential
	industrial
	commercial
	agricultural
	recreational
   other
Future land use:
	residential
	industrial
	commercial
	agricultural
	recreational
   other
Size of exposure areas (in acres)	
Contaminant Release Mechanisms (check all that apply):
Source #	D leaching   D volatilization  D fugitive dusts   D erosion/runoff  D uptake by plants  D direct exposure
Source #	D leaching   D volatilization  D fugitive dusts   D erosion/runoff  D uptake by plants  D direct exposure
Source #	D leaching   D volatilization  D fugitive dusts   D erosion/runoff  D uptake by plants  D direct exposure
(describe rationale for not including any of the above release mechanisms)
Media affected (or potentially affected) by soil contamination.
Source #	D air     D ground water   D surface water   D sediments  D wetlands   Dsubsurface
Source #	D air     D ground water   D surface water   D sediments  D wetlands   Dsubsurface
Source #	D air     D ground water   D surface water   D sediments  D wetlands   Dsubsurface

Check if present on-site or on surrounding land (attach map showing locations)
D wetlands D surface water D subsistence fishing D recreational fishing D dairy/beef production D elevated indoor radon

Check SSL exposure pathways applicable at site; describe basis for not including any pathway
D ingestion of soil D inhalation D migration to ground water D  produce ingestion
D external exposure

Check if there is a potential for:
D Acute Effects (describe)
D Other Human Exposure Pathways (describe)
D Ecological concerns (describe)
D Small areas of elevated activity (describe)
                                                     A-10

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                                Soil Screening Guidance for Radionuclides
                                  Conceptual Site Model Summary Forms
Form 4: Soil Contaminant Source Characteristics                 Site Name  	
Source No.:  	
Name:  	(e.g., drum storage area)
Type:	(e.g., spill, dump, wood treater)
Location:	(site map)
Waste type:	(e.g., solvents, waste oil, tailings)
Description (describe history of contamination, other information)
Describe past/current remedial or removal actions
Source depth:	m (D measures D estimated)    Ref	
Source area:	  acres	m2 (D  measures D estimated)   Ref	
Source length parallel to ground water flow:   	  m (if uncertain, use longest source dimension)
Contaminant types (check all that apply):  D volatile organics  D other organics D metals D other inorganics
                                     D radionuclides
Soil Contaminants Present (list):	
(attach Worksheet #1)
Describe previous soil analyses, (attach available results and map showing sample locations)
(attach Worksheet #2)
Are NAPLs suspected?  D Yes  D No  Reason

Average Soil Characteristics
average water content (6J	(L wate/Lsoil)     Ref.
dry bulk density (pb)  	(kg/L)         Ref.
pH	                                                   Ref.
                                                     A-ll

-------
Worksheet 1. Contaminant-specific properties

Regulatory and Human Health Benchmarks1
Site Name
Radionuclide






CASRN






MCL
(pCi/L)






Slope factors
Ingestion
- soil
(pCi)-1






Inhalation
(pCi)-1






Ingestion
- water
(pCi)-1






External
exposure
(kg/pCi-s)






Ingestion
- produce
(pCi)-1






Chemical Properties2
Contaminant







CAS#







Sources
(no.)







Koc3
(L/kg)







Kd4
(L/kg)







H5







Dia5
(cm2/s)







D 5
^IW
(cm2/s)







S5
(mg/L)







    1. Attachment D
    2. Attachment C
    3. For organic compounds
    4. For metals and inorganic compounds
    5. Not applicable to metals except mercury
                                                       A-12

-------
Worksheet 2. Contaminant concentrations by source




Source #
Site Name

Contaminant













CAS#













average













standard
deviation













number of
samples













minimum













maximum













variance












Source #

Contaminant













CAS#













average













standard
deviation













number of
samples













minimum













maximum













variance












                                                 A-13

-------
Worksheet 3. Surface SSLs by Exposure Area (EA)




EA #: 	    SSL type:     n site-specific
       Site Name	




u generic (default)     u detailed approach
Radionuclide






CASRN






Soil Screening Level (pCi/g)
Ingestion -
soil






Inhalation






Ingestion -
water






External
exposure






Ingestion -
produce






EA #: 	 SSL type:    D site-specific   D generic (default)   Ddetailed approach
Radionuclide







CASRN







Soil Screening Level (pCi/g)
Ingestion -
soil







Inhalation







Ingestion -
water







External
exposure







Ingestion -
produce







                                                   A-14

-------
Worksheet 4. Subsurface SSLs by source               Site Name  	




Source #:	SSL type:     D site-specific   D generic (default)     Ddetailed approach
Radionuclide









CASRN









Soil Screening Level (pCi/g)
migration to ground water









Source #:
SSL type: D site-specific  D  generic (default)    Ddetailed approach
Radionuclide









CASRN









Soil Screening Level (pCi/g)
migration to ground water









                                                 A-15

-------

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                 WOODED ARIA
                                          GEOLOGIC CROSS SECTION
                                                    WOODED AREA
                               FILL MATERIAL
               DEPRESSION
(DIRECT CONTACT^
                     '. {GROUND WATER)
                     \CUSTRINE
               "GLACIAL TILL
                BEDROCK
POTENTIAL
CONTAMINANT
MIGRATION
PATHWAY
                                         SITE CROSS SECTION
        Figure A-3. Example Site Sketch (adapted from U.S. EPA, 1987)
                              A-17

-------
                    Attachment B




Soil Screening DQOs for Surface Soils and Subsurface Soils

-------
                                                  Table B.1
                        Soil Screening DQOs for Surface Soils Using the Max Test
         DQO Process Steps
                       Soil Screening Inputs/Outputs
State the Problem
Identify scoping team

Develop conceptual site model (CSM)
Define exposure scenarios

Specify available resources
Write brief summary of contamination
  problem
Site manager and technical experts (e.g., health physicists, risk assessors,
  statisticians)
CSM development (described in Step 1)
Direct ingestion of soil, inhalation of fugitive dusts, external radiation exposure, and
  ingestion of homegrown produce in a residential setting;
Sampling and analysis budget, scheduling constraints, and available personnel
Summary of the surface soil contamination problem to be investigated at the site
Identify the Decision
Identify decision

Identify alternative actions
Do mean soil concentrations for particular radionuclides (e.g., radionuclides of
  potential concern) exceed appropriate screening levels?
Eliminate area from further study under CERCLA
or
Plan and conduct further investigation
Identify Inputs to the Decision
Identify inputs

Define basis for screening
Identify analytical methods
 SSLs for each pathway for specified radionuclides
Measurements of surface soil radionuclide concentration
Soil Screening Guidance for Radionuclides
Feasible analytical methods (both field and laboratory) consistent with program-
  level requirements
Define the Study Boundaries
Define geographic areas of field
  investigation
Define population of interest
Divide site into strata

Define scale of decision making
Define temporal boundaries of study
Identify practical constraints
The entire NPL site, (which may include areas beyond facility boundaries), except
  for any areas with clear evidence that no contamination has occurred
Surface soils (usually the top 15 centimeters )
Strata may be defined so that radionuclide concentrations are likely to be relatively
  homogeneous within each stratum based  on the CSM and field measurements
Exposure areas (EAs) no larger than 0.5 acre each (based on residential land use)
Temporal constraints  on scheduling field visits
Potential impediments to sample collection,  such as access, health, and safety
  issues
Develop a Decision Rule
Specify parameter of interest
Specify screening level

Specify "if..., then..." decision rule
"True mean" (u) individual radionuclide concentration in each EA. However, since
  the determination of the "true mean" would require the collection and analysis of
  many samples, another sample statistic, the maximum composite concentration,
  or "Max Test" is used.
Screening levels calculated using available parameters and site data (or generic
  SSLs if site data are unavailable)
Ideally, if the "true mean" EA concentration exceeds the screening level, then
  investigate the EA further. If the "true mean" is less than the screening level,
  then no further investigation  of the EA is required under CERCLA.
                                                     B-l

-------
                                                  Table B.1
                  Soil Screening DQOs for Surface Soils Using the Max Test (continued)
         DQO Process Steps
                    Soil Screening Inputs/Outputs
Specify Limits on Decision Errors*

 Define baseline condition (null
  hypothesis)

 Define the gray region**

 Define Type I and Type II decision errors
 Identify consequences
Assign acceptable probabilities of Type I
  and Type II decision errors
 Define QA/QC goals
The EA needs further investigation


From 0.5 SSL to 2 SSL

Type I error: Do not investigate further ("walk away from") an EA whose "true
  mean" exceeds the screening level of 2 SSL

Type II error: Investigate further when an EA "true mean" falls below the
screening level of 0.5 SSL

Type I error: potential public health consequences

Type II error: unnecessary expenditure of resources to investigate further

Goals:

Type I: 0.05 (5%) probability of not investigating further when "true mean" of
the EA is 2 SSL

Type II: 0.20 (20%) probability of investigating further when "true mean" of the
EA is 0.5 SSL

Analytical laboratory precision and bias requirements
10% laboratory analyses for field methods
Optimize the Design

Determine how to best estimate "true
mean"
Determine expected variability of EA
surface soil radionuclide concentrations
Design sampling strategy by evaluating
costs and performance of alternatives
Samples composited across the EA as physical estimates of EA mean (x).
 Use maximum composite concentration as a conservative estimate of the true
 EA mean.

A conservatively large expected coefficient of variation (CV) from prior data for
 the site, field measurements,  or data from other comparable sites and expert
 judgment. A minimum default CV of 2.5 should be used when information is
 insufficient to estimate the CV.

Lowest cost sampling design option (i.e., compositing scheme and number of
 composites) that will achieve  acceptable decision error rates
Develop planning documents for the field
investigation
Sampling and Analysis Plan (SAP)
Quality Assurance Project Plan (QAPP)
    Since the DQO process controls the degree to which uncertainty in data affects the outcome of decisions that are
    based on that data, specifying limits on decision errors will allow the decision maker to control the probability of
    making an incorrect decision when using the DQOs.

    The gray region represents the area where the consequences of decision errors are minor, (and uncertainty in
    sampling data  makes decisions too close to call).
                                                     B-2

-------
                                                  Table B.2
                                Soil Screening DQOs for Subsurface Soils
 DQO Process Steps
                     Soil Screening Inputs/Outputs
State the Problem
Identify scoping team

Develop conceptual site model (CSM)
Define exposure scenarios
Specify available resources

Write brief summary of contamination
  problem
Site manager and technical experts (e.g., health physicists, risk assessors,
  hydrogeologists, statisticians).
CSM development (described in Step 1).
Migration of radionuclides from soil to potable ground water.
Sampling and analysis budget, scheduling constraints, and available
  personnel.
Summary of the subsurface soil contamination problem to be investigated at
  the site.
Identify the Decision
Identify decision

Identify alternative actions
Do mean soil concentrations for particular radionuclides (e.g., radionuclides
  of potential concern) exceed appropriate SSLs?
Eliminate area from further action or study under CERCLA
or
Plan and conduct further investigation.
Identify Inputs to the Decision
Identify decision

Define basis for screening
Identify analytical methods
Migration to ground water SSLs for specified radionuclides
Measurements of subsurface soil radionuclide concentration
Soil Screening Guidance for Radionuclides
Feasible analytical methods (both field and laboratory) consistent with
  program-level requirements.
Specify the Study Boundaries
Define geographic areas of field
  investigation
Define population of interest
Define scale of decision making

Subdivide site  into decision units

Define temporal boundaries of study
Identify (list) practical constraints
The entire NPL site (which may include areas beyond facility boundaries),
  except for any areas with clear evidence that no contamination has
  occurred.
Subsurface soils
Sources (areas of contiguous soil contamination, defined by the area and
  depth of contamination or to the water table, whichever is more shallow).
Individual sources delineated (area and depth) using existing information or
  field measurements (several  nearby sources may be combined into a single
  source).
Temporal constraints on scheduling field visits.
Potential impediments to sample collection, such as access, health, and
  safety issues.
                                                      B-3

-------
                                                 Table B.2
                         Soil Screening DQOs for Subsurface Soils(continued)
Develop a Decision Rule

Specify parameter of interest


Specify screening level


Specify "if..., then..." decision rule
Mean soil radionuclide concentration in a source (i.e., discrete radionuclide
  concentrations averaged within each boring).

SSLs calculated using available parameters and site data (or generic SSLs if
  site data are unavailable).

If the mean soil concentration exceeds the SSL, then investigate the source
  further. If mean soil concentration in a source is less than the SSL, then no
  further investigation is required under CERCLA.
Specify Limits on Decision Errors

Define QA/QC goals
Analytical laboratory precision and bias requirements
10% laboratory analyses for field methods
Optimize the Design

Determine how to estimate mean
  concentration in a source

Define subsurface sampling strategy by
  evaluating costs and site-specific
  conditions

Develop planning documents for the field
  investigation
For each source, the highest mean soil boring concentration (i.e., depth-
  weighted average of discrete radionuclide concentrations within a boring).

Number of soil borings per source area; number of sampling intervals with
  depth.


Sampling and Analysis Plan (SAP)
Quality Assurance Project Plan (QAPP)
                                                     B-4

-------
              Attachment C




Radiological Properties for SSL Development

-------
                                       Attachment C

                     Radiological Properties for SSL Development


C.1  Radionuclides Included in Generic Soil Screening Analysis

Principal radionuclides are radionuclides with half-lives greater than six months. The decay products of any
principal radionuclide down to, but not including, the next principal radionuclide in its decay chain are called
associated radionuclides and consist of radionuclides with half-lives less than six months. It is assumed that
a principal radionuclide is in secular equilibrium with its associated radionuclides at the point of exposure.
This assumption is reasonable because it usually takes  about  three years or longer to clean up a site.
Principal and associated radionuclides for which generic Soil Screening Levels have been calculated are
listed in Table C.I. Associated decay chains are indicated, as well as principal radionuclide half-life and the
terminal nuclide or radionuclide (i.e., the principal radionuclide or stable nuclide that terminates an
associated decay chain).
                                             C-l

-------
     Table C.1 Radionuclides Included in Generic Soil Screening Analysis
Principal Radionuclide3
Nuclide
Ac-227+D
Ag-108m
Ag-110m
Am-241
Am-243+D
Bi-207
C-14
Cd-109
Ce-144+D
CI-36
Cm-243
Cm-244
Co-57
Co-60
Cs-134
Cs-135
Cs-137+D
Eu-152
Eu-154
Eu-155
Fe-55
Gd-153
H-3
1-129
K-40
Half-life (yr)
22
127
0.7
432
7400
38
5730
1.3
0.8
300000
28
18
0.7
5
2
3000000
30
13
8
5
3
0.7
12
16000000
1300000000
Associated Decay Chainb
[Th-227 (98.6%, 19 d)
Fr-223(1.4%, 22 min)]
Ra-223(11 d)
Rn-219(4s)
Po-215(2ms)
Pb-211 (36 min)
Bi-211 (2 min)
[TI-207 (99.7%, 5 min)
Po-211 (0.3%, 0.5s)]


-
Np-239 (2 d)
-
-
-
[Pr-244(9%, 17 min)
Pr-244m (2%, 7 min)]
-
-
-
-
-
-
-
Ba-137m(95%, 3 min)
-
-
-
-
-
-
-
-
Terminal Nuclide or
Radionuclidec
Nuclide
Pb-207
Pd-108(91%)
[Cd-108(98%}
Ag-108(9%)
Pd-108(2%)]
Cs-110(99%)
[Cd-11 0(99.7%)
Ag-110(1%)
Pd-110(0.3%)]
Np-237
Pu-239
Pb-207
N-14
Ag-109
Nd-144
S-36
Am-243 (0.2%)e
Pu-240
Fe-57
Ni-60
Ba-134(~100%)
Ba-135
Ba-137
Sm-152(72%)
Gd-152(28%)
Gd-154(~100%)
Gd-155
Mn-55
Eu-153
He-3
Xe-129
Ca-40 (89%)
Ar-40(11%)
Half-life (yr)
stable
stable
stable
2 min
stable
stable
stable
25s
stable
21000001
24000
stable
stable
stable
stable
stable
7400
6600
stable
stable
stable
stable
stable
stable
1.1E+14
stable
stable
stable
stable
stable
stable
stable
Note:2.1E+6 = 2.1xlO+'
                                    C-2

-------
Table C.1  Radionuclides Included in Generic Soil Screening Analysis
Principal Radionuclide3
Nuclide
Mn-54
Na-22
Nb-94
Ni-59
Ni-63
Np-237+D
Pa-231
Pb-210+D
Pm-147
Pu-238
Pu-239
Pu-240
Pu-241
Pu-242
Pu-244+D
Ra-226+D
Ra-228+D
Ru-106+D
Sb-125+D
Sm-147
Sm-151
Sr-90+D
Tc-99
Th-228+D
Th-229+D
Th-230
Half-life (yr)
0.9
3
20000
75000
100
2100000
33000
22
3
88
24000
6500
14
380000
93000000
1600
8
1
3
110000000000
90
29
210000
2
7300
77000
Associated Decay Chainb
-
-
-
-
-
Pa-233 (27 d)
-
Bi-210(5d)
Po-210(138d)
-
-
-
-
-
-
U-240-100%, 14)
Np-240
Rn-222 (4 d)
Po-218(3min)
Pb-214(~100%, 27min)
Bi-214(20min)
Po-214(~100%, 1 min)
Ac-228 (6 h)
Rh-106(30s)
Te-125m(23%, 58 d)
-
-
Y-90 (64 h)
-
Ra-224 (4 d)
Rn-220 (56 s)
Po-216(0.2s)
Pb-212(11h)
Bi-212(61 min)
[Po-212(64%, 0.3 |js)
TI-208 (36%, 3 min)]
Ra-225(15d)
Ac-225(10d)
Fr-221 (5 min)
At-217(32ms)
Bi-213(46min)
[Po-213(98%, 4 |js)
TI-209 (2%, 2 min)]
Pd-209 (3 h)
-
Terminal Nuclide or
Radionuclidec
Nuclide
Cr-54
Ne-22
Mo-94
Co-59
Cu-53
U-233
Ac-227
Pb-206
Sm-147
U-234
U-235
U-236
Am-241
U-238
Pu-240
Pb-210
Th-228
Pd-106
Te-125
Nd-143
Eu-151
Zr-90
Ru-99
Pb-208
Bi-209
Ra-226
Half-life (yr)
stable
stable
stable
stable
stable
160000
22
stable
1.10000e+11
240000
700000000
2300000
432 y
4500000000
6500
22
2
stable
stable
stable
stable
stable
stable
stable
stable
1600
                             C-3

-------
          Table C.1   Radionuclides Included in Generic Soil Screening Analysis
Principal Radionuclide3
Nuclide
Th-232
TI-204
U-232
U-233
U-234
U-235+D
U-236
U-238+D
Zn-65
Half-life (yr)
14000000000
4
72
160000
240000
700000000
2300000
4500000000
0.7
Associated Decay Chainb
-
-
-
-
-
Th-231 (26 h)
-
Th-234 (24 d)
[Pa-234m (99.8%, 1 min)
Pa-234 (0.2%, 7 h)]
-
Terminal Nuclide or
Radionuclidec
Nuclide
Ra-228
Pb-204 (97%)
Hg-204 (3%)
Th-228
Th-229
Th-230
Pa-231
Th-232
U-234
Cu-65
Half-life (yr)
6
stable
stable
2
7300
80000
34000
14000000000
240000
stable
Radionuclides with half-lives greater than six months.  "+D" designates principal radionuclides with associated decay chains.
The chain of decay products of a principal radionuclide extending to (but not including) the next principal radionuclide or a stable nuclide. Half-
lives are given in parentheses. Branches are indicated by square brackets with branching ratios in parentheses.
The principal radionuclide or stable nuclide that terminates an associated decay chain.
A hyphen indicates that there are no associated decay products.
The branching decay for Pu-241 and Cm-243 involves multiple principal radionuclides and associated radionuclides.
                                                    C-4

-------
C.2 Soil-water Partition Coefficients for Radionuclides

As with organic chemicals, development of SSLs for inorganics (including radionuclides) requires a soil-
water partition coefficient (Kd) for each constituent. However, the simple relationship between soil organic
carbon content and sorption observed for organic chemicals does not apply to inorganics (including
radionuclides).  The soil-water distribution coefficient (Kd)  for inorganics (including radionuclides) is
affected by numerous geochemical parameters and processes, including pH; sorption to clays, organic matter,
iron oxides, and other soil constituents; oxidation/reduction conditions; major  ion chemistry;  and  the
chemical form of the radionuclide. The number of significant influencing parameters, their variability in the
field, and differences in experimental methods result in as much as seven orders of magnitude variability in
measured metal Kd values reported in the literature (see Table 43 in the Soil Screening Guidance: Technical
Background Document (EPA 1996b)). This variability makes it much more difficult to derive generic Kd
values for metals (including radionuclides) than for organics.  Therefore, it is recommended that Kd values
be measured for site-specific conditions. If the Kd is not measured site-specifically, then a conservative Kd
should be used in calculating SSLs.

Tables C.2a and C.2b list the default Kd values for each element. Table C.2a is derived from the EPA Office
of Radiation and Indoor Air's 1999 "Understanding Variation In Partition Coefficient, Kd, Values, Volume
1: The Kd Model of Measurement, And Application Of Chemical Reaction Codes, & Volume 2: Review Of
Geochemistry And Available  Kd Values  For  Cadmium, Cesium, Chromium, Lead , Plutonium, Radon,
Strontium, Thorium, Tritium, And Uranium". The Kd values in Table C.2a are the most conservative values
provided for each element in (EPA 1999).  Each of these values are based on the chemical behavior that was
considered to provide the most conservative Kd value for that element. Users that have measured pH values
at their site that differ from the range given in this report, may want to consult Tables 5.4 to 5.9 in the TBD
for alternative Kds that are still conservative.

The Kd values in Table C.2b are the most conservative values provided by Sheppard and Thibault (Sheppard,
1990) for the remaining elements not addressed in (EPA 1999), that are not based on soil-to-plant transfer.
EPA recommends that Kds based on soil-to-plant uptake data should not be used when estimating migration
of contaminants from soil to groundwater.

When estimating migration of contaminants  from soil to groundwater for a contaminant which is  not
represented with a default Kd value in either Table C.2a and C.2b, site decision-makers should develop a site-
specific Kd.  Site decision-makers  also  may measure  a  site-specific  Kds to more accurately estimate
contaminant migration rather than using the default values in either Tables C.2a or C.2b or Tables 5.4 to 5.9
in the TBD.
                                              C-5

-------
                     Table C.2a Default KH Values for Selected Elements
Element
Cs
H
Pu
Rn
Kd value
10
0
5
0
Element
Sr
Th
U

Kd value
1
20
0.4

                Source: EPA, 1999
          Table C.2b  Sheppard and Thibault's Default Kd Values for Selected Elements
Element
Ac
Ag
Am
Bi
C
Cd
Ce
Cl
Cm
Co
Kd value
NDA
2.7
8.2
NDA
0.8
2.7
35
NDA
86
0.1
Element
Eu
Fe
Gd
I
K
Mn
Na
Nb
Ni
Np
Kd value
NDA
3.1
NDA
0.03
NDA
4.9
NDA
NDA
34
0.1
Element
Pa
Pb
Pm
Ra
Ru
Sb
Sm
Tc
Tl
Zn
Kd value
NDA
6
NDA
3
5
NDA
NDA
0.007
NDA
0.1
Source:   Sheppard, 1990

NDA:     No Default Kd Available. A Kd for this element must be developed on a site-specific basis to
         evaluate the potential for fate and transport of this contaminant from the soil to groundwater.
                                            C-6

-------
C.3    Soil-to-Plant Transfer Factors

The soil-to-plant transfer factor is defined as the ratio of the concentration of the principal radionuclide in
plant in pCi/g to the concentration of the radionuclide in soil in pCi/g. This factor is also known as the plant
root uptake factor. The soil-to-plant or soil-to-vegetation transfer factor, for a given type of plant and for
a given radionuclide can vary considerably from site to site with season and time after contamination.  These
variations depend on such factors  as the  physical  and chemical properties of the soil,  environmental
conditions, and chemical form of the radionuclide in the soil. Furthermore, soil management practices such
as ploughing, liming, fertilizing and irrigation can also effect the uptake of radionuclides by vegetation.
Readers are referred to  the  TBD  for a  discussion of the  variability of this  parameter.   This is  a
chemical/radionuclide specific parameter.  The default values for different radionuclides are presented in
Table C.3.
                                               C-7

-------
                       Table C.3 Default Soil-to-Plant Transfer Factors
Elem
H
Be
C
N
F
Na
Al
P
S
Cl
Ar
K
Ca
Sc
Cr
Mn
Fe
Co
Ni
TFP
4.8
0.004
5.5
7.5
0.02
0.05
0.004
1
0.6
20
0
0.3
0.5
0.002
0
0.3
0.001
0.08
0.05
Elem
Cu
Zn
Ge
As
Se
Br
Kr
Rb
Sr
Y
Zr
Nb
Mo
Tc
Ru
Rh
Pd
Ag
Cd
TFP
0.13
0.4
0.4
0.08
0.1
0.76
0
0.13
0.3
0.0025
0.001
0.01
0.13
5
0.03
0.13
0.1
0.15
0.3
Elem
In
Sn
Sb
Te
I
Xe
Cs
Ba
La
Ce
Pr
Nd
Pm
Sm
Eu
Gd
Tb
Ho
Ta
TFP
0.003
0.0025
0.01
0.6
0.02
0
0.04
0.005
0.0025
0.002
0.0025
0.0024
0.0025
0.0025
0.0025
0.0025
0.0026
0.0026
0.02
Elem
W
Ir
Au
Hg
Tl
Pb
Bi
Po
Rn
Ra
Ac
Th
Pa
U
Np
Pu
Am
Cm
Cf
TFP
0.018
0.03
0.1
0.38
0.2
0.01
0.1
0.001
0
0.04
0.0025
0.001
0.01
0.0025
0.02
0.001
0.001
0.001
0.001
Source:   ANL, 1993.
                                             C-8

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             Attachment D

Regulatory and Human Health Benchmarks
  Used for Radionuclide SSL Development

-------
                                            Attachment D

                          Regulatory and Human  Health Benchmarks
                            Used for Radionuclide SSL Development
D.1    Current Radionuclide Slope Factors

The slope factors listed in Table D. 1 are taken from the Health Effects Assessment Summary Tables (HEAST) which
may be found on the internet at the following address: http://www.epa.gov/superfund/programs/risk/calctool.htm.
The slope factors are derived primarily fmmtfealth RisksfromLow-Level Environmental Exposure to Radionuclides,
Federal Guidance Report No. 13, Parti - ,  U.S. EPA, 1999 (also known as FGR13).  Table D.I lists cancer slope
factors for each route of intake for principal radionuclides in units of picocuries (pCi).1  Radionuclides are presented
alphabetically by element.

Selected radionuclides and radioactive decay chain products are designated with the suffix "+D" (e.g., U-238+D, Ra-
226+D, Cs-137+D) to indicate that cancer risk estimates for these radionuclides include the contributions from their
short-lived decay products, assuming equal activity concentrations (i.e., secular equilibrium) with the principal or
parent nuclide  in the environment. Decay chains are identified in Attachment C, Table C. 1.

In most cases, site-specific analytical data should be used to establish the actual degree of equilibrium between each
parent radionuclide and its decay products in each media sampled.  However, in the absence of empirical data, the
"+D"  values for radionuclides should be used unless there are compelling reasons not to.

Note that there may be circumstances, such as long disposal times or technologically enhanced concentrations of
naturally occurring radionuclides, that may  necessitate the combination of the risks of a parent radionuclide and its
decay products over several contiguous subchains. For example, Ra-226 soil analyses at a site might show that all
radium decay  products  are present in secular equilibrium down to stable Pb-206.  In this  case, Ra-226 risk
calculations should be based on  the ingestion, inhalation and external exposure slope factors for the  Ra-226+D
subchain, plus the ingestion, inhalation and external exposure factors for the Pb-210+D subchain.  For actual sites,
users  should consult with a health physicist or radiochemist (1) to evaluate the site-specific analytical  data to
determine the degree of equilibrium between parent radionuclides and decay members of contiguous  decay chains
and (2) to assist in the combination of appropriate slope factor values.
           1 Slope factors are reported in the customary units of picocuries (1 pCi = 10"12 curies (Ci) = 3.7xlO"2 nuclear
    transformations per second) for consistency with the system used for radionuclides in the IRIS database. If required,
    slope factors in Table 4 can be converted into the International System (SI) units of becquerels (1 Bq = 1 nuclear
    transformation per second) by multiplying each inhalation, ingestion, or external exposure value by 27.03. Users can
    calculate cancer risks using slope factors expressed in either customary units or SI units with equivalent results, provided
    that they also use air, water and soil concentration values in the same system of units.

                                                  D-l

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Table D.1  Radionuclide Cancer Morbidity - Slope Factors (1)
Radionuclide
Ac-227+D
Ag-108m+D
Ag-110m+D
Am-241
Am-243+D
Bi-207
C-14
Cd-109
Ce-144+D
CI-36
Cm-243
Cm-244
Co-57
Co-60
Cs-134
Cs-135
Cs-137+D
Eu-152
Eu-154
Eu-155
Fe-55
Gd-153
H-3
1-129
K-40
Mn-54
Na-22
Nb-94
Ni-59
Ni-63
Np-237+D
Pa-231
Pb-210+D
Pm-147
Pu-238
Pu-239
Pu-240
Pu-241
Pu-242
Pu-244+D
Ra-226+D
Ra-228+D
Ru-106+D
Sb-125+D
Sm-147
Sm-151
Sr-90+D
Tc-99
Th-228+D
Th-229+D
Th-230
Th-232
TI-204
U-232
U-233
U-234
U-235+D
U-236
U-238+D
Slope Factor (Morbidity Risk Coefficient)
Lifetime Excess Cancer Risk per Unit Exposure
Water
Ingestion
(risk/pCi)
4.86E-10
8.14E-12
9.88E-12
1.04E-10
1.08E-10
5.66E-12
1.55E-12
5.00E-12
3.53E-11
3.30E-12
9.47E-11
8.36E-11
1.04E-12
1.57E-11
4.22E-11
4.74E-12
3.04E-11
6.07E-12
1.03E-11
1.90E-12
8.62E-13
1.52E-12
5.07E-14
1.48E-10
2.47E-11
2.28E-12
9.62E-12
7.77E-12
2.74E-13
6.70E-13
6.74E-11
1.73E-10
1.27E-09
1.69E-12
1.31E-10
1.35E-10
1.35E-10
1.76E-12
1.28E-10
1.44E-10
3.86E-10
1.04E-09
4.22E-11
5.13E-12
3.74E-11
5.55E-13
7.40E-11
2.75E-12
3.00E-10
5.28E-10
9.10E-11
1.01E-10
5.85E-12
2.92E-10
7.18E-11
7.07E-11
7.18E-11
6.70E-11
8.71E-11
Food
Ingestion
(risk/pCi)
6.53E-10
1.12E-11
1.37E-11
1.34E-10
1.42E-10
8.14E-12
2.00E-12
6.70E-12
5.19E-11
4.44E-12
1.23E-10
1.08E-10
1.49E-12
2.23E-11
5.14E-11
5.88E-12
3.74E-11
8.70E-12
1.49E-11
2.77E-12
1.16E-12
2.22E-12
6.51E-14
3.22E-10
3.43E-11
3.11E-12
1.26E-11
1.11E-11
3.89E-13
9.51E-13
9.10E-11
2.26E-10
3.44E-09
2.48E-12
1.69E-10
1.74E-10
1.74E-10
2.28E-12
1.65E-10
1.90E-10
5.15E-10
1.43E-09
6.11E-11
7.21E-12
4.77E-11
8.07E-13
9.53E-11
4.00E-12
4.22E-10
7.16E-10
1.19E-10
1.33E-10
8.25E-12
3.85E-10
9.69E-11
9.55E-11
9.76E-11
9.03E-11
1.21E-10
Soil
Ingestion
(risk/pCi)
1.16E-09
1.92E-11
2.37E-11
2.17E-10
2.32E-10
1.49E-11
2.79E-12
1.14E-11
1.02E-10
7.66E-12
2.05E-10
1.81E-10
2.78E-12
4.03E-11
5.81E-11
7.18E-12
4.33E-11
1.62E-11
2.85E-11
5.40E-12
2.09E-12
4.26E-12
9.25E-14
2.71E-10
6.18E-11
5.14E-12
1.97E-11
2.05E-11
7.33E-13
1.79E-12
1.62E-10
3.74E-10
2.66E-09
4.88E-12
2.72E-10
2.76E-10
2.77E-10
3.29E-12
2.63E-10
3.14E-10
7.30E-10
2.29E-09
1.19E-10
1.32E-11
7.59E-11
1.59E-12
1.44E-10
7.66E-12
8.09E-10
1.29E-09
2.02E-10
2.31E-10
1.54E-11
5.74E-10
1.60E-10
1.58E-10
1.63E-11
1.49E-10
2.10E-10
Inhalation
(risk/pCi)
2.09E-07
2.67E-11
2.83E-11
2.81 E-08
2.70E-08
2.10E-11
7.07E-12
2.19E-11
1.10E-10
2.50E-11
2.69E-08
2.53E-08
2.09E-12
3.58E-11
1.65E-11
1.86E-12
1.19E-11
9.10E-11
1.15E-10
1.48E-11
7.99E-13
6.55E-12
5.62E-14
6.07E-11
1.03E-11
5.88E-12
3.89E-12
3.77E-11
4.66E-13
1.64E-12
1.77E-08
4.55E-08
1.39E-08
1.61E-11
3.36E-08
3.33E-08
3.33E-08
3.34E-10
3.13E-08
2.93E-08
1.16E-08
5.23E-09
1.02E-10
1.93E-11
6.88E-09
4.88E-12
1.13E-10
1.41E-11
1.43E-07
2.25E-07
2.85E-08
4.33E-08
2.45E-12
1.95E-08
1.16E-08
1.14E-08
1.01 E-08
1.05E-08
9.35E-09
External Exposure
(risk/yr per
PCi/g soil)
1.47E-06
7.19E-06
1.30E-05
2.76E-08
6.36E-07
7.08E-06
7.83E-12
8.73E-09
2.44E-07
1.74E-09
4.19E-07
4.85E-11
3.55E-07
1.24E-05
7.10E-06
2.36E-11
2.55E-06
5.30E-06
5.83E-06
1.24E-07
0
1.62E-07
0
6.10E-09
7.97E-07
3.89E-06
1.03E-05
7.29E-06
0
0
7.97E-07
1.39E-07
4.21 E-09
3.21 E-11
7.22E-11
2.00E-10
6.98E-11
4.11E-12
6.25E-11
1.51E-06
8.49E-06
4.53E-06
9.66E-07
1.81E-06
0
3.60E-13
1.96E-08
8.14E-11
7.76E-06
1.17E-06
8.19E-10
3.42E-10
2.76E-09
5.98E-10
9.82E-10
2.52E-10
5.43E-07
1.25E-10
1.14E-07
Notes
2
2
2

2

3

2







2





4
5






2

2






2
2
2
2
2


2

2
2






2

2
                          D-2

-------
Radionuclide
Zn-65
Water
Ingestion
(risk/pCi)
1.17E-11
Food
Ingestion
(risk/pCi)
1.54E-11
Soil
Ingestion
(risk/pCi)
2.45E-11
Inhalation
(risk/pCi)
5.81E-12
External Exposure
(risk/yr per
PCi/g soil)
2.81 E-06
Notes

Notes:

1. A curie (Ci), the customary unit of activity, is equal to 3.7x 1010 nuclear transformations per second. 1 picocurie (pCi) = 10~12
Ci.  If required, slope factors in Table D.1 can be converted into the International System (SI) units of becquerels(1 Bq = 1 nuclear
transformation per second) by multiplying each inhalation, ingestion, or external exposure value by 27.03. Users can calculate
cancer risks using slope factors expressed in either customary units or SI units with equivalent results, provided that they also
use air, water, food and soil concentration values in the same system of units.

2. For each radionuclide listed, slope factors correspond to the risks per unit intake or exposure for that radionuclide only, except
when  marked with a "+D". In these cases, the risks from associated short-lived radioactive decay products (i.e., those decay
products with  radioactive half-lives less than or  equal to 6 months) are also included, based on an assumption  of secular
equilibrium.  These decay chains are identified in Table C.1 of Attachment C.

3. The inhalation slope factor listed represents inhalation of C-14 as a particulate.  Alternative values for inhalation of C-14 as a
gas are 3.36E-15 risk/pCi for carbon monoxide and 1.99E-14 risk/pCi for carbon dioxide.

4. The inhalation slope factor for H-3 represents inhalation of titiated water vapor, which is considered the most likely form in the
environment. Alternative values of inhalation of H-3 include 1.99E-13 risk/pCi for  particulates, 5.62E-18 risk/pCi for elemental
hydrogen gas, and 1.28E-13 risk/pCi for organic forms. Similarly, the ingestion slope factor values for H-3 represent ingestion
of tritiated water, which is considered the most likely form in the environment. Alternative values for ingestion of organically bound
forms of  H-3 in water,  food, and soil are 1.12E-13 risk/pCi, 1.44E-13 risk/pCi, and  2.02E-13 risk/pCi,  respectively.

5. The food ingestion slope factor for 1-129 represents  ingestion of milk. For ingestion of non-dairy foodstuffs, a lower value of
1.93E-10 risk/pCi ingested would apply.  The inhalation slope factor for 1-129 represents inhalation of particulates;   alternative
values for inhalation of 1-129 vapor are 1.24E-10 for inhalation of methyl iodide and 1.60E-10 for inhalation of other compounds
in vapor form.
                                                        D-3

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 D.2    MCLs for Radionuclides in Drinking Water

 Current MCLs for radionuclides are set at 4 mrem/yr for the sum of the doses from beta particles and photon emitters,
 15  pCi/L for gross alpha particle activity (including Ra-226, but excluding uranium and radon), and 5 pCi/L
 combined for Ra-226 and Ra-228.  The current MCLs for beta emitters specify that MCLs are to be calculated based
 upon an annual dose equivalent of 4 mrem to the total body or any internal organ. It is further specified that the
 calculation is to be performed on the basis of a 2 liter per day drinking water intake using the 168 hours data listed
 in "Maximum Permissible Body Burdens andMaximum Permissible Concentrations of Radionuclides in Air or Water
for Occupational Exposure, " NBS Handbook 69 as amended August 1963, U.S. Department of Commerce (U.S.
 DOC, 1963). These calculations have been done for most beta emitters and published as part of the EPA Office of
 Water Supply's National Interim Primary Drinking Water Regulations, Report EPA-570/9-76-003 (U.S, EPA, 1976).
 The calculated MCLs are included in Table D.2. For those beta emitters not included in EPA-570/9-76-00, MCLs
 have been calculated, for purposes of this guidance, using the existing MCL methodology, and are also included in
 Table D.2.

 In July 1991, EPA proposed to revise the MCLs for Ra-226 and Ra-228 to 20 pCi/L for each, change the methodology
 used for determining a 4 mrem/yr dose for the sum of the doses from beta particles and photon emitters, alter the
 definition of alpha particle activity to exclude Ra-226, and establishing new MCLs of 300 pCi/L for Rn-222 and 20
 (ig/L (30 pCi/L) for uranium (56 FR 33050).  EPA is under Court Order to either finalize the 1991 proposal for
 radionuclides (except for radon), or to ratify existing standards by November 2000. On April 21,2000 EPA solicited
 comment in a Notice of Data Availability (NODA) on three options for a uranium MCL: 1) 20 /j,g/l and 20 pCi/1 as
 a preferred option, 2) 40 ,ug/l  and 40 pCi/1, and  3) 80 ,ug/l and 80 pCi/1 (65 FR 21576).  In this NODA, EPA
 indicated that changes would not be made to the existing MCLs for radium, alpha particle activity, and beta particles
 and photon emitters. The 1996 Amendments to the Safe Drinking Water Act (SOWA) require EPA to propose a
 MCL for radon by August 1999, and to finalize the MCL by August 2000.  To comply with the requirements of the
 amended SDWA, on August 6,1997, EPA withdrew its 1991 proposal for Rn-222 (62 FR 42221). EPA issued a new
 proposal for Rn-222 (65 FR 21576). EPA proposed an MCL of 300 pCi/1 with an alternative MCL of 4,000 pCi/1
 if a state or local indoor radon  mitigation program was established.
                                                 D-4

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Table D.2 Radionuclide Drinking Water MCLs
Radionuclide
Ac-227
Ag-108m
Ag-110m
Am-241
Am-243
Bi-207
C-14
Cd-109
Ce-144
CI-36
Cm-243
Cm-244
Cm-248
Co-57
Co-60
Cs-134
Cs-135
Cs-137
Eu-152
Eu-154
Eu-155
Fe-55
Gd-153
H-3
1-129
K-40
Mn-54
Na-22
Nb-94
Ni-59
Ni-63
Np-237
Pa-231
Pb-210
Pm-147
Pu-238
Current MCLa b
(pCi/L)


90
15
15
200
2,000
600
30
700
15
15
15
1,000
100
80
900
200
200
60
600
2,000
600
20,000
1

300
400

300
50
15
15

587
15
Proposed MCL
(pCi/L)




































Risk Base Limit
(RBL)e
(pCi/L)
0.24
5.8























1.9


6.1




0.054


Mass Equivto MCL,
Proposed MCL, or
RBL (mg/L)
3.3E-12
2.2E-10
1.9E-11
4.4E-09
7.5E-08
4.4E-09
4.5E-07
2.3E-10
9.1E-12
2.1E-05
2.9E-10
1.9E-10
3.5E-06
1.2E-10
8.9E-11
6.2E-11
7.8E-04
2.3E-09
1.1E-09
2.3E-10
1.3E-09
8.3E-10
1.7E-10
2.1E-09
5.7E-06
2.7E-4
3.9E-11
6.4E-11
3.3E-8
3.7E-06
8.5E-10
2.1E-05
3.2E-07
7.1E-13
6.3E-10
8.8E-10
                  D-5

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                           Table D.2 Radionuclide Drinking Water MCLs
Radionuclide
Pu-239
Pu-240
Pu-241
Pu-242
Pu-244
Ra-226
Ra-228
Ru-106
Sb-125
Sm-147
Sm-151
Sr-90
Tc-99
Th-228
Th-229
Th-230
Th-232
TI-204
U-232
U-232
U-233
U-233
U-234
U-234
U-235
U-235
U-236
U-236
U-238
U-238
Zn-65
Current MCLa b
(pCi/L)
15
15

15
15
5C
5C
30
300
15
1,000
8
900
15
15
15
15
300












300
Proposed MCL
(pCi/L)


















20d
(20 /.g/l)d
20d
(20 /4)/l)d
20d
(20 /.g/l)d
20d
(20 /4)/l)d
20d
(20 /.g/l)d
20d
(20 /4)/l)d

Risk Base Limit
(RBL)e
(pCi/L)


27




























Mass Equivto MCL,
Proposed MCL, or
RBL (mg/L)
2.4E-07
6.6E-08
2.6E-10
3.8E-06
8.5E-04
5.1E-09
1.8E-11
9.0E-12
2.9E-10
6.5E-01
3.8E-08
5.9E-11
5.3E-05
1.8E-11
7.1E-08
7.4E-07
1.4E-01
6.5E-10
9.4E-10
2.0E-02
2.1E-06
2.0E-02
3.2E-06
2.0E-02
9.3E-03
2.0E-02
3.1E-04
2.0E-02
6.0E-02
2.0E-02
3.6E-11
Notes:
a   Existing MCL is 4 mrem/yrto the whole body or an organ, combined from all beta and photon emitters.
b   Existing MCL is 15 pCi/L, with the concentration level combined for all alpha emitters, except radon and uranium.
c   Existing MCL is 5 pCi/L combined for Ra-226 and Ra-228.
d   Preferred EPA proposed MCL standard is 20 ,ug/l and 20 pCi/l for uranium, with EPA soliciting comments on options of
    40 /^g/l and 40 pCi/l, and 80 /^g/l and 80 pCi/l. The preferred proposed MCL standard for uranium of 20 /^g/l and 20 pCi/l
    is represented in this table.
                                                 D-6

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Risk Based Limits calculated for 30-year exposure duration and 10~6 risk. These were calculated using equation 11' in
Risk Assessment Guidance for Superfund (RAGS): Volume i: Human Health Evaluation Manual (Part B, Development
of Risk-based Preliminary Remediation Goals), (page 37). The equations were adjusted to account for radioactive decay.
                                              D-7

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