J?l°*T*tf
                         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                         WASHINGTON, D.C. 20460


                                   ^   16  m                      OF.CEOF
                                                               SOLID WASTE AND EMERGENCY
                                                                       RESPONSE
                                                                       OSWER 9355.5-26
MEMORANDUM

SUBJECT:   Distribution of Superfund Preliminary Remediation Goals for
              Radionuclides in Outdoor Surfaces (SPRG) Electronic Calculator
FROM:      James E. Woolford, Director
              Office of Superfund Remediwfon and Technology Innovation
TO:           Superfund National Policy Managers, Regions 1-10

Purpose

       The purpose of this memorandum is to transmit the final electronic calculator
entitled: "Superfund Preliminary Remediation Goals for Radionuclides in Outdoor
Surfaces (SPRG)."   The radionuclide SPRG calculator is found at the following website
http://epa-sprg.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 hard outside surfaces (e.g., building slabs, outside
building walls, sidewalks and roads). The electronic calculator provides guidance for
establishing risk-based PRGs for remedial actions at radioactively  contaminated hard
outside surfaces under the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA).'  The calculator addresses contaminated dust and fixed
 The electronic calculator transmitted by this memorandum provides guidance on preliminary remediation goals
under CERCLA and is consistent with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP).  It does not alter the NCP's general expectations for remedial actions, such as those 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 need to attain or waive applicable or relevant and
appropriate requirements (ARARs); potential ARARs for contaminated ground water at radiation sites typically
include Maximum Contaminant Levels (MCLs) or non-zero Maximum Contaminant Level Goals (MCLGs)
established under the Safe Drinking Water Act.

        This electronic calculator provides  guidance to U.S. Environmental Protection Agency (EPA) staff on
how to establish risk-based SPRGs. The guidance is designed to be consistent with EPA's national guidance on
these values. 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

-------
surface or volumetric contamination on or inside hard outside surfaces located in areas
having a residential or commercial/industrial land use.

       When initially used at the scoping phase of a project taking into account readily
available information, risk-based SPRGs generally are modified based on site-specific
data gathered during the Remedial Investigation and Feasibility Study phase.  SPRG
development and screening should assist staff in streamlining the consideration of
remedial alternatives.  Radionuclide-specific SPRGs 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 often include
concentration limits set by other environmental regulations, such as Safe Drinking Water
Act maximum contaminant levels (MCLs).  The second source for SPRGs, and the focus
of this database tool, typically is risk-based  calculations that set concentration limits
using toxicity values under specific exposure condition.

Background

       EPA issued guidance entitled "Establishment of Cleanup Levels for CERCLA
Sites with Radioactive Contamination" (OSWER No. 9200.4-18, August 22,  1997). This
1997 guidance provided clarification for establishing protective cleanup levels for
remedial actions involving radioactive contamination. The 1997 guidance also 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. Thus, for
example, 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.2
In addition, 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.). Furthermore, the 1997 guidance provides a listing of radiation standards
that are likely to be used as ARARs to establish cleanup levels for remedial actions.

       The attached SPRG 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, taking into account the technical differences
between radionuclides and chemicals.  OSRTI intends for this effort to facilitate cleanups
that are consistent  with the NCP at radioactively contaminated sites and to incorporate
new information based on improvements to the Superfund program that have been
implemented through Administrative Reforms.
community, and may not apply to a particular situation based upon the circumstances. EPA may change this
guidance in the future, as appropriate.
2 This calculator for the remedial program defaults towards PRGs based on a 1 x IO"6 cancer risk.  Please
note the removal program, when conducting emergency and time-critical removal responses involving
carcinogenic contaminants generally uses Removal Action Levels (RALs) based on a cancer risk of 1 x
IO-4.

-------
      A draft version of the SPRG calculator underwent external peer review in 2008.
Comments received during thai peer review have been addressed and revisions made to
the calculator, as appropriate. An earlier draft of SPRG calculator underwent internal
EPA regional review in 2007.

Implementation

      For questions regarding radiation site policy and guidance for CERCLA cleanup
actions, readers are referred to the Superfund Radiation Webpage at
http://ww\\ .epa.gov/supertund.heal th/contaminants/radiatioa index.htm.
The subject matter specialist for this calculator is Stuart Walker of OSRTI.  He can be
reached by e-mail at walker.smart gepa.utn or by telephone at (703) 603-8748.

cc:
Susan Bodine. OSWER
Barry Breen. OSWER
Brigid Lowery. CPA
Debbie Dietrich. OEM
Matt Hale. OSW
David Lloyd. OBLR
John Reeder. FFRRO
Renee Wynn. OPM
Cliff Rothenstein, OUST
Marcia Mulkey. OSRE
David Kling, FFEO
Elizabeth Cotsworth. ORIA
Randall Wentsel. ORD
Mary-Kay Lynch, OGC
Jace Cuje, ORD/OSP
Bill Sette, OSWER
Stiven Foster, OSWER
Reggie Cheatham. OEI
Wendy Lubbe, Superfund Lead Region Coordinator, US EPA Region 7
NARPM Co-Chairs

-------