UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C, 20460
                                                                  OFFICE OF
                                                           SOLID WASTE AND EMERGENCY
                                                                  RESPONSE
                                   JAI-i  -4  201C
                                                                  OSWER 9355.5-30
MEMORANDUM

SUBJECT:  Distribution of Superfund ARAR Dose Compliance Concentrations for
             Radionuclides in Buildings (BDCC) and ARAR Dose Compliance
             Concentrations for Radionuclides in Surfaces (SDCC) Electronic
             Calculators

FROM:      James E. Woolford, Director  V/>-'
                                        r J            -:-J
             Office of Superfund RemediaHon and Technology Innovation
                                                     /
TO:         Superfund National Policy Managers, Regions 1-10

Purpose

       The purpose of this memorandum is to transmit the two final electronic
calculators, the Applicable or Relevant and Appropriate Requirements (ARAR) "Dose
Compliance Concentrations for Radionuclides in Buildings (BDCC)" and the ARAR
"Dose Compliance Concentrations for Radionuclides in Surfaces (SDCC)." The BDCC
calculator is found at the following website:  http://epa-bdcc.ornl.gov/. The radionuclide
SDCC calculator is found at the following website: http://epa-sdcc.ornl.gov/. These
electronic calculators are intended to help risk assessors, remedial project managers, and
others involved with risk assessment and decision making at sites with contaminated
buildings and hard outside surfaces (e.g., building slabs, outside  building walls, sidewalks
and roads). These electronic calculators provide guidance for establishing dose
compliance concentrations (DCCs) for dose-based1 Applicable or Relevant and
Appropriate Requirements (ARARs) for remedial actions addressing radioactive releases
that have migrated inside buildings and onto and within hard outside surfaces under the
Comprehensive Environmental Response, Compensation, and Liability Act of  1980
(CERCLA).2 These  calculators address contaminated dust and fixed surface or
 These are standards that are expressed in terms of dose (e.g., 10 millirem per year (mrem/yr)).

 The electronic calculators transmitted by this memorandum provide guidance on compliance with ARARs
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

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volumetric contamination on the inside of buildings or on hard outside surfaces, and air
inside of buildings, that are located in areas that will have a residential or
commercial/industrial land use.

       Initially applied at the scoping phase of a project using readily available
information, dose-based BDCCs and SDCCs generally are modified based on site-
specific data gathered during the Remedial Investigation and Feasibility Study (RI/FS).
BDCC and SDCC development and use in screening should assist staff in streamlining
the consideration of remedial alternatives.  Radionuclide-specific BDCCs and SDCCs
usually are derived from two general sources: (1) concentrations based on potential
ARARs and (2) concentrations based on risk assessment. The focus of these database
tools are dose-based calculations for ARAR compliance that set concentration limits
under specific exposure conditions.

Background

       In 1997, 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 recommendations for establishing protective
cleanup levels for radioactive contamination at CERCLA remedial sites.  The guidance
reiterated that cleanup levels of radionuclides generally should be within the risk range
for carcinogens established in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) when ARARs are not available or are not sufficiently
protective. Thus, remedial Superfund cleanups generally should achieve a level of risk
within the 10" to 10*  carcinogenic risk range based on the reasonable maximum
exposure for an individual. As addressed in the 1997 guidance, regions should include
exposures from all potential pathways and through all media (e.g., soil, ground water,
surface water, sediment, air, structures, etc.), when calculating remedial cleanup levels.
The guidance also provides a listing of radiation standards that are likely to be used as
ARARs to establish cleanup levels or to conduct remedial actions.

       The BDCC and SDCC calculators are part of a continuing effort by the Office of
Superfund Remediation and Technology Innovation (OSRTI) to provide  updated
guidance for addressing radioactively contaminated remedial Superfund sites consistent
with our guidance for addressing chemically contaminated sites (while accounting for the
technical differences between radionuclides and chemicals). OSRTI intends for this
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 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.

       These electronic calculators provide guidance to U.S. Environmental Protection Agency (EPA) staff on
how to establish BDCCs and SDCCs for compliance with dose-based ARARs. The guidance is designed to be
consistent with EPA's national guidance on these values. These electronic calculators do not, however,
substitute for EPA's statutes or regulations, nor are they regulations themselves. Thus, they 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 these guidance in the future, as appropriate.
                                          2

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effort to facilitate remedial cleanups that are consistent with the NCP at radioactively
contaminated sites and to incorporate new information based on improvements to the
Superfund program.

       Today's radionuclide BDCC and SDCC calculators are based partially on a
calculator previously issued by EPA entitled "Radionuclide ARAR Dose Compliance
Concentrations (DCCs) for SuperfuiKT (January 28, 2004). The BDCC calculator is
based mostly on the "Preliminary Remediation Goals for Radionuclides in Buildings
(BPRGV calculator previously issued by EPA (August 29, 2007). The SDCC calculator
is based mostly on the "Preliminary Remediation Goals for Radionuclides in Outdoor
Surfaces (SPRG)" calculator previously issued by EPA (January 16, 2009). Unlike the
earlier DCC calculator which addressed soil and water, the BDCC and SDCC calculators
address inside buildings and outside hard surfaces. Also in contrast to the BPRG and
SPRG calculators which are intended to develop concentrations for Preliminary
Remediation Goals based on risk (e.g.,  1 x 10~6), the BDCC and SDCC calculators are
intended to develop concentrations for compliance with ARARs that are expressed in
terms of dose (e.g., 10 mrem/yr).

Implementation

       For questions regarding radiation site policy and guidance for CERCLA cleanup
actions, readers are referred to the Superfund Radiation Webpage at
http://www.epa.gov/superfund/health/contamjnants/radiation/index.htm.  The subject
matter specialist for these calculators 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:
Mathy Stanislaus, OSWER
Barry Breen, OSWER
Lisa Feldt, OSWER
Brigid Lowery, CPA
Debbie Dietrich, OEM
Matt Hale, OSW
David Lloyd, OBLR
John Reeder, FFRRO
Renee Wynn, OPM
Carolyn Hoskinson, OUST
Elliott Gilberg, OSRE
David Kling, FFEO
Tom Kelly, ORIA
Randall Wentsel, ORD
Mary-Kay Lynch, OGC
Jace Cuje, ORD/OSP
Bill Sette, OSWER
Stiven Foster, OSWER
Reggie Cheatham, OEI
Debbie Bishop, Superfund Lead  Region Coordinator, US EPA Region 7

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