United States Solid Waste and
Environmental Protection Emergency Response
Agency (5305W)
PB96-963 220
EPA540-R-96-012
OSWER Directive 9205.5-08
March 1996
RCRA/UST, Superfund, & EPCRA
Hotline Training Module
Introduction to:
Radiation Site Cleanup
Rulemaking
Updated as of November 1995
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DISCLAIMER
This document was developed by Booz-Allen & Hamilton Inc. under contract 68-W0-0039 to EPA. It is intended
to be used as a training tool for Hotline specialists and does not represent a statement of EPA policy.
The information in this document is not by any means a complete representation of EPA's regulations or policies.
This document is used only in the capacity of the Hotline training and is not used as a reference tool on Hotline
calls. The Hotline revises and updates this document as regulatory program areas change.
The information in this document may not necessarily reflect the current position of the Agency. This document
is not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any
party in litigation with the United States.
RCRA/UST, Superfund & EPCRA Phone Numbers:
National toll-free (outsidi of DC area)
Local number (within DC area)
National toll-free for the hearing impaired (TDD)
(800) 424-9346
(703)412-9810
(800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Standard Time,
Monday through Friday, except for federal holidays.
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RADIATION SITE CLEANUP RULEMAKING
CONTENTS
1. Introduction 1
2. Rulemaking Summary 2
2.1 Definitions 2
2.2 Radiation and Its Effects 4
2.3 Current Authorities for Site Cleanup 6
2.4 Radiation Site Cleanup Rulemaking 7
3. Information Resources 9
4. Module Summary 11
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Radiation Site Cleanup Rukmaking -1
1. INTRODUCTION
Since the 1940's, use of radioactive materials at weapons production facilities,
research laboratories/ medical facilities, and power plants (private sector and federal
facilities) has resulted in site contamination. These contaminated sites, some of
which are extremely large, contain different types and varying concentrations of
radionudides. A lack of specific cleanup standards raises the concern that sites with
similar contamination are being inconsistently remediated. In order to ensure that
sites contaminated with radionuclides are cleaned up to levels protective of human
health and the environment, EPA is in the process of developing rules to establish
comprehensive cleanup levels for radionudides in soil, groundwater, surface water,
biota, and structures at federal facilities.
EPA's Office of Radiation and Indoor Air (ORIA) within the Office of Air and
Radiation is responsible for developing these radiation site cleanup regulations.
Because the Hotline has expertise answering questions pertaining to how deanup
standards are developed for the Superfund response process, we are also responsible
for supporting ORIA by responding to questions on this rulemaking effort.
The goal of this module is to provide an overview of radionuclide contamination
issues, a history of regulatory efforts, and a chronicle of EPA's current rulemaking
effort. When you have completed this module, you should be able to:
• Briefly explain the major types of radiation and their effects on human health
and the environment
• Describe the current rulemaking effort and the types of regulations that may
be promulgated
« Identify information and resources pertinent to this rulemaking.
Use this list of objectives to check your knowledge of the topic after you complete
the training session.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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2 - Radiation Site Cleanup Rulemaking
2. RULEMAKING SUMMARY
Requirements for cleaning up sites contaminated with radiation are currently
addressed in a variety of laws, regulations, and policies. The Department of Energy
(DOE), the Department of Defense (DOD), the Nuclear Regulatory Commission
(NRC), and states all have potential jurisdiction over sites with radioactive
contamination. Often, different standards, models, and approaches are used to
characterize sites with similar types of contamination. Also, the assumptions used
to support risk assessments performed under different authorities may vary, leading
to significant differences between what is considered an appropriate cleanup level
and remedy selection for sites contaminated with radionuclides.
In order to standardize cleanup levels and streamline the cleanup process, ORIA is
developing a comprehensive regulatory strategy for sites with radioactive material
contamination. Specifically, regulations are being developed to establish cleanup
regulations for radionuclides in soil, groundwater, surface water, biota, and
structures at federal facilities, and to limit the amount of exposure to surrounding
communities from sites contaminated with radionuclides.
When promulgated, the regulatory standards will apply to federal facilities, and
therefore will be applicable or relevant and appropriate requirements at those
radionuclide-contaminated sites being remediated under the authority of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), otherwise known as Superfund. For more detailed information on how
other laws may apply at Superfund sites, reference the module entitled Applicable
or Relevant and Appropriate Requirements. These radiation site cleanup
regulations will not mandate the cleanup of any site, nor will they provide
requirements pertaining to how a site should be remediated. The regulations will
only provide standard cleanup levels that are protective of human health and the
environment.
2.1 DEFINITIONS
Familiarity with the following terms is key to understanding this module.
DOSE
For the purposes of this module, dose means the amount of energy that ionizing
radiation imparts on an object. The term dose, or dose-equivalent, takes into
account the amount of damage different types of radiation can cause to human
tissue. The unit of measure for dose-equivalent is a millirem.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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Radiation Site Cleanup Rulemaking - 3
M1LLIREM (MREM)
A millirem is a unit of measure for a dose or dose-equivalent equal to 1 X 10~3 rem.
A rem is a unit used in radiation protection to measure the amount of damage to
human tissue from a dose of radiation. This is the unit of measure most commonly
used for radionuclides regulated under the National Emission Standards for
Hazardous Air Pollutants (NESHAPs) established by the Clean Air Act (CAA).
NATURALLY OCCURRING AND ACCELERATOR-PRODUCED RADIOACTIVE
MATERIALS (NARM)
A NARM is any radioactive material produced from nuclear transformations in a
nuclear accelerator, excluding source, byproduct, and special nuclear material. An
accelerator-produced radionuclide may come from a process such as the
manufacturing of radiopharmaceuticals.
NATURALLY OCCURRING RADIOACTIVE MATERIALS (NORM)
NORM are naturally occurring radionuclides, excluding source, byproduct, and
special nuclear material. NORM is generally associated with mineral extraction and
processing industries (e.g., radium-contaminated soils). NORM waste is classified as
either discrete (low-volume, high-concentration of radiation), or diffuse (high-
volume, low-concentration of radiation).
NUCLEAR REGULATORY COMMISSION (NRC)
The NRC is the federal agency that regulates the use of certain radioactive materials.
(In the context of this module, "NRC" should not be confused with the National
Response Center.)
RADIATION
Radiation is the emission and propagation of energy through space, a material, or
medium in the form of waves. For instance, the emission and propagation of
electromagnetic waves from power lines or televisions constitutes a form of
radiation.
RADIONUCLIDE
A radionuclide is any naturally occurring or artificially produced radioactive
element or isotope.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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4 - Radiation Site Cleanup Rulemaking
SOURCE, SPECIAL NUCLEAR, AND BYPRODUCT MATERIAL
(a.k.a., AEA MATERIALS)
Radioactive materials are defined as source, spent nuclear, or byproduct under the
Atomic Energy Act (AEA). These materials are usually associated with nuclear
power and weapons production.
2.2 RADIATION AND ITS EFFECTS
Radiation is defined as energy traveling in the form of waves or particles. One form
of radiation, ionizing radiation, has sufficient energy to change or disrupt human
cells as it passes through human tissue. This more energetic form of radiation is
often the cause of adverse health and environmental problems. This module
focuses mainly on ionizing radiation, hereinafter referred to as radiation.
Most exposure to radiation comes from natural sources. For example, one source of
exposure is radon, a gas produced by the decomposition of uranium that is naturally
found in many soils. Radon accounts for over half of the exposure to radiation a
typical person receives. Other sources of natural radiation include the sun, outer
space, and rocks and soil. Exposure to radiation can also come from man-made
sources such as x-rays and radioactive medicine.
Radiation dosage is measured in units of rem, or an even smaller unit, the
millirem. The average person in the United States is exposed to approximately 360
millirem of radiation per year. Roughly 80 percent of this exposure comes from
natural sources, while 20 percent comes from man-made sources, primarily medical
x-rays.
Radiation can be detrimental to the human body. Acute exposure (a large dose
received over a short period of time) can cause severe and rapid damage to human
tissue, possibly even death. Chronic exposure (a small dose regularly received over
a long period of time) can cause health effects that may not be readily apparent, but
will manifest in time. Radiation can damage the DNA within a healthy human
cell, causing the cell to mutate and become cancerous.
TYPES OF RADIATION
Different radionuclides emit different types of radiation, which may have different
effects on the human body. There are four basic types of radiation: alpha particles,
beta particles, gamma rays, and x-rays. The first three, alpha particles, beta particles,
and gamma rays, originate from the nucleus of a radioactive atom, or radionuclide.
The fourth type of radiation, x-rays, originate from a source other than the nucleus
of an atom. Table I provides a more detailed description of the different types of
radiation and their effects on humans.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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Radiation Site Cleanup Rulemaking - 5
Exposure to natural radiation can come from the sun, cosmic rays, radon, and from
elements found naturally in soil, such as uranium, thorium, and potassium.
Exposure to man-made radiation can come from medicine, dentistry, research
institutions, nuclear reactors, or the nuclear fuel cycle. Many consumer products
also use low-level radioactive materials, such as glow-in-the-dark watches and
smoke detectors.
TYPES OF RADIATION
Type of Radiation
Description
Alpha particles
Large particles emitted from the decay of radioactive elements
that lose energy rapidly and rarely penetrate human tissue.
Usually absorbed by the outer layer of skin and can be stopped
by a sheet of paper. Can cause significant internal damage if
ingested or inhaled.
Beta particles
Electrons emitted from the nucleus of an atom during the
radioactive decay of a number of natural and man-made
radioactive elements. Smaller than alpha particles, but more
energetic. Beta particles may penetrate skin, but are easily
stopped by clothing or materials such as aluminum. Can cause
significant internal damage if ingested or inhaled.
Gamma rays
Made up of weightless packets of energy called photons, not
particles. They have no charge or mass, and often accompany
the emission of an alpha or beta particle. Can come from
natural or man-made sources, and can pass through the
human body or be absorbed by tissue, posing a health hazard.
Several feet of concrete or a few inches of lead are needed to
stop gamma rays.
X-rays
Similar to gamma rays, but originate from a source other that
the nucleus of a radioactive element. Generally, not as strong
as gamma rays. Used in medical diagnosis and in therapy to
destroy malignant cancer cells. X-rays are the largest source of
man-made radiation.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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6 - Radiation Site Cleanup Rulemaking
CLASSIFICATION OF RADIOACTIVE MATERIAL AND WASTE
The major categories of radioactive materials are source material, special nuclear
material, byproduct material, NARM, and NORM. Source, special nuclear, and
byproduct materials are all defined under the AEA and referred to as "AEA
materials." NARM and NORM encompass other nuclear materials not defined
under the AEA. Although these classifications are commonly used, they are not
mutually exclusive.
A radioactive waste is further categorized by the NRC according to its origin rather
than its level of radioactivity. The first category, high-level waste (HLW), is
generated by reprocessing spent nuclear reactor fuel. EPA, DOE, and NRC have the
overall responsibility for the safe management and disposal of HLW. Another
category of wastes, transuranic (TRU) waste, originates from the production of
nuclear weapons. These wastes pose the greatest threat when ingested or inhaled.
The radiation from the TRU waste is damaging to lung tissue and internal organs.
The third category, low-level radioactive waste (LLW), consists of radioactive
industrial or research waste such as paper, rags, and protective clothing. The federal
government is also responsible for the management of TRU and LLW. The last
category, NARM waste, generally contains radionuclides normally found in nature.
For example, crude oil and gas production wastes may contain high concentrations
of radioactive components. There are currently no federal regulations covering the
disposal of NARM waste, but it may be regulated by states.
2.3 CURRENT AUTHORITIES FOR SITE CLEANUP
Authority for the cleanup of radioactive sites varies depending on the type of site
and the type of contamination present at the site. EPA has a broad range of
authority to protect the public from exposure to radioactive contamination.
Authority is provided to address radioactive sites through several statutes including
AEA, CERCLA, CAA, the Toxic Substances Control Act (TSCA), the Low-Level
Radioactive Waste Policy Act, and the Uranium Mill Tailings Radiation Control Act
(UMTRCA). Varying guidance and inconsistent standards for the cleanup of
radionuclides have been developed under each of these different authorities.
Agencies with large numbers of contaminated sites manage cleanups under their
own programs. NRC has authority to regulate cleanup at sites operated by its
licensees. Cleanups initiated by the NRC usually involve the decommissioning of
facilities, and in most instances, apply only to AEA materials. DOE regulates the
cleanup of AEA materials and NARM at its research laboratories and weapons
production facilities. DOD regulates cleanups at active and former defense sites
involving weapons production and military use of radionuclides, while other DOD
facilities are regulated by NRC, EPA, or both.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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Radiation Site Cleanup Rulemaking - 7
2.4 RADIATION SITE CLEANUP RULEMAKING
Although there is statutory authority for the cleanup of sites contaminated with
radionudides, progress in cleaning up contaminated sites has been slow, largely due
to the lack of consistent cleanup standards. In order to accelerate the cleanup process
and provide consistent standards, EPA initiated a radiation site cleanup rulemaking
effort in September 1993, and published Issues Paper on Radiation Site Cleanup
Regulations (EPA402-R-93-084). This issues paper was designed as a starting point
for the National Advisory Council for Environmental Policy and Technology
(NACEPT) subcommittee formed to advise EPA in its rulemaking efforts. To date,
two meetings and one teleconference of NACEPT's Radiation Site Cleanup
Subcommittee have been conducted, and the subcommittee has provided valuable
input that EPA is using in the process of drafting the proposed rule. No further
meetings of this subcommittee are planned at this time. These regulations will be
promulgated under the authority of the AEA, and will apply to cleanups at federal
facilities and NRC-licensed sites.
SITE CLEANUP REGULATIONS
ORIA is. in the process of drafting a proposed rule for the cleanup of soil,
groundwater, surface water, air and structures at sites contaminated with
radionudides. A working draft of the site deanup regulations was presented to the
NACEPT subcommittee for comment at the last subcommittee meeting, held May
18 and 19,1994.
The proposed regulations seek to establish limits on the levels of radiation exposure
to communities near contaminated sites licensed by the NRC. The limits will be
imposed in the event the site is returned to public use. The proposed levels for all
radionudides, except for NARM, addressed in the draft include:
• An annual committed effective dose of 15 mrem/year above background
levels for total exposure for persons at a site
• Groundwater protection standards which do not exceed either Maximum
Contaminant Level Standards under 40 CFR Part 141 or background levels,
whichever is higher.
According to the draft proposed rule, in order for a site to be returned to residential
use, deanup at the site would need to meet these dose-based levels. If a site cannot
be cleaned up to these levels, land use restrictions (such as limiting use of the site to
industrial activities) would to be imposed to ensure that total exposure at a site does
not exceed these levels. Future monitoring of sites with land use restrictions would
also be required to ensure continued compliance.
NRC has proposed generic standards for NRC-licensed sites contaminated with
radioactive material. If EPA determines that NRC's regulatory program affords a
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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8- Radiation Site Cleanup Rulemaking
sufficient level of protection to public health and the environment, EPA will
propose in the Federal Register that NRC licensees be exempted from the EPA
radiation site cleanup regulations.
EPA expects to publish the proposed rule in the Federal Register in spring or
summer 1996.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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Radiation Site Cleanup Rulemaking - 9
3. INFORMATION RESOURCES
The Cleanup Standards Outreach Bulletin Board System (CSO BBS, or Radiation
Site Cleanup BBS) provides the regulated community and the public with quick
access to information on this rulemaking. It contains all information pertaining to
the radiation site cleanup rulemaking, including Federal Register notices, issues
papers, meeting announcements, meeting minutes, and the working draft of the site
cleanup proposed rule. Documents may be downloaded at no charge, and a bulletin
menu facilitates access to information relating to hot topics and the newest available
information.
The phone numbers are:
Computer Modem Access (800) 700-7837
(703) 790-0825
(703) 790-0723
System Operator (703) 893-6600 (ask for CSO BBS Sysop)
The CSO BBS can also be reached via the Internet through the Fed world system at
http://www.fedworld.gov.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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10 - Radiation Site Cleanup Rulemaking
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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Radiation Site Cleanup Rulemaking -11
4. MODULE SUMMARY
ORIA is developing a rulemaking to govern the cleanup of sites contaminated with
radionuclides. The regulations will apply to all federal facilities and sites licensed by
the NRC. The rulemaking will establish limits on the amount of radiation that
members of the public might receive from radionuclide-contaminated sites. This
approach includes the promulgation of a regulation that sets standards for the
remediation of soil, groundwater, surface water, biota, and structures at federal
facilities. A working draft of the proposed site cleanup regulations is available, and
the actual proposed rule is expected to be published in the Federal Register in spring
or summer 1996. The radiation site cleanup bulletin board system (CSO BBS)
contains all pertinent information on this rulemaking, including documents that
may be downloaded at no charge.
Although a proposed rule has not been published to date, it is important that
Information Specialists be familiar with this information. Learning the background
of the radiation site cleanup rulemaking efforts prior to the promulgation of the
rules in the Federal Register enables the Hotline to provide in-depth, thorough
responses to inquiries concerning the rule's progress, and to provide callers with
current, accurate information.
The information in this document is not by any means a complete representation of EPA's regulations or policies, but is
an introduction used for Hotline training purposes.
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