\
                            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                             WASHINGTON, D.C. 20460
                                   AU6  29  2007
                                                                              OFFICE OF
                                                                      SOLID WASTE AND EMERGENCY
                                                                              RESPONSE
                                                                 OSWER No. 9355.0-114
MEMORANDUM
SUBJECT:   Distribution of Superfund Preliminary Remediation Goals for Radionuclides in
               Buildings (BPRG) Electronic Calculator
FROM:


TO:

PURPOSE
               James E.Woolford, Director
               Office of Superfund Remediation and TechnWogy Innovatiorr(OSRTI)

               Superfund National Policy Managers, Regions 1-10
       The purpose of this memorandum is to transmit the final electronic calculator entitled:
"Preliminary Remediation Goals for Radionuclides in Buildings (BPRG)."  The BPRG calculator
is found at the following website http://epa-bprg.ornl.gov/. The electronic calculator is intended
to help risk assessors, remedial project managers, and others involved with risk assessment and
decision making at sites with contaminated buildings. The electronic calculator provides
guidance for establishing risk-based preliminary remediation goals (PRGs) for remedial actions
at radioactively contaminated buildings under the Comprehensive Environmental Response,
Compensation, and Liability Act ofT980 (CERCLA).1 The calculator addresses contaminated
        The electronic calculator transmitted by this memorandum provides guidance on preliminary remediation goal
issues for CERCLA remedial actions and is consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), It does not alter the NCP expectations regarding treatment of principal threat waste and the use
of containment and institutional controls for low level threat waste. Consistent with CERCLA and the NCP, remedial
actions must attain or waive applicable or relevant and appropriate requirements f ARARs). CERCLA remedial actions for
contaminated ground water at radiation sites must attain {or waive as appropriate) the Maximum Contaminant Levels
(MCLs) or non-zero Maximum Contaminant Level Goals (MCLGs) established under the Safe Drinking Water Act, where
the MCLs or MCLGs are relevant and appropriate for the site.

       This electronic calculator provides guidance to U.S. Environmental Protection Agency (EPA) staff on how to
establish risk-based BPRGs, It also provides guidance to the public and to the regulated community on how EPA intends
that the NCP be implemented.  The guidance is designed to describe EPA's national policy on these issues.  The electronic
calculator does not, however, substitute for EPA's statutes or regulations, nor is it a regulation itself. Thus, it cannot
impose legally-binding requirements on EPA, states, or the regulated community, and may not apply to a particular
situation based upon the circumstances. EPA may change this guidance in the future, as appropriate.

-------
                             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                             WASHINGTON, D.C. 20460
      %<
                                                                               OFFICE OF
                                                                       SOLID WASTE AND EMERGENCY
                                                                               RESPONSE
                                                                  OSWERNo. 9355.0-114

MEMORANDUM

SUBJECT:   Distribution of Superfund Preliminary Remediation Goals for Radionuclides in
               Buildings (BPRG) Electronic Calculator

FROM:       James E. Woolford, Director
               Office of Superfund Remediation and Technology Innovation (OSRTI)

TO:           Superfund National Policy Managers, Regions 1-10

PURPOSE

       The purpose of this memorandum is to transmit the final electronic calculator entitled:
"Preliminary Remediation  Goals for Radionuclides in Buildings (BPRG)."  The BPRG
calculator is found at the following website http://epa-bprg.ornl.gov/. The electronic calculator
is intended  to help risk assessors, remedial  project managers, and others involved with risk
assessment and decision making at sites with contaminated buildings.  The electronic  calculator
provides guidance for establishing risk-based preliminary remediation goals (PRGs) for remedial
actions at radioactively contaminated buildings under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA).1 The calculator addresses
contaminated dust, indoor  air, and fixed surface or volumetric contamination on or inside of
        The electronic calculator transmitted by this memorandum provides guidance on preliminary remediation goal
issues for CERCLA remedial actions and is consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). It does not alter the NCP expectations regarding treatment of principal threat waste and the use
of containment and institutional controls for low level threat waste. Consistent with CERCLA and the NCP, remedial
actions must attain or waive applicable or relevant and appropriate requirements (ARARs). CERCLA remedial actions for
contaminated ground water at radiation sites must attain (or waive as appropriate) the Maximum Contaminant Levels
(MCLs) or non-zero Maximum Contaminant Level Goals (MCLGs) established under the Safe Drinking Water Act, where
the MCLs or MCLGs are relevant and appropriate for the site.

       This electronic calculator provides guidance to U.S. Environmental Protection Agency (EPA) staff on how to
establish risk-based BPRGs. It also provides guidance to the public and to the regulated community on how EPA intends
that the NCP be implemented. The guidance is designed to describe EPA's national policy on these issues. The electronic
calculator does not, however, substitute for EPA's statutes or regulations, nor is it a regulation itself.  Thus, it cannot
impose legally-binding requirements on EPA, states, or the regulated community, and may not apply to a particular
situation based upon the circumstances. EPA may change this guidance in the future, as appropriate.

-------
walls, floors, and ceilings within buildings that will be occupied for residential or
commercial/industrial land use.

       Initially used at the scoping phase of a project using readily available information, risk-
based BPRGs generally are modified based on site-specific data gathered during the RI/FS study.
BPRG development and screening should assist staff in streamlining the consideration of
remedial alternatives. Radionuclide-specific BPRGs are from two general sources: (1)
concentrations based on potential applicable or relevant and appropriate requirements (ARARs)
and (2) concentrations based on risk assessment. ARARs include concentration limits set by
other environmental regulations, such as Safe Drinking Water Act maximum contaminant levels
(MCLs). The second source for BPRGs, and the focus of this database tool, is risk-based
calculations that set concentration limits using toxicity values under specific exposure
conditions.

BACKGROUND

       The U.S. Environmental Protection Agency (EPA) issued guidance entitled
"Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination"
(OSWERNo. 9200.4-18, August 22, 1997).  This 1997 guidance provided clarification for
establishing protective cleanup levels for remedial actions involving radioactive contamination.
The guidance reiterated that remedial  actions for radionuclides are governed by the risk range for
all carcinogens established in the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) when ARARs are not available or are not sufficiently protective.  Remedial actions
should generally achieve a level of risk within the 10"4 to 10"6 carcinogenic risk range based on
the reasonable maximum exposure for an individual.  In calculating cleanup levels, one should
include exposures from all potential pathways, and through all media (e.g., soil, ground water,
surface water, sediment, air, structures, etc.) The guidance also provides a listing of radiation
standards that are likely to be used as ARARs to establish cleanup levels for remedial actions.

       This BPRG calculator is part of a continuing effort by the Office of Superfund
Remediation and Technology Innovation (OSRTI) to provide updated guidance for addressing
radioactively contaminated sites consistent with our guidance for addressing chemically
contaminated sites, except to account for the technical differences between radionuclides and
chemicals.  This effort is intended to facilitate compliance with the NCP at radioactively
contaminated sites while incorporating the improvements to the Superfund program that have
been implemented through Administrative Reforms.

       A draft version of the BPRG calculator underwent external peer review in 2006.
Comments received during that peer review have been addressed and revisions made to the
calculator as appropriate.
                                          -2-

-------
IMPLEMENTATION

      For questions regarding radiation site policy and guidance for CERCLA remedial actions,
readers are referred to the Superfund and EPCRA call center at 1-800-424-9346 or the Superfund
Radiation Webpage at http://www.epa.gov/superfund/health/contaminants/radiation/index.htm.
The subject matter specialist for this calculator is Stuart Walker of OSRTI.  He can be reached
by e-mail at walker.stuart@epa.gov or by telephone at (703) 603-8748.

cc:    Susan Bodine, OSWER
      Barry Breen, OSWER
      Scott Sherman, OSWER
      OSRTI Managers
      Ed Chu, Land Revitalization Staff
      Debbie Dietrich, OEM
      David Lloyd, OBCR
      Matt Hale, OSW
      John Reeder, FFRRO
      Susan Bromm, OSRE
      Dave Kling, FFEO
      Elizabeth Cotsworth, ORIA
      Randall Wentsel,  ORD
      Mary-Kay Lynch, OGC
      Joanne Marinelli, Superfund Lead Region Coordinator, US EPA Region 3
      NARPM Co-Chairs
      OSRTI Documents Coordinator

-------