EPA/600/R-15/317 I July 2016
www.epa.gov/homeland-security-research
United States
Environmental Protection
Agency
oEPA
Practical Considerations and
Operational Recommendations for
Waste Staging for Wide-Area
Radiological Releases
»gi> 'I
p
I
Office of Research and Development
Homeland Security Research Center
-------
This page is intentionally left blank.
-------
EPA/600/R-15/317
July 2016
U.S. Environmental Protection Agency
Practical Considerations and Operational Recommendations for
Waste Staging for Wide-Area Radiological Releases
Revision Number: 005
Issue Date: May 18, 2016
U.S. Environmental Protection Agency
National Homeland Security Research Center
Decontamination and Consequence Management Division
Research Triangle Park, NC
-------
This page is intentionally left blank.
-------
DISCLAIMER AND LIMITS ON SCOPE
The U.S. Environmental Protection Agency through its Office of Research and Development
managed the research described here. This work was performed by Battelle under Contract No.
EP-C-10-001 Work Assignment 5-34. It has been subjected to the Agency's review and has been
approved for publication. Note that approval does not signify that the contents necessarily
reflect the views of the Agency.
The cleanup process described in this practical recommendations document does not rely on
and does not affect authority under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 42 U.S.C. 9601 et seq., and the National Contingency
Plan (NCP), 40 CFR Part 300. This document does not address or impact site cleanups occurring
under other statutory authorities such as the United States Environmental Protection Agency's
(EPA) Superfund program, the Nuclear Regulatory Commission's (NRC) decommissioning
program, or other federal or state cleanup programs. This document expresses no view as to
the availability of legal authority to implement this process in any particular situation. This
document is intended to provide information and suggestions that may be helpful for
implementation efforts and should be considered advisory. As indicated by the use of non-
mandatory language such as "may," "should" and "can," this Manual only provides
recommendations and does not confer any legal rights or impose any legally binding
requirements upon any member of the public, states, or any other federal agency. The
recommendations in this document are not required elements of any rule. Therefore, this
document does not substitute for any statutory provisions or regulations, nor is it a regulation
itself, so it does not impose legally-binding requirements on EPA, states, or the regulated
community. The recommendations herein may not be applicable to each and every situation.
Questions concerning this document or its application should be addressed to:
Paul Lemieux
National Homeland Security Research Center
Office of Research and Development
U.S. Environmental Protection Agency
Mail Code E343-06
Research Triangle Park, NC 27711
919-541-0962
i
-------
TABLE OF CONTENTS
Disclaimer AND LIMITS ON SCOPE
Table of Contents
List of Figures
List of Tables
List of Acronyms and Abbreviations
Glossary
Acknowledgments
1. BACKGROUND
1.1 Purpose of the Operational Recommendations
1.2 Why These Recommendations are Necessary
2. Scope of the Operational Recommendations
2.1 Intended Audience
2.2 Response Management and Agency Roles and Responsibilities
2.2.1 Radiological Dispersal Device (RDD) Incident Example
3. Planning Assumptions
3.1 Pre-lncident Waste Management Planning
3.2 Scalable and Adaptable Strategies
3.3 Types of Resources Needed
4. Concept of Operations
4.1 Importance of Waste Staging
5. Waste Management
5.1 Waste Type
5.2 Waste Quantity
6. Waste Staging
6.1 Waste Staging Decision Tree
6.2 Criteria to Evaluate and Pre-Establish Potential Staging/Temporary Storage Sites.
6.2.1 Location
6.2.2 Site Ownership/Site Leasing
6.2.3 Length of Storage Time
6.2.4 Truck or Railcar Size/Equipment Needed
6.2.5 Waste Staging Site Size/Capacity
6.2.6 Site Operations
6.2.7 Condition of Materials (Debris and Waste)
6.2.8 Sites for Designated Materials
6.2.9 Security and Signage
6.2.10 Ease of Accessibility / Travel Conditions
7. Estimated Waste Quantities Under the WARRP RDD Scenario
8. References
...i
...ii
..iv
..iv
...v
. vii
.xiv
.. 1
.. 3
..4
..7
.. 8
.. 8
..9
11
12
14
14
15
15
16
17
18
19
19
23
23
28
29
30
32
35
39
41
43
44
46
54
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
APPENDIX A: Radiological Contamination Mitigation through Technologies for Containment and
Gross Decontamination Wastes 1
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
LIST OF FIGURES
Figure 1. Example of Incident Command Structure for RDD Incident 11
Figure 2. Decision Tree to Pre-establish Waste Staging Areas 22
Figure 3a. WARRP RDD scenario releases at U.S. Mint 47
Figure 3b. Example of 12 different fallout patterns for Washington, DC 48
Figure 4. WARRP RDD scenario - estimated number of contaminated structures in area
bounded by <15-millirem contamination zone 50
Figure 5. Estimated quantities and sources of waste from WARRP RDD scenario in area
bounded by <15-millirem contamination zone 51
Figure 6. Estimated breakdown of solid waste from WARRP RDD scenario in area
bounded by <15-millirem contamination zone 52
Figure 7. Average estimated activity concentration of waste from WARRP RDD scenario
in area bounded by <15-millirem contamination zone 53
LIST OF TABLES
Table 1. Classes of Low-Level Radioactive Waste* (LLRW) 17
Table A-1. Containment Technologies considered by Stakeholder Workgroup 2
Table A-2. Gross Decontamination Technologies considered by Stakeholder Workgroup 3
Table A-3. Approaches to contain water generated from gross decontamination
technologies listed in Table A-2 3
Table A-4. Surfaces of interest to Stakeholders for possible application of gross
decontamination technologies 4
Table A-5. UK Handbook's Listing of Management Options for Decontamination
Planning 6
iv
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
LIST OF ACRONYMS AND ABBREVIATIONS
BOTE
Bio-response Operational Testing and Evaluation
137Cs
Cesium-137
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
CI/KR
Critical Infrastructure/Key Resources
CMAT
Consequence Management Advisory Team
CRZ
Contamination Reduction Zone
DHS
U.S. Department of Homeland Security
DHS S&T
Department of Homeland Security Science and Technology Directorate
DoD
U.S. Department of Defense
DOE
U.S. Department of Energy
EOC
Emergency Operations Center
EPA
U.S. Environmental Protection Agency
EZ
Exclusion Zone
FEMA
Federal Emergency Management Agency
FR
Federal Register
FRMAC
Federal Radiological Monitoring and Assessment Center
Hazus-MH
Hazards U.S. Multi-Hazard Model
HHS
Health and Human Services
HHW
Household Hazardous Waste
HW
Hazardous Waste
l-WASTE
Incident Waste Assessment and Tonnage Estimator
IAEA
International Atomic Energy Agency
ICS
Incident Command System
IND
Improvised Nuclear Device
LLMW
Low-Level Mixed Waste
LLRW
Low-Level Radioactive Waste
MDEQ
Michigan Department of Environmental Quality
NCP
National Contingency Plan
NHSRC
EPA National Homeland Security Research Center
NIMS
National Incident Management System
NRC
Nuclear Regulatory Commission
NRF
National Response Framework
NRIA
Nuclear/Radiological Incident Annex
NRT
National Response Team
NPP
Nuclear Power Plant
ORCR
Office of Resource Conservation and Recovery
OSC
On-Scene Coordinator
OSHA
Occupational Safety and Health Administration
OSWER
Office of Solid Waste and Emergency Response
PAG
Protective Action Guide
PPE
Personal Protective Equipment
RCM
Radiological Contamination Mitigation
RCRA
Resource Conservation and Recovery Act
RDD
Radiological Dispersal Device
SME
Subject Matter Expert
V
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
sz
Support Zone
UASI
Urban Area Security Initiative
UC
Unified Command
UK
United Kingdom
USACE
U.S. Army Corps of Engineers
USDA
U.S. Department of Agriculture
WAC
Waste Acceptance Criteria
WARRP
Wide Area Recovery and Resiliency Program
WEST
Waste Estimation Support Tool
WWTP
Wastewater Treatment Plant
vi
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
GLOSSARY
Agency - A division of government with a specific function, or a non-governmental organization
(e.g., private contractor, business, etc.) that offers a particular kind of assistance. In the incident
command system (ICS), agencies are defined as jurisdictional (having a statutory role in incident
mitigation) or assisting and/or cooperating (providing resources and/or assistance).
Aqueous Waste - Waste that is water-soluble or water-based. Dealing with these wastes can
require different approaches than other wastes that are in the liquid form of matter. Such
wastes can be generated from radiological contamination mitigation activities. Compare to
"liquid waste" and "solid waste."
Clearance - The process of determining that an item or facility is acceptable for reuse or
reoccupancy. Generally occurs after decontamination and before reoccupancy. Clearance is not
a term typically used when discussing waste management, although its usage is somewhat akin
to the waste acceptance criteria (WAC) that deals with allowable levels of contaminants for
waste to be allowed to proceed through a given disposal pathway.
Code of Federal Regulations (CFR) - The codification of the federal regulations published in the
Federal Register by the executive departments and agencies of the federal government. Each
volume of the CFR is updated once each calendar year and is issued on a quarterly basis. See
http://www.qpoaccess.qov/cfr/index.html. Accessed February 25, 2015
Contamination (radioactive) - Radionuclides on surface or in the environment as a result of a
release of radiological material.
Contamination Reduction Zone (CRZ) - The transition area between the exclusion and support
zones. This area is where responders enter and exit the exclusion zone and where
decontamination activities take place. Also called the warm zone.
Critical Infrastructure (CI) - Systems and assets, whether physical or virtual, so vital that the
incapacity or destruction of such may have a debilitating impact on the security, economy,
public health or safety, environment, or any combination of these matters, across any federal,
state, regional, tribal, territorial, or local jurisdiction.
Debris - The remains of something broken down or destroyed. Debris may also be considered
to be waste depending upon what contaminants may be present.
Decontamination - The inactivation or reduction of contaminants from surfaces by physical,
chemical or other methods to meet a cleanup goal. For the purposes of this document,
decontamination does not include treatment of contaminated water or wastewater, or other
wastes such as solid waste. Compare to definition of Treatment.
Early Phase - The beginning of a radiological incident when immediate decisions for effective
use of protective actions are required and must therefore be based primarily on the status of
the radiological incident and the prognosis for worsening conditions. When available,
predictions of radiological conditions in the environment based on the condition of the source
or actual environmental measurements may be used. Protective actions based on the
vii
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Protective Action Guides (PAGs) may be preceded by precautionary actions during the period.
This phase may last from hours to days. For the purpose of these recommendations, early
phase is defined as the first 72 hours. Although waste may be generated during the early phase
of the response, it is likely that waste management activities will not take place until after the
early-phase of the response. This document intends to highlight information to be included in
pre-incident planning, and to provide decision makers information to identify incident-specific
waste staging areas based on criteria established in the Pre-lncident Waste Management Plan
(WMP); these decisions may very well be made during the first 72 hours of a response.
Emergency-Any incident, whether natural or man-made, that requires responsive action
within hours to protect life or property. As defined in the Stafford Act, any occasion or instance
for which, in the determination of the President, federal assistance is needed to supplement
state and local efforts and capabilities to save lives and to protect property and public health
and safety, or to lessen or avert the threat of a catastrophe in any part of the United States (Per
42 U.S.C. 5122).
Exclusion Zone (EZ) - The area with actual or potential contamination and the highest potential
for exposure to hazardous substances. Also called the hot zone.
Federal On-Scene Coordinator (OSC) - The federal official responsible for coordinating and
directing federal responses under subpart D, or the government official designated by the lead
agency to coordinate and direct removal actions under subpart E, of the National Contingency
Plan (NCP) (per 40 CFR 300.5). The specific duties of the OSC are provided in 40 CFR 300.120.
The federal OSC is predesignated by the U.S. Environmental Protection Agency (EPA), U.S. Coast
Guard, U.S. Department of Energy (DOE), or U.S. Department of Defense (DoD) depending on
the location and/or source of the release and may be designated by other federal agencies
under certain circumstances.
Federal Radiological Monitoring and Assessment Center (FRMAC) - An interagency response
asset, supplemented by a DOE team and other DOE assets, to assist state, tribal, and local
officials with monitoring, assessment, and health guidance for nuclear/radiological incidents.
The mission of the FRMAC is to coordinate and manage all federal radiological environmental
monitoring and assessment activities during a radiological incident, within the United States.
Federal Register (FR) - The official weekday publication for rules, proposed rules, and notices
of federal agencies and organizations, as well as executive orders and other presidential
documents. See http://www.qpo.qov/fdsvs/browse/collection.action?collectionCode=FR. Accessed
February 25, 2015.
Gross Decontamination - In the context of this document, "gross decontamination" is a part of
the decontamination process, often representing a small fraction of the timeline of the entire
decontamination process, during which the goal is to reduce contamination to levels that will
be safe for at least a limited period of time. Such purposes support rapid restoration of critical
infrastructure (CI) or key resources (KR) following a wide area incident.
Hazardous Waste - For the purposes of these recommendations, a solid or aqueous waste that
may cause an increase in mortality or serious illness or pose a substantial present or potential
hazard to human health or the environment when improperly treated, stored, transported,
viii
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
disposed of, or otherwise managed. See Solid Waste and Aqueous Waste for the definitions of
solid waste and aqueous waste, respectively, for the purposes of these recommendations.
Improvised Nuclear Device (IND) - An explosive nuclear device with energy measured in
kilotons (a small fraction of Cold War-era nuclear weapons) that can be detonated with no
warning.
Incident - An occurrence, caused by either human action or natural phenomena, that may
cause harm and may require action. Incidents can include major disasters, emergencies,
terrorist attacks, terrorist threats, wild and urban fires, floods, spills of hazardous materials,
nuclear accidents, aircraft accidents, earthquakes, hurricanes, tornadoes, tropical storms, war-
related disasters, public health and medical emergencies, and other occurrences requiring an
emergency response.
Incident Command System (ICS) - A standardized on-scene emergency management construct
specifically designed to provide for the adoption of an integrated organizational structure that
reflects the complexity and demands of single or multiple incidents, without being hindered by
jurisdictional boundaries. ICS is a management system designed to enable effective incident
management by integrating a combination of facilities, equipment, personnel, procedures, and
communications operating within a common organizational structure, designed to aid in the
management of resources during incidents. ICS is used for all kinds of emergencies and is
applicable to small as well as large and complex incidents. ICS is used by various jurisdictions
and functional agencies, both public and private, to organize field-level incident management
operations.
Initial Response - Actions taken immediately following notification of a contamination incident
or release. In addition to search and rescue, scene control, and law enforcement activities,
initial response may include initial site containment, environmental sampling and analysis, and
public health activities such as treatment of potentially exposed persons. These initial response
activities are typically performed during the early phase of the response.
Intermediate Phase - The period beginning after the source and releases have been brought
under control (has not necessarily stopped but is no longer growing) and reliable environmental
measurements are available for use as a basis for decisions on protective actions and extending
until these additional protective actions are no longer needed. This phase may overlap the early
phase and late phase and may last from weeks to months.
Isolation Distance - Defined as the circular evacuation distance related to dangerous upwind
and life-threatening downwind.
Key Resources (KR) - As defined in the Homeland Security Act, publicly or privately controlled
resources essential to the minimal operations of the economy and government.
Late Phase - The period beginning when recovery actions designed to reduce radiation levels in
the environment to acceptable levels are commenced and ending when all recovery actions
have been completed. This phase may extend from months to years. A PAG level, or dose to
avoid, is not appropriate for long-term cleanup.
Low-Level Radioactive Waste (LLRW) - Radioactive waste not classified as high-level
radioactive waste, transuranic waste, spent nuclear fuel, or by-product material as defined in
ix
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
defined in Section lie, (2), (3) or (4) of the definition of by-product material set forth in 10 CFR
20.1003 (per 10 CFR 61.2). LLRW may contain either high or low concentrations of radioactivity.
In general practice, LLRW does not include naturally occurring radioactive material but does
include man-made material.
Liquid Waste Liquid waste is any waste material that is determined to contain "free liquids" as
defined by Method 9095 (Paint Filter Liquids Test), as described in Test Methods for Evaluating
Solid Wastes, Physical/Chemical Methods (SW-846). Compare to "solid waste."
Mitigation - Measures taken to reduce adverse impacts from radiological contamination to
humans and the affected urban and environmental areas.
Mixed Waste - For the purposes of these recommendations, RCRA Section 1004 (41) defines
mixed waste as waste that contains both hazardous waste and source, special nuclear, or by-
product material subject to the Atomic Energy Act of 1954.
National Contingency Plan (NCP) - Also called the National Oil and Hazardous Substances
Pollution Contingency Plan, the plan (40 CFR Part 300) that generally provides a blueprint for
carrying out response actions under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and section 311 of the Clean Water Act. The NCP is
designed to provide for efficient, coordinated, and effective response to discharges of oil and
releases of hazardous substances, pollutants, and contaminants. The NCP describes the
organizational structure and procedures for preparing for and responding to discharges of oil
and releases of hazardous substances, pollutants, and contaminants. The NCP is also the
primary source from which Pre-lncident WMPs should be developed from, and coordinated
with Area Contingency Plans by the regional response teams, including both state and local
response agencies.
Pre-lncident Waste Management Plan - A plan that addresses the management of waste
generated by all hazards, particularly from homeland security incidents ranging from natural
disasters and animal disease outbreaks to chemical spills and nuclear incidents to terrorist
attacks involving conventional, chemical, radiological, or biological agents. Given the amount
and types of waste that can be generated during an incident, this plan is designed to assist
emergency managers and planners in the public and private sectors in preparing for an
incident's waste management needs, regardless of the hazard. For this document, being
intended for a wide area radiological release, a Pre-lncident WMP needs to be developed with
appropriate Federal, State and local response agencies, and incorporated into Area Contingency
Plans to include "pre-established" waste staging areas. Without doing this ahead of time, first
responders will not even know where waste would be considered to be staged within the initial
72 hours of an incident which could result in double handling of waste.
Protective Action Guide (PAG) - The projected dose to an individual, resulting from a
radiological incident at which a specific protective action to reduce or avoid that dose is
warranted.
Radiological Contamination Mitigation (RCM) - In the context of this document, radiological
contamination mitigation means measures taken to reduce adverse impacts of radiological
contamination on people and the environment. RCM is made possible through "containment"
x
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
and "gross decontamination" technologies. Note that RCM is a subset of mitigation activities
undertaken by emergency responders which are measures taken to limit or control the
consequences, extent, or severity of an incident that cannot be reasonably prevented. Note
that although waste management is not specifically included in RCM, many of the activities that
would be used for RCM may also be associated with waste minimization activities, and many of
the "containment" and "gross decontamination" technologies generate waste.
Radiological Dispersal Device (RDD) - Any device that causes the purposeful dissemination of
radioactive material, across an area with the intent to cause harm, without a nuclear
detonation occurring. An RDD is commonly known as a "dirty bomb."
Recovery - Those capabilities necessary to assist communities affected by an incident to
recover effectively, including, but not limited to, rebuilding infrastructure systems; providing
adequate interim and long-term housing for survivors; restoring health, social, and community
services; promoting economic development; and restoring natural and cultural resources.
(From U.S. Department of Homeland Security, National Disaster Recovery Framework, FEMA
publication, September 2011.)
Remediation - Any measures that may be carried out to reduce the radiation exposure from
existing contamination of land areas (urban and environmental) through actions applied to the
contamination itself (the source) or to the exposure pathways to humans.
Remediation Waste - For the purposes of these recommendations, when used in connection
with hazardous waste, all solid and hazardous wastes, and all media (including ground water,
surface water, soils, and sediments) and debris that are managed for implementing cleanup.
The cleanup process presented in these recommendations do not rely on and does not affect
any authority, including the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), 42 U.S.C. 9601 et seq. and the National Contingency Plan (NCP), 40 CFR
Part 300. This document expresses no view as to the availability of legal authority to implement
this process in any particular situation.
Resource Conservation and Recovery Act (RCRA) - A 1976 federal law (42 U.S.C. §6901 et seq.)
that gives the EPA the authority to control hazardous waste from the "cradle-to-grave,"
including the generation, transportation, treatment, storage, and disposal of hazardous waste.
RCRA also set forth a framework for the management of nonhazardous solid wastes. The 1986
amendments to RCRA enabled EPA to address environmental problems that could result from
underground tanks storing petroleum and other hazardous substances. For more information,
see http://www.epa.gov/lawsregs/laws/rcra.html.
Response - Immediate actions taken to save lives, protect property and the environment, and
meet basic human needs (see also Initial Response). Response includes the execution of
emergency plans and actions to support short-term recovery (see Recovery).
Resuspension - Settled matter that has returned to the atmosphere or has been dispersed in
the environment due to physical disturbance.
Safety Zone - Safety or work zones are established primarily to reduce the accidental spread of
radioactive substances by workers or equipment from contaminated areas to clean areas.
Safety zones specify the type of operation that will occur in each zone, the degree of hazard at
xi
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
different locations within the release site, and the areas at the site that should be avoided by
unauthorized or unprotected employees. The three most frequently identified zones are the
exclusion zone (hot zone), the support zone (cold zone), and contamination reduction zone (or
warm zone). Safety zones for first responders to a radiological incident are identified as the
Low-Radiation Zone (<10-100 mR/hr); Medium-Radiation Zone (100-1000 mR/hr); High-
Radiation Zone (1000-<10,000 mR/hr); and Extreme Caution Zone (>10,000 mR/hr).
Solid Waste - Any discarded material that is abandoned, recycled, inherently waste-like, or a
military munition, subject to certain exclusions. See 40 CFR 261.2 for the complete definition.
Compare to "liquid waste" and "aqueous waste" which refer to composition and state of
matter of the waste, which leads to necessarily special approaches to dealing with radiological
waste. RCRA defines the term solid waste as: Garbage (e.g., milk cartons and coffee grounds);
Refuse (e.g., metal scrap, wall board, and empty containers); Sludges from waste treatment
plants, water supply treatment plants, or pollution control facilities (e.g., scrubber slags);
Industrial wastes (e.g., manufacturing process wastewaters and non-wastewater sludges and
solids); Other discarded materials, including solid, semisolid, liquid, or contained gaseous
materials resulting from industrial, commercial, mining, agricultural, and community activities
(e.g., boiler slags). The definition of solid waste is not limited to wastes that are physically solid.
Many solid wastes are liquid, while others are semisolid or gaseous. The term solid waste, as
defined by the Statute, is very broad, including not only the traditional nonhazardous solid
wastes, such as municipal garbage and industrial wastes, but also hazardous wastes. Hazardous
waste, a subset of solid waste, is regulated under RCRA Subtitle C.
Staging Area - A temporary location at or near an incident site that is designated as a support
or cold zone used to stage personnel and equipment for immediate dispatch to the incident site
to support operations. There can be more than one staging area per incident. For the purposes
of this document, there would be two types of staging areas that would be set up: 1) "Response
and/or Equipment/Emergency Personnel Staging Area"; and 2) "Waste Staging/Temporary
Storage Area".
Support Zone (SZ) - The area of the site that is free from contamination and that may be used
safely as a planning and staging area. Also called the cold zone.
Treatment - For the purposes of these recommendations, when used in connection with
hazardous waste, any method, technique, or process, including neutralization, designed to
change the physical, chemical, or biological character or composition of any hazardous waste to
neutralize such waste or to recover energy or material resources from the waste, or to render
such waste nonhazardous, or less hazardous and therefore safer to transport, store, or dispose
of; or amenable to recovery, amenable to storage, or reduced in volume. Treatment is not the
same as "decontamination." (See Decontamination.)
Treatment technology - For the purposes of these recommendations, any unit operation or
series of unit operations that alters the composition of a hazardous substance or pollutant or
contaminant through chemical, biological, or physical means so as to reduce toxicity, mobility,
or volume of the contaminated materials being treated. Treatment technologies are an
alternative to land disposal of hazardous wastes without treatment.
xii
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
WARRP-The Wide Area Restoration and Recovery Program, a DHS-led effort done in
collaboration with other government agencies and the Denver Urban Areas Security Initiative
(UASI) to develop planning documents for chemical, biological, and radiological incidents in the
city of Denver that could be used as starting templates for other communities to use for
planning purposes.
Waste - Material in gaseous, liquid or solid form for which no further use is foreseen.
Waste Acceptance Criteria
Waste Management - For the purposes of these recommendations, the administration of
activities that include, but are not limited to, source reduction, waste minimization, waste
segregation, decontamination, recycling, transport, staging, storage, treatment, and disposal.
Waste Staging - Temporarily storing waste for the purpose of accumulation and sorting to
facilitate transportation, transfer, treatment and/or disposal, and to keep radiological waste
from contaminating non-hazardous waste streams or from causing impacts to public health and
the environment.
Waste Staging Area - A location at an incident site designated for the temporary accumulation
and sorting of radioactive waste and debris until that waste is manifested and shipped to an
offsite disposal facility. In the context of this document (i.e., first 72 hours), the Waste Staging
Area(s), or at least selection criteria for the Waste Staging Area(s) should be "Pre-Designated"
as part of the Pre-lncident Waste Management Plan.
xiii
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
ACKNOWLEDGMENTS
We would like to thank the following EPA staff members, outside organizations, and
contractors for their ongoing participation in this effort:
Cardarelli, John
Hall, John
lerardi, Mario
Jablonowski, Eugene
Lee, Sang Don
Lemieux, Paul
Lynch, Marissa
Magnuson, Matthew
Parrish, Cayce
Pickrel, Jan
Rhame, Ken
Schultheisz, Dan
Snyder, Emily
Steuteville, Bill
Stilman, Terry
Walker, Stuart
EPA Consequence Management Advisory Team
EPA National Homeland Security Research Center
EPA Office of Resource Conservation and Recovery
EPA Region 5
EPA NHSRC
EPA NHSRC
EPA Office of Water
EPA NHSRC
EPA Office of Homeland Security
EPA Office of Water
EPA Region 4
EPA Office of Radiation and Indoor Air
EPA NHSRC
EPA Region 3
EPA Region 4
EPA Office of Superfund Remediation and Technology Innovation
Outside Organizations
Nisbet, Ann United Kingdom (UK) - Public Health England
Stevenson, Ben Department of Homeland Security
Contractors
Battelle Memorial Institute
Booz-Allen Hamilton
CSS-Dynamac
xiv
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
This page is intentionally left blank.
XV
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
1. BACKGROUND
The U.S. Environmental Protection Agency (EPA) is working with the U.S. Department of
Homeland Security Science and Technology Directorate (DHS S&T) to strengthen the Homeland
Security Enterprise by performing a project to support first responders for radiological
incidents.1 This project focuses on four tasks: (1) methods for radiological contamination
mitigation (RCM) via "containment" which prevents the resuspension and subsequent
dispersion of radiological particle contamination, (2) methods for radiological contamination
mitigation via "gross decontamination" which physically removes radiological contaminants
from impacted areas of interest, (3) methods of early phase (first 72 hours) staging and storage
of radiological waste, and (4) development of a software application to help facilitate early
decision-making regarding containment, decontamination and waste storage/disposal during a
wide-area radiological incident.
A recurring theme in this document concerns the whole concept of waste management
activities that would occur during the early phase (first 72 hours) of an incident. During the
early phase of an incident, the first responders will not be performing waste management
activities to any great extent. There are, however, two main aspects of waste management that
will apply during the early phase of an incident:
• From a planning perspective, a Pre-lncident Waste Management Plan (WMP) should be
developed to address all aspects of waste management in the context of a system-of-
systems where inter-related decisions cascade throughout the response; this WMP will
contain elements that may impact or be impacted by activities the first responders take
during the early phase of the response; and
• From an operational perspective, decision making regarding waste management will begin
during the early phase of the response, as the Pre-lncident WMP is implemented.
Implementing waste staging operations will not likely occur during the first 72 hours of a
response, however, using criteria developed in the Pre-lncident WMP to identify incident-
specific areas for waste staging operations may indeed occur during the first 72 hours of a
response. For radiological incidents, conducting waste staging without conducting Pre-
lncident Waste Management Planning and coordinating that plan with the overall response
plan may result in health impacts to first responders, as well as longer term impacts to
public health and the environment.
Containment (task 1 listed above) and gross decontamination (task 2) approaches for
radiological containment mitigation after wide-area radiological contamination incidents are
under study. They are briefly described in Appendix A and will be presented separately with the
software application "app" (task 4) housing the waste management information summarized in
this document. It should be noted that since the first-responders would probably not be
actually performing waste staging operations during the early-phase of a response, this
documents inclusion in the app will be as a linked reference, since the target audience for this
1 DHS website: http://www.dhs.aov/homeland-securitv-enterprise. accessed February 28, 2015.
1
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
document is not the first responders themselves, but the waste management decision makers
who will be making decisions in parallel with the first-responders. This document focuses on
methods to incorporate waste staging into Pre-lncident planning, as well as to support waste
management decision makers for staging and temporary storage of radiological waste (task 3),
with the intent to provide decision-makers with recommendations and best practices for initial
waste handling and staging that could be implemented in the early phases of a response to a
wide-area radiological incident (in parallel to the first-responders' early-phase activities). Waste
staging can be defined as the process by which space is allocated for sorting waste into
different waste streams, isolating radioactive waste in order to keep it from contaminating non-
hazardous waste streams, and storing waste until disposal capacity becomes available. These
incidents could include nuclear power plant (NPP) accidents as well as detonation of
radiological dispersal devices (RDDs), otherwise known as "dirty bombs," or Improvised Nuclear
Devices (INDs). Note that NPPs have their own response plans which may or may not include
considerations of waste staging and temporary storage. It is hoped that waste management
would be included in the NPP response planning.
Clean up of cesium-137 is the primary focus of this document, due to its ability to move easily
throughout the environment; however, other radionuclides could contribute to a
contamination incident and these recommendations can be applied to those radionuclides.
These operational recommendations provide multi-level (federal, state, territorial, tribal and
local) response/recovery information for wide-area radiological releases, are intended to be
general in nature, and could be used in a multitude of settings (i.e., applied nationwide,
including urban environments).
Although waste management is typically viewed as a function associated with later phases of
the response and recovery, waste will start being generated almost immediately after the initial
contaminating incident and as a result, "pre-incident" waste management planning to include
early phase staging of waste is needed. Waste management decisions made by first responders
during the early phase of the response may impact waste management options available later
in the response/recovery process as well as impact the overall cost, timeline, and difficulty of
the recovery to come.
To support this project, an extensive literature review of waste management topics related to
other types of wide area disasters, such as natural disasters, including exercises and incidents
related to wide area radiological contamination, such as NPPs, RDDs, or INDs was performed.
The review also included the identification of waste staging procedures (task 3) directed at
radiologically contaminated waste. In addition, the Radiological Mitigation and Waste
Management Stakeholders Workshop was held on April 1-2, 2014, in Arlington, Virginia. The
meeting goals were: (1) to develop a shared understanding of existing knowledge in the area of
early phase mitigation and waste management activities, (2) to obtain stakeholder input on
what specific containment and mitigation technologies should be tested and how to test them
in a realistic manner, and (3) to obtain stakeholder input on needs for waste management
guidance and the Radiological Gross Decontamination and Waste Management First Responder
2
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Application (Radiation Decon Application). Following the April 2014 meeting, five
representative cities were initially chosen for visits/meetings in an effort to engage
stakeholders further. The cities were chosen after considering criteria such as city size, climate,
emergency response experience, radiological experience, and other resources available. One
small city, one medium city, and three large cities were chosen based on these criteria and
discussions among a group of EPA regional contacts and members of the proposed software
development team. Of five cities initially considered, the three cities visited were Burlington,
Vermont; Charlotte, North Carolina; and Los Angeles/Long Beach, California. The three city
visits took place in mid- to late-June 2014.
Collectively, more than 60 stakeholders attended
the meetings ranging from firefighters, health care
officials, health and safety officials, health
physicists, civil support personnel, bomb squad
personnel, nuclear power plant emergency
planners, and HAZMAT specialists to interested
scientists and responders. In each of the cities,
stakeholders agreed that an electronic software
application ("app") that could be used to assist
with decision-making regarding radiation
decontamination and waste management in the
early phases of an incident would be useful. The
information from this document is intended to be
included in the app, once completed, however, it
is likely that the information will be provided as a
link because the first-responders may not be
making waste management decisions during the
early phase of a response (they may, however,
require background information to place waste
management into perspective with the wider response). Many stakeholders did note that the
application would likely be more useful for response personnel that staff Emergency Operations
Centers (EOCs) rather than for firefighters or other first responders whose principal initial role
during a large-scale radiation incident response would be safeguarding lives. Rather, the state
and local waste management and radiation control authorities will be making waste
management decisions to implement Pre-lncident Waste Management Planning documents in
parallel with the emergency response operations that the first responders will be performing.
1.1 Purpose of the Operational Recommendations
The purpose of this document is to provide general information directed at pre-planning waste
management, primarily early phase (first 72 hours after onset of the incident) staging and
storage of radiological waste for a user audience that may include first responders, emergency
management planning organizations, qualified radiological cleanup contractors, or recovery
personnel involved in response/recovery operations. Based on input from the stakeholder
workshop and the three-city meetings, the operational recommendations developed for this
project will be formatted suitably for inclusion in the application software that is also being
A Radiological Mitigation and Waste
Management Stakeholders Workshop was
held on April 1-2, 2014. Thirty-five
meeting attendees representing a wide
range of federal, state, and local
government, international organizations,
health care professionals, emergency
response personnel, and academia
participated in the two-day meeting.
Participants of the meeting shared
knowledge, explored differing opinions,
and expanded understanding of the
current state and future research and
technology needs for the areas related to
early phase radiological responses. The
overwhelming consensus at the workshop
was "the need" for waste management
operational guidelines following an
incident of this nature.
3
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
developed, and will become an important consideration in local, state, and federal decision-
making. Information in this document may be helpful as Pre-lncident WMPs are produced as
well as while the plans described in the Pre-lncident WMP are carried out.
This document leverages previously published information by EPA and other federal agencies,
as well as institutional knowledge gained from existing programs such as EPA's Superfund
program and from recent large-scale incidents (Hurricane Katrina, Deepwater Horizon,
Fukushima, etc.). In addition, the audience (see Section 2.1) intended to use this document also
has access to online guidance and handbooks that may be considered when responding to a
radiological incident. See the reference section for complete citations for relevant guidance and
handbooks.
1.2 Why These Recommendations are Necessary
DHS National Planning Scenario 11
describes a hypothetical radiological attack
with an RDD in a moderate-to-large U.S. city
(DHS, 2006). After the initial lifesaving
activities occur in response to a radiological
incident, first responders may be
responsible for initial efforts to contain the
contamination, perform gross
decontamination of vehicles and
equipment, and temporarily stage waste
(e.g., used personal protective equipment
[PPE], decontamination wash water). All waste and debris removal activities (e.g., waste staging
area management and coordination) will be coordinated by the Incident Command/Unified
Command (IC/UC) (state and local agencies, as well as other federal agencies) and will be
consistent with or coordinated with pre-incident WMPs and address state or local requirements
developed as part of the RDD incident preparation. Given the differences between debris and
waste, FEMA guidelines for debris (FEMA, 2014) may not be applicable to waste management.
Therefore, the recommendations in this document for initial waste staging are adapted from
FEMA guidelines for debris management, with the understanding that a radiological incident
may require more space. The incident may involve different types of wastes (liquid versus
solid), mixed versus hazardous or non-hazardous. If these nuances are not accounted for in the
Pre-lncident WMP, there is a chance that the waste may not be handled properly causing
additional delays, costs, and potentially exposures to the public or first responders.
These "operational recommendations" have been developed as part of an overall "Pre-lncident
Waste Management Planning Process", to facilitate identification of specific sites for waste
staging that may have been not specifically defined in Pre-lncident WMPs, and to aid as those
sites are prepared. Proper identification of waste staging sites is important, otherwise, waste
might be subjected to multiple handling, which increases the potential impact on the health of
the first responders, the public, and the environment.
Regulations and permitting procedures for
these activities may need to take advantage
of state authorities that allow for emergency
approvals. Most state regulations allow for
such emergency approvals. It is important
that this be planned ahead of time so that the
appropriate coordination and approvals take
place among all the stakeholders who will be
involved in the waste management activities.
4
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Plans developed before the incident may need to be modified to meet the needs of the specific
incident. In all cases, RDD waste management will involve creating nearby temporary waste
staging and storage locations. For example, as part of the Liberty RadEx exercise, a
comprehensive WMP was developed for RDD wastes, including options for waste staging and
disposal for all waste streams. It should be noted that in the Liberty RadEx exercise, these
activities did not take place during the first 72 hours after the incident. In addition, successful
waste management activities required the appropriate State and local (city public works)
people working on the Pre-lncident WMP who knew about the city. This again substantiates
that a Pre-lncident WMP, developed by the right people ahead of time and coordinated with
Federal, State and local agencies as part of the Area Contingency Plan in accordance with the
National Contingency Planning process is what is needed.
Most immediate injuries from a radiological incident, such as an RDD incident, are likely to
occur from the explosion of the bomb (heat, debris, and force); such attacks immediately affect
individuals close to the site of the explosion and contaminate nearby areas with large amounts
of radioactive particles. Health risks include the trauma associated with being caught in the
explosion itself and the potential for increased risk of cancers attributable to (1) long-term
exposure to increased amounts of residual radiation and (2) acute inhalation and ingestion of
high concentrations of contaminated particles. Following a radiological release, re-suspension
and tracking of contamination may complicate containment of the contaminated area and
create additional exposure to the first responders. As a result of this and what the State and
local individuals at the workshop identified as their priorities in the first 72 hours, it will be
important that Pre-lncident WMPs address wastes being generated from medicals facilities and
personal/mass decontamination operations as an early phase activity. An example of an RDD
scenario is described in Section 7. As part of the Wide Area Recovery and Resiliency Program
(WARRP), guidance was developed to reduce the time and resources required to recover a wide
urban area (specifically, Denver) following a chemical, biological, or radiological incident,
including meeting public health requirements and restoring critical infrastructure (CI), and key
resources (KR) (both civilian and military) and high-traffic areas.
Zones of contamination are identified based on the degree of actual or potential contamination
and the radiation levels in the area.2 Defining zones in this manner can be a useful approach to
planning and executing a response, including predicting casualties and medical needs,
determining where to locate waste staging areas, and understanding where to expect damage
to select the appropriate staging area(s) where federal assets can be optimally located.
Containment and gross decontamination actions that may help to mitigate impacts of these
issues (See Appendix A) include, for example, (1) securing the area within identified isolation
distances, (2) setting up a single egress and ingress route, and (3) minimizing the amount of
contaminated equipment and vehicles leaving the contamination reduction zone (CRZ) or
"warm zone." This zone is also where first responders enter and exit the hot zone and where
decontamination activities take place.
2 U.S. Department of Health and Human Services (HHS), Radiation Control Zones and Perimeters Recommended by Various
Agencies for Responding to Radiological Emergencies http://www.remm.nlm.gov/zones radincident.htm. accessed March 24, 2015.
5
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
2. SCOPE OF THE OPERATIONAL RECOMMENDATIONS
Lessons learned during natural disasters
emphasize the need for pre-incident waste
management planning to address the
complexities of radiological incidents,
otherwise one risks handling waste several
times, increasing the cost and risk of
exposure to workers and the public, or
treatment/ storage/ disposal facilities may
not be available when needed. These
operational recommendations focus on
early phase waste staging activities (staging
refers to temporarily storing waste so that
separation, pre-treatment, packaging, and
other waste management activities can be
performed at a designated location away
from the primary response activities) in the
context of the complex system of activities occurring during the response. Prior to the
response, it is anticipated that some degree of pre-incident waste management planning and
preparation has been conducted. The definition of the "early phase" of a response may vary
based on the incident, but for this document generally includes the first 72 hours.
Beyond the initial life-saving operations immediately following a radiological incident,
responding to such an incident may involve containment, gross decontamination and
mitigation, and waste management. Waste is generated after the initial contaminating incident
and as soon as the first responders enter the area of contamination ("hot zone").3 Most
activities related to casualty management, medical care, personnel decontamination,
containment of contaminants, and gross mitigation will generate waste, which is why pre-
incident waste management planning and preparation is important (discussed in Section 3.1).
From an overall response strategy, it will be of utmost importance to prevent waste
management issues from interfering with the path to recovery. In standard project
management parlance, it is important to remove waste management from the critical path to
recovery.
Early Phase (generally within the first 72 hours)
is defined as the beginning of a radiological
incident when immediate decisions for
effective use of protective actions are required
and must therefore be based primarily on the
status of the radiological incident and the
prognosis for worsening conditions. When
available, predictions of radiological conditions
in the environment based on the condition of
the source or actual environmental
measurements may be used. Protective actions
based on the Protective Action Guides (PAGs)
may be preceded by precautionary actions
during the period.
3 Zones are identified based on the degree of actual or potential contamination and the radiation levels in the area:
http://www.remm.nlm.gov/zones radincident.htm. accessed March 24, 2015.
7
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
2.1 Intended Audience
The intended audience ("user") of the application could potentially include first responders
(fire, police), EOC director/personnel, IC/UC, federal response personnel, public health officials,
nuclear power plant emergency planners,
etc. The user audience is intended to be
broad because many decision makers
have specific roles during a radiological
incident. For example, not all first
responders are HAZMAT specialists, and
not all the audience may be experienced
in handling low-level radioactive waste. If
the waste is handled improperly during
the first 72 hours, it can end up costing
more time and money and potentially
increase radiation exposure of the public and first responders. The uniqueness of how these
types of waste is regulated needs to be recognized. It is also important to recognize the
different agencies involved in LLRW to include the NRC for NPPs and whatever existing NPP
emergency response plans that exist. Urban responders may have more training and expertise
than responders in rural areas. It is critical that decision-makers establish a site-specific pre-
incident WMP before an incident occurs.4
2.2 Response Management and Agency Roles and Responsibilities
In the United States, all levels of government - federal, state, territorial, tribal, and local -
respond to disasters. Federal agencies provide critical assistance to state, tribal, territorial, and
local response organizations in the event of a disaster that overwhelms state and local
capabilities. The National Response Framework (NRF) (DHS, 2013) provides guidance for
response functions immediately following a disaster. For radiological incidents, the policies,
situations, concept of operations, and responsibilities of federal agencies as well as potential
roles (but not in a proscriptive manner) of local, tribal, territorial, state governments, and
private entities are described in the Nuclear/Radiological Incident Annex (NRIA) to the NRF. The
NRIA applies to two categories of radiological incidents: (1) inadvertent or otherwise accidental
releases (such as NPP accidents) and (2) releases related to deliberate acts (such as RDDs or
INDs). These incidents may also include a potential release of radioactive material that poses an
actual or perceived hazard to public health, safety, national security, and/or the environment.
Given the differences of these types of radiological incidents, different early phase practices
may need to be applied.
The NRIA sets out the roles of primary federal radiological response and support agencies such
as the U.S. Department of Energy (DOE), the U.S. Nuclear Regulatory Commission (NRC), the
U.S. Department of Defense (DoD), the U.S. Department of Health and Human Services (HHS),
4 Resources to develop a WMP can be found here: http://www.epa.gOv/osw/homeland/plan.htm#contents. accessed January 14,
2015.
As part of pre-incident planning, reaching out to
first responders with specialized capabilities and
proper training and knowledge is important. After
a radiological incident, there will be a need for
identifying isolation distances, radiation exposure,
and contamination levels. Specialized capabilities
and proper training and knowledge all play a part
in "pre-incident" waste management planning and
early phase waste staging.
8
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
EPA, DHS, and the U.S Department of Agriculture (USDA). The Federal Radiological Monitoring
and Assessment Center (FRMAC) is a multi-agency response asset to assist state and local
officials with monitoring, assessment, and health guidance for radiological incidents. DOE leads
the FRMAC (along with representation from DHS, EPA, and DoD) for the initial early phase and
intermediate-phase response for incidents involving nuclear/radiological materials, while EPA
leads the FRMAC for long-term response (after the early phase) (FEMA, 2008). For large
incidents, FRMAC transition is likely to occur sometime during the intermediate phase5, and
Pre-lncident WMPs need to be coordinated with local and state agencies, but also the federal
agencies involved in the response (DHS, FEMA, DOE, NRC, HHS, and EPA).
Recognizing that every incident is unique (see Section 2.2.1 for one example) and that decisions
will likely be made under the auspices of an incident command structure (see Figure 1 below),
this document describes recommendations that could be applied to a radiological incident (i.e.,
NPPs, RDDs, or INDs) and highlights the advantages and disadvantages of those
recommendations, without being prescriptive. Any reference to a response or recovery process
described in this document does not rely on and does not affect any authority including CERCLA
and the NCP. This document expresses no view as to the availability of legal authority to
implement this process in any particular situation.
2.2.1 Radiological Dispersal Device (RDD) Incident Example
Procedures currently exist for developing appropriate temporary staging and storage areas for
waste from natural disasters and other conventional incidents; however, these procedures do
not address the many unique considerations associated with RDD or IND scenarios, especially
wide-area urban release scenarios, as called out in the National Planning Scenarios.6
Disadvantages with current procedures include very limited final disposal options, difficulty in
finding adequate short term staging locations within urban environments, economic impacts
that could exceed any incident that the country has ever had to respond to, public concerns of
the staging of waste, and the importance of the interrelation of decisions made about
decontamination, sampling, and waste management. In addition, because of the type of
contamination, one has to consider that consolidating the waste may increase its activity,
thereby causing additional exposure. This makes it much more difficult. You cannot just apply
typical waste processing procedures without considering the potential exposure being caused
by consolidating the waste. It may require shielding from waste handlers, haulers, first
responders, and/or the public.
For an RDD incident, the roles and responsibilities of local, tribal, territorial, state, and federal
governments and private entities are set out in the NRIA. Response to an RDD will be managed
using the incident command system (ICS) based on the National Incident Management System
(NIMS) (DHS, 2008a). ICS is a standardized, on-scene, all-hazards incident management
approach allowing its users to adopt an integrated yet flexible organizational incident command
5 Five criteria have been developed to determine when the transfer is appropriate (see
http://www.nv.doe.aov/librarv/publications/frmac/FRMAC%20Division/FRMAC-EPA%20Post%20Emeraencv/FRMAC Transfer.pdf).
Accessed March 1, 2016.
6 Specific information about National Planning Scenarios associated with a RDD or IND can be found at:
https://www.llis.dhs.gov/sites/default/files/NPS-LLIS.pdf. accessed January 14, 2015.
9
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
structure (Figure 1) to match the complexities and demands of single or multiple incidents,
including multi-agency and multi-jurisdictional responses. ICS allows facilities, equipment,
personnel, procedures, and communications to be integrated and operated within a common
organizational structure. ICS coordinates response among various jurisdictions and public and
private entities and establishes a common process for planning and managing resources. ICS
includes both Command Staff and General Staff. General Staff is broken into four sections: (1)
Operations, (2) Planning, (3) Logistics, and (4) Finance/ Administration. An IC/UC is typically
used for the command function of multi-jurisdiction ICS response; an IC/UC consists of the
appropriate local, state, and federal incident commanders representing the principal
jurisdictions and lead agencies. IC/UC has proven to be a highly effective means of managing
multi-agency and multi-jurisdictional responses. A strong coordinated IC/UC will be
instrumental in overcoming the challenges of radiological waste management. Figure 1 shows
an example of the ICS/IC/UC structure following an RDD incident.
Because waste management is a major RDD response challenge, the ICS will have Operations
and Planning Sections that are assigned waste management-related responsibilities that occur
from the early phase through the intermediate and later phases of the response7. Although the
primary intent of this document is to be useful as Pre-lncident WMPs are developed (before the
incident) and the waste staging operations are identified and located (during the early phase of
the incident), much of the waste staging activities described herein would be done during the
intermediate- and late-phase of the response. The ICS organizational structure may include, for
example, a Disposal Division or Group in the Waste Management Branch of the Operations
Section and a Waste Management Group in the Environmental Unit of the Planning Section.
The Operations Section Waste Management Branch is responsible for collecting, staging,
characterizing, documenting, shipping, and/or treating all wastes generated or collected on-site
during field activities, including radiological wastes, solid wastes, liquid wastes, and other
hazardous materials generated by such activities. Waste management can also include on-site
disposal and design and fabrication of temporary or permanent storage/disposal facilities. The
Planning Section Waste Management Group is responsible for conducting waste planning,
identifying waste treatment and disposal options, obtaining appropriate waste disposal
approvals, working with policy/regulatory authorities, etc.
In responding to an RDD incident, the Environmental Unit should include or consult with local
and state waste regulators, federal waste regulators (including the EPA Office of Resource
Conservation and Recovery [ORCR] and NRC waste personnel), state and local officials, and
private disposal facilities in waste planning. Cleanup and waste planning discussions should also
include state water regulators, local wastewater and drinking water treatment facility
operators, and the public. These initial discussions may have a profound effect on waste
staging, screening, segregation, treatment, transportation, and disposal that will occur as the
the staging sites are identified and response progresses to the intermediate and late phases.
7 It is advisable to have an integrated waste management group made up of representatives from EPA, NRC, DoD, DOE, state/local
water and solid/hazardous waste management authorities, and appropriate State Radiation Control Officers.
10
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Command Staff
General Staff
Public Information
Officer
Operations
Section Chief
Liaison Officer
Safety Officer
Unified
Command
Planning
Section Chief
Logistics
Section Chief
Finance/
Administration
Section Chief
Figure 1. Example of Incident Command Structure for RDD Incident.
3. PLANNING ASSUMPTIONS
These operational recommendations are based on several planning assumptions related to the
appropriate identification of waste staging areas that are large enough to allow for temporary
storage of waste, on-site treatment, packaging, and segregation during the early phases (i.e.,
within the first 72 hours) of the response. Note that it is unlikely that significant quantities of
waste would require transportation during the first 72 hours of an incident. It is important to
understand the basic nature of a radiological incident and the factors that guide response and
recovery following the incident. Recognizing that planning is unlikely to capture all the
contingencies that may arise during an incident, this document will not be regulatory guidance,
but rather will present options and relevant technical information, along with advantages and
disadvantages that could be applied by first responders and decision-makers based on incident-
and site-specific considerations.
It is important to recognize that the recommendations in this document are likely to be part of
a framework of an overall integrated containment/decontamination strategy and WMP for the
response and recovery. Strategies and plans will depend on factors such as the exact nature of
the contaminant and the size of the contaminated area, the statutory and regulatory
framework governing the response, the timeline within which the response is operating, the
resources available to implement the response, cleanup goals, and decisions on final disposal
locations. Regardless, waste management decisions must protect public health and the
11
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
environment.8 These and other factors affecting the response involve important policy
considerations, which are beyond the scope of this document to address.
Waste handling and staging decisions must protect public health and the environment, and the
community potentially receiving the waste should be provided with an opportunity to provide
meaningful input on receiving radioactive waste. As part of the Liberty RadEx exercise, a
committee of Philadelphia citizens was able to reach consensus on their own cleanup
prioritization and local staging/storage (DOE, 2012a), but these discussions occurred much later
than the early phases of the response for the purposes of Liberty RadEx. In fact, these
discussions were one of the primary motivations for performing the work described in this
document, highlighting the need to not only include waste staging as a critical piece of Pre-
Incident Waste Management Planning, but observing that pre-identification of specific waste
staging sites may be controversial to include in the Pre-lncident WMP; however, identification
of criteria that could be used to select the waste staging sites was not as controversial
3.1 Pre-lncident Waste Management Planning
Nearly every incident involving contamination will
generate waste. The amount of waste generated
will vary, but for many of these incidents, the
amount of waste generated may be greater than
the amount of waste many communities typically
handle in a year. In addition, homeland security
incidents may generate waste streams (e.g.,
chemically, biologically, and radiologically-contaminated wastes) that are not typically handled
by the local communities or waste management facilities. For the purposes of these
recommendations, finding treatment and disposal facilities to accept radiologically
contaminated wastes may be challenging. Therefore, pre-incident planning is very important.
Communities should develop a WMP detailing how they will manage the potential
radiologically-contaminated wastes before an incident occurs. The key elements for a Pre-
lncident WMP follow.
I. Plan Overview
a. Scope
b. Planning assumptions
c. List of officials who should be notified in the case of an incident
d. Regulatory requirements
e. Record of plan reviews and updates
II. Materials and Waste Streams
a. List of anticipated waste streams
b. Description of each waste stream
8 See Statement of Michael Shapiro, then Principal Deputy Assistant Administrator, Office of Solid Waste and Emergency Response
(OSWER), before the U.S. Senate Committee on Environment and Public Works (July 25, 2000). Also see related letter from Robert
Perciasepe, then-EPA Assistant Administrator of the Office of Air and Radiation, and Timothy Fields, Jr., then-Assistant
Administrator of the Office of Solid Waste and Emergency Response, to The Honorable Clint Stennett, Minority Leader, Idaho State
Senate, June 26, 2000.
The concept of pre-incident waste
planning and preparation is important
and supports early phase waste staging.
Waiting until the incident to have a
WMP is too late.
12
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
III. Waste Quantities
a. Forecast quantity of each type of anticipated waste
b. Method for estimating actual waste quantities during/after incident
IV. Waste Characterization Sampling and Analysis
a. Sampling
b. Analysis
c. Quality assurance
V. Waste Management Strategies/Options
a. General principles
i. Minimization (actions to minimize waste generation, toxicity, physical size)
ii. Collection (procedures; health and safety requirements)
iii. Segregation (procedures)
iv. Decontamination (people, equipment, waste/materials; health and safety
requirements)
v. Accumulation/Storage (site location selection criteria; documentation; health
and safety requirements)
b. Pre-selected waste management sites
i. Waste staging and storage (temporary and permanent) locations
ii. Equipment staging and storage (temporary and permanent) locations
iii. Decontamination stations
VI. Waste Management Facilities
a. Anticipated types of waste management facilities needed
b. Specific facilities identified
VII. Transportation
a. Logistical options
b. Routes (including maps)
c. Hauler information
VIII. Waste and Material Tracking and Reporting System
a. General principles
b. Databases or other tracking software to be used
c. Waste tracking report templates
IX. Community Communications/Outreach Plan
a. Contact information for key stakeholder groups
b. Pre-scripted information for waste management activities involving the public
c. Information for a response website
X. Health and Safety for Waste Management Activities
XI. Resource Summary
a. Resource needs
b. Resource sources
i. Mutual Assistance Agreements (MAA)
ii. Pre-negotiated contracts
c. Specialized Technical Assistance Contacts
d. Contracting
i. Emergency procurement procedures
13
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
e. Contract oversight plan
f. Cost Accounting/Financial Management
g. FEMA Cost Reimbursement Forms and Guidance
XII. Oversight Activities and Exit Strategy
A health and safety (H&S) plan is a critical component to waste staging. The objective of the
H&S plan is to assure that all work conducted is performed as safely as possible. The H&S plan is
site specific and involves conducting a hazard assessment to identify and evaluate all potential
risks.
3.2 Scalable and Adaptable Strategies
A radiological incident has unique dimensions and characteristics requiring that response plans
and strategies be flexible enough to address emerging needs and requirements effectively. For
example, a radiological incident may include other hazards such as chemical or biological
contaminants, or physical hazards like fire or unstable structures, which may require concurrent
implementation of other local, state, and federal plans and procedures.
In response to a large-scale RDD incident, resources such as equipment and personnel are
expected to be assigned to various waste staging areas to join teams or to be deployed. Some
limiting factors for scaling this type of deployment include the availability of resources, the
number and size of staging areas, and physical constraints such as the actual size of the affected
area.
3.3 Types of Resources Needed
Personnel resources will be needed during a radiological incident. Depending on where the
incident occurs and how large it is these people may not be available. This further highlights the
need to address these key personnel resource issues in a Pre-lncident WMP. It is likely that
more responders will be needed in an urban setting because contamination will be
concentrated through entrainment by the densely packed buildings. Local response capabilities
and resources may be insufficient and quickly overwhelmed. It is possible that some local
emergency personnel who normally respond to incidents may be among those affected and
unable to perform their duties following the radiological incident. Resources should include
federal, state and local subject matter experts in areas that support waste management
activities (such as emergency planners/managers, public works operators, water and
wastewater treatment operators, sanitation, public health information officers, local
professional organizations), as well as unique resources like contractors capable of handling
radiological waste issues (pre-placed contracts, mutual aid agreements, etc.) and equipment for
personnel and public radiation monitoring.
14
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
4. CONCEPT OF OPERATIONS
Handling a radiological incident is unique compared to an incident involving other hazards such
as chemical or biological hazards. If every incident, lifesaving activities take priority over
decontamination. Radiation dose to first responders is of paramount importance but can be
managed so first responders can complete
critical activities (i.e., assuring public health and
safety goals are compatible with the criminal
investigation of a terrorist attack). Unlike
chemical and biological agents, which can usually
be altered or destroyed to eliminate or reduce
toxicity and infectivity, radiological materials
cannot be destroyed.
While the focus for response and recovery after a radiological incident will be on cleanup,
effective strategies for waste management in the early phase will also be required. These
strategies include:
• Identification of appropriate waste staging areas that are large enough to allow for
temporary storage of waste;
• On-site treatment and packaging; and
• Transportation to the final disposal.
The strategies presented will not minimize the size of the cleanup itself as that is dictated by
the amount of the urban area that is contaminated, the level of radioactivity, and concerns for
resuspension of contamination due to atmospheric events, human activity, or precipitation.
Implementing these strategies can potentially expedite and minimize cleanup and recovery
times by improving cleanup efficiency, reducing waste volume, maximizing the segregation of
waste into homogeneous waste streams, and separating higher-activity materials from lower-
activity materials.
4.1 Importance of Waste Staging
Identification of appropriate waste staging areas that are large enough to allow for temporary
storage of waste, on-site treatment and packaging, and transportation to the final disposal
destination will include a set of decisions made during (and often prior to) the early phases of
the response. The total quantity, activity, and type of waste, along with which technologies are
being used for containment and mitigation during the early phase, will largely determine the
requirements for waste staging areas. These staging areas will be selected in the context of the
rest of the response, including personnel deployment activities, transportation of response
personnel and equipment into and out of the safety zones, and activities intended to
repopulate evacuated areas and resume economic activities.
Identifying temporary storage sites has been identified as an obstacle when initiating waste
management activities. This becomes even more complex when dealing with radiological waste
management options. The lack of final disposal options (i.e., limited availability of disposal sites)
makes locating early phase staging areas for waste critical, especially within an urban
A strategy that is likely in the early
phase is a temporary transfer location.
There is no assurance that an incident
will occur in the most convenient
location with regard to pre-selected
staging areas.
15
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
environment. Planning to procure staging/temporary storage sites is best done before an
incident so that arrangements such as leases and permits for the land can be accomplished
quickly. Having waste staging sites available in advance gives a jurisdiction additional time to
develop diversion strategies and programs to handle the waste from the incident and can help
prevent repeated handling of this waste.
5. WASTE MANAGEMENT
For the purposes of this document, debris and waste are used somewhat interchangeably, but
in general, debris refers to co-mingled materials that are generated due to some sort of
destructive force, whereas waste refers to discarded materials in general, including co-mingled
materials as well as materials that may be relatively undamaged. Waste is the broader term;
debris is a subset of waste that refers to damaged materials that are not easily amenable to
separation processes.
Early phase waste management is an integral part of cleanup planning and response operations
during all phases of response and recovery. During the early phase, waste management
activities may largely be confined to the activation of waste staging areas and staging of waste
generated. Waste is expected to be generated as soon as the first responders arrive at the site;
therefore, it is just a matter of "activating" the locations that have been pre-identified as part of
a larger pre-incident WMP to temporarily stage waste and debris. During the early phase, waste
management should consist of supporting first responders by removing debris that could cause
an immediate threat to public safety (e.g., unstable structures), clearing roadways, and
removing fallen limbs and curbside debris that may hinder emergency vehicle movement along
access pathways and egress routes.
The selection of appropriate waste staging areas that are large enough to allow for temporary
storage of waste, on-site treatment and packaging, and transportation to the final disposal will
depend on total quantity, activity, and type of waste, along with which technologies are being
used for containment, gross decontamination and mitigation during the early phase. Given that
each situation will be unique, it should not be assumed that all waste and debris will be
declared contaminated.
It will also be important to identify and determine, hopefully prior to the incident, available
waste management facilities and to determine and establish waste acceptance criteria (WAC)
for those facilities. If site personnel (either emergency responders or the personnel from the
waste facilities) know the WAC ahead of time, field surveys could create a site model that
correlates portions of the site with the WAC for the various disposal facilities and level of
hazard associated with the waste (low, very low, etc.). If Low-Level Radioactive Waste (LLRW) is
going to be sent to a LLRW facility outside of a state's LLRW compact, appropriate approvals
will be necessary. Having these pieces of information prior to the incident will be useful during
the first 72 hours after the incident to help the decision making process to site waste
staging/temporary storage facilities. Again, it will not be the first responders making these
decisions, but they will be impacted by these decisions.
16
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
5.1 Waste Type
Depending on the radiological incident, differences in waste types are likely which pose an
inherent challenge. For example, a wide area
radiological incident could potentially result in the
generation of millions of tons of solid waste and
billions of gallons of aqueous waste, all lightly
contaminated with radionuclides. Generally,
physical damage outside the blast zone is expected
to be minimal, and the amount of blast-related
debris is likely to be relatively small compared to
the amount of undamaged contaminated
materials. It is probably not possible to
systematically segregate contaminated waste
during the early phase, which includes debris, from uncontaminated waste from a wide-area
radiological incident.9 However, decisions made during the early phase of the response may
facilitate these segregation activities in the later phases of the response.
A radiological incident like an RDD will likely result in a small area containing high-
concentration/high-activity wastes within the hot zone found immediately surrounding and
immediately downwind of the blast. These higher-activity wastes may be contaminated with
radionuclides at levels consistent with Class B or Class C LLRW. Any waste above Class C is
generally not suitable for near surface burial. Beyond this area of higher-activity waste, it is
anticipated that the remaining contaminated materials will be significantly less concentrated.
Most wastes (95 to 99+%) will be contaminated at levels consistent with Class A (the lowest
level) LLRW. All classes of LLRW are shown in Table 1.
Table 1. Classes of Low-Level Radioactive Waste* (LLRW)
Radionuclide
Class A
Class B
Class C
Cs-137 *
<1
>1 and <44
>44 and <4600
Sr-90 *
< 0.04
> 0.04 and <150
> 150 and < 7000
Alpha emitting transuranics with
half-life greater than 5 years +
<10
NA
> 10 and < 100
* Units: curies/m3 (per NRC Waste Classification Regulations, 10 CFR 61.55)
+ Units: nanocuries/gram (per NRC Waste Classification Regulations, 10 CFR 61.55); if the concentration
exceeds the upper end value of Class C, the waste is not generally acceptable for near-surface disposal.
Given that much of the waste will be only lightly contaminated (Class A), local disposal options
that can provide the necessary level of protection should be considered as a first option, in the
contaminated area (considering state and local requirements). This approach may be a more
efficient use of resources and expedite cleanup.
9 The terms "contaminated" and "uncontaminated" will be defined based on the cleanup goals and the waste acceptance criteria
(WAC) of the disposal facilities.
The question of whether RDD or other
incident waste would be considered
LLRW is a legal determination that may
depend on situation-specific factors.
Allow flexibility in these situations
compared to assigning everything as
LLRW, as greater effort will be needed
to remove that designation once
assigned.
17
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Waste generated during the early phase from an RDD (adapted from the Liberty RadEx
exercise10) could be characterized into the following categories:
• Class A LLRW (majority of the waste material)
• Class B LLRW (higher levels from blast zone or onsite concentration efforts)
• LLRW with asbestos (i.e., old steam pipes from demolished buildings)
• LLRW with polychlorinated biphenyls (PCBs) (i.e., PCB transformer oils coating demolished
building exteriors)
• LL Mixed Waste (LLMW) (RCRA Hazardous Waste [HW] and LLRW)
• Personal protective equipment (PPE) waste
• Sludge from onsite decontamination efforts
• Sludge from wastewater treatment plants (WWTPs)
• Laboratory samples (e.g., for mobile laboratory analysis)
• Contaminated clothing from off-site health facilities
• Bags of contaminated clothing outside homes and businesses
• Non-radiological solid or HW for disposal in RCRA C or D landfills
• Normal urban trash for disposal in RCRA subtitle D landfills.
Radiologically-contaminated waste will specifically consist of:
• Inorganic materials (construction and demolition waste, buildings, sidewalks, streets, motor
vehicles, buses, light rail trains, contaminated soils, household furnishings, white goods,
electronics, etc.)
• Organic (petroleum products/fuel, vegetative debris, food, animal carcasses11)
• Liquids (aqueous wastes, household hazardous waste, etc.)
• Hazardous Materials (e.g., asbestos, PCBs, other toxic industrial chemicals).
5.2 Waste Quantity
Following a radiological incident, there will be
an urgent need to put in place all of the
elements of an integrated waste management
system to safely gather and manage the large
volumes of waste that are being generated; it is
also unlikely that all needs will be addressed
within the first 72 hours of a response; it may
be up to weeks before all needs are put into
place. Contaminated waste and debris volumes
from a radiological incident could be significantly larger than the volumes of LLRW typically
generated annually in the United States from decommissioning activities, DOE cleanup
activities, and nuclear power production by the public and private sectors combined, further
10Liberty RadEx
http://yosemite.epa.gov/opa/admpress.nsf/90829d899627a1d98525735900400c2b/28c5b280d311903a8525771100525103!opendo
cument
11 It should be noted that human remains are not classified as waste
Because of the potentially massive amount
of waste that may be generated, WAC for
municipal solid waste landfills (regulated
under Subtitle D of the Resource
Conservation and Recovery Act [RCRA])
may be considered because not all waste
may be classified as contaminated material
that needs to be shipped to a low-level
waste facility.
18
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
emphasizing the importance of staging waste based on knowledge of pre-identified waste
management staging options. Quantities of waste expected to be generated from a radiological
incident will likely far exceed the capacity of nearby landfills, and unless that landfill is approved
by the regulator and the local community, the landfill likely cannot be used.
6. WASTE STAGING
Determining where to locate staging areas early will help reduce spread of contamination and
the timeline of the recovery to come. Local and state agencies may need to be self-sufficient
during the early phase (or even longer) until federal resources are available to assist. A
complete understanding of the situation may not be achievable for 24 to 48 hours (or weeks)
after the incident.
Based on input from the stakeholder workshop and the three-city meetings, the first
responders who were in attendance indicated that since they would be focusing on life saving
operations, they would not be intentionally focused on any waste management activities during
the first 72 hours. This is why waste management activities should be planned out prior to the
incident and documented, trained, and exercised on ahead of an incident. To date, very few
national, regional or local level exercises focus on waste management activities for radiological
incidents. Section 7 presents a hypothetical radiological incident scenario in the U.S. along with
generated waste quantities, waste source, and structures affected. This scenario focused on a
wide urban area radiological release.
The overall information within Section 6 is the type of information and considerations needed
to prepare the Pre-lncident WMP document.
6.1 Waste Staging Decision Tree
The preceding sections have discussed the importance of pre-incident planning and
preparation, waste management, waste types, and waste quantities. This section addresses the
general steps associated with pre-establishing a temporary waste staging/storage area and the
many operational and logistical aspects of selecting the appropriate site(s).
Figure 2 presents a decision tree that may assist in establishing waste staging areas. The
decision tree is used to pre-establish areas based on specific scenarios and conditions. Then,
after an event, the pre-selected sites can be
further vetted based on actual incident data
(incident data may also affect decisions that were
initially made based only on planning
assumptions). The decision tree offers
recommendations and best practices that could
be considered when determining the magnitude
of the problem i.e., Step 1 - identify characteristics and quantities of waste; Step 2 - develop
criteria to evaluate potential sites; and Step 3 - pre-establish temporary staging sites for waste
and debris storage following a radiological incident.
All three of these steps in the decision
tree should be conducted within a
pre-incident WMP. Do not rely on the
decision tree after there is a
confirmed need.
19
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Before applying this decision tree, it should be assumed that the need for waste staging sites
has already been determined and confirmed. Given this, the next step should focus on
developing criteria to evaluate potential staging sites. Step 2 of the decision tree lists several
criteria that may be considered for pre-establishing temporary storage sites. These criteria are
discussed in greater detail in Section 6.2 in a format similar to the display of the Rad Decon
"app" that could be used to assist with waste management decision-making in the early phases
of a radiological incident.
Other potential factors affecting establishment of temporary waste staging areas are:
• Incident location and distance to a (licensed or public) disposal facility;
• Transportation modes serving the site and disposal facility (rail, truck, vessel);
• Types of waste;
• Volume of the waste;
• Status of appropriate permits and/or licenses that would allow facilities to accept the
waste;
• Design of the disposal facility receiving the waste;
• Performance of the treatment or disposal facility (a history of leaking contaminants, etc.);
• Capacity (both daily and total) of treatment/disposal facility receiving the waste;
• Proximity to populations, including populations that may be disproportionately impacted by
contamination;
• Length of storage time; and
• Temperature.
The first five factors generally drive transportation and disposal costs, while the remaining
factors would be considered in determining whether waste would be shipped to a given facility
(Beckman et al., 2011).
Radiological wastes must be managed consistently with relevant local, state, tribal, and federal
regulations. At the time of this publication, commercial options for the disposal of LLRW in the
United States are limited, but include EnergySolutions, U.S. Ecology, and Waste Control
Specialists. In the event of a wide-area radiological incident, other disposal options, including
in-state disposal options, may need to be considered and/or developed to handle the vast
quantities of wastes that will not likely be resolved within the early phase of the incident.
Decision-makers should be aware of provisions in their state regulations that allow for
expedited regulatory approval in the event of an emergency. These strategies could be
documented as part of the Pre-lncident WMP.
Another challenge includes inadequate on-site
storage space for water or wastewater
contaminated with radionuclides, and for
treatment and storage of secondary waste (e.g.,
sludges, loaded zeolites, filter media) produced
from cleanup activities. For liquid waste, some
degree of on-site treatment at the waste staging/storage area might be possible, although this
treatment may produce solid wastes. If on-site treatment is selected, then the temporary
The focus of the decision tree is not
just for solid waste; liquid waste,
secondary waste, and mixed waste
are also taken into consideration.
20
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
storage area of the liquids should be selected with the treatment in mind. Also, for wastewater
plants receiving radiologically-impacted water, storage of the sludge (secondary waste) may
need consideration.
Locations of a staging area(s) for radiological material should be carefully chosen because
radiological material has the potential to cause risk to human health due to the higher levels of
radiation. Considerations for the waste staging locations should extend beyond debris
segregation and storage to include sufficient space for operations to screen the debris for
human remains, ensuring site security, avoiding environmental and human health impacts, and
any applicable waste management requirements. For example, when selecting appropriate
temporary staging areas, one should consider staging location (e.g., out of flood zones), space
requirements, the amount of material that has to be handled, waste volume generated,
coordination among utilities, and worker exposure. Considerations should also include
secondary containment, space for possible use of decontamination technologies, shielding
(especially gamma ray emitting waste) capability, vehicle traffic, vehicle decontamination,
utilities to support activities, signs, infrared cameras, waste record keeping, radiological
monitors throughout the site, etc.
21
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Step 1. Characteristics and Quantities of Waste (Magnitude of
Problem).
YES
Use existing
landfills
NO
Assuming pre-incident plans and agreements have been established, do existing
landfills have sufficient capacity for the expected volumes of waste and can they
accept it immediately?
Volume of Waste generated: The
information gathered during the preliminary
damage assessment immediately after the
radiological incident should give a rough
order of magnitude indication of the types
and amounts of waste to be handled. (See
Sections 5.1 and 5.2, for a discussion of
waste types and quantities).
Site a temporary storage area at a landfill
vacant lot, etc., for waste segregation
operations (focus of this document)
• Expand disposal facilities to handle the
increased demand (if possible, via
renovation or enhancement to facilities)
• Haul to intermediate sites and reduce the
Step 2. Develop Criteria to Evaluate
Potential Sites.
Avoid unintended consequences: The use
of specific technologies could impact
contamination levels of quantities of waste
that have to be treated and disposed of later.
An example of an unintended consequence
could be accumulating plowed, contaminated
snow into a staging area in a manner that
creates an unintended hot spot, or washing an
area in a manner that generates difficult to
treat aqueous waste.
Consider the following in
developing criteria for potential
temporary waste staging sites
for solid, liquid, mixed, and
secondary wastes. These topics
are discussed in section 6.2.
Length of storage time
Truck or railcar size
Equipment needed
Site Ownership/Site
Leasing
Location
Waste staging site
size or capacity
Site operations
Condition of materials
Sites for designated
materials
Security and signage
Ease of accessibility
Travel conditions
1
Step 3. Identify Temporary Staging Sites for Radiological
Waste.
i
List sites: Prepare a list of potential temporary staging sites based
upon the type and amount of materials projected to be collected,
processing techniques, and transportation constraints.
Check on available public and private sites for use as temporary
staging or storage sites. Explore the possibilities of using city/county-
owned land, state lands, and private property. Private property will
probably be the last resort given the liability associated with this. Large
open areas will be needed with capability of storage of large volumes of
liquid and solid waste.
1
Temporary waste staging areas will likely be critical element of the
overall response - waste can be first moved to these temporary
locations while landfill capacity is being constructed or negotiated.
Examples of Temporary Staging Sites:
• Commercial/industrial facilities (rail
yards, industrial parks, licensed rad
users, nuclear power plants)
• Federal facilities (DOE and DoD
facilities)
• State/local facilities (Solid Waste
Management and HW Facilities)
• recycling facilities
• landfills
• transfer stations
• vacant lots or buildings
• corporation yards
• parks
• parking lots
• right-of-ways
• city/county-owned properties
• private properties
• For liquid waste, consider storage
areas, tanker trucks and rail cars,
ponds, or "deep tunnels", etc.
Figure 2. Decision Tree to Pre-establish Waste Staging Areas
22
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2 Criteria to Evaluate and Pre-Establish Potential Staging/Temporary Storage Sites
6.2.1 Location
Sites should be located within the outer cordoned area that is secured and preferably in a
structure to prevent the spread of contamination (e.g., by wind or rain). The sites should be in
the contaminated area, out of flood zones, and away from people, CI/KR, and locations
targeted for early cleanup. One possible location for temporary storage is in the exclusion zone,
which limits public access.2,3,4
Sites should:5
• Be sufficient in size with appropriate topography and soil type (if possible, work with
national and local environmental agencies to determine this);
• Be located away from potable water wells and rivers, lakes, streams and drainage channels.
If possible, work with national and local environmental agencies to determine appropriate
setback distances; and
• Be located close to the affected area, but far enough away from residences, infrastructure,
and businesses that could be affected by site operations during the recovery period; and Be
on public lands because approval for this use is generally easier to obtain (however, private
land may be more convenient and logistically necessary).
The site should be established in an area that does not impede the flow of traffic along major
transportation corridors, disrupt local business operations, or cause dangerous conditions in
residential neighborhoods or schools. Whenever possible, avoid locating a site near residential
areas, schools, churches, hospitals, and other such sensitive areas.
The site requires good ingress/egress to accommodate heavy truck traffic. The planning staff
should consider adjusting traffic signals to accommodate projected truck traffic on critical haul
routes. The site selection criteria should consider access to major routes to allow for trucks to
transport material to final disposition locations.
When selecting public or private sites, pre-existing conditions should be considered because
the sites will have to be restored upon site closeout. Proper management of the site allows the
site to be closed with manageable efforts. For site closure reasons, planning staff should refrain
from aggravating an existing environmental issue during the debris management operations.
Therefore, a site should not be established in an environmentally or historically sensitive area
such as wetlands, critical animal and plant habitats, sole source aquifers, freshwater well fields,
historic districts, or archeological sites. Site selection criteria should also take into consideration
any disproportionately high or adverse impacts on minority or low-income populations.
Adverse impacts should be avoided or minimized where possible. If an environmental or
historic preservation concern is found in the preliminary site search, the potential site should
be ranked lower than others. However, if use of such areas is unavoidable, the State and local
environmental and historic preservation requirements may be required to be followed.9
The topography and soil/substrate conditions should be evaluated to determine the best site
layout. When planning site preparation, the designer should consider ways to make site closure
and restoration easier. For example, if the local soils are very thin, the topsoil can be scraped to
23
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
bedrock and stockpiled in perimeter berms. Upon site closeout, the uncontaminated soil can be
re-spread to preserve the integrity of the tillable soils.9
Potential site location - things to avoid:10
• Wetlands. If near wetlands, establish buffer and/or turbidity barriers;
• Public water supplies; well fields or surface waters;
• Threatened and endangered species;
• Critical habitat;
• Rare ecosystems;
• Historic sites;
• Archaeological sites;
• Sensitive surrounding land uses - schools, nursing homes, hospitals, residential, etc.; and
• Consider prevailing winds for dust and odors.
Potential site location - things to look for:10
• Good ingress/egress;
• Good transportation arteries nearby;
• Open flat topography; and
• Ability to establish a buffer zone to abate concerns over dust, noise and traffic.
Finding the right location - when selecting a proposed waste staging site, the following should
be considered:11
• What is the proposed use for this site?
• Is it easily accessible?
• Is it removed from obstructions such as power lines and pipelines?
• Is the site considered to be a wetland area, as defined by the U.S. Army Corps of Engineers?
• Is the general site topography conducive to the activity that will be conducted there?
• Are there nearby residences and/or businesses that will be inconvenienced or adversely
affected by use of this site?
• Is the size sufficient for its intended use?
• Is the soil type suitable for its intended use?
• Is the site a previously authorized location that is being reactivated for use?
• Is the site located near water bodies such as rivers, lakes or streams or does it have
proximity to occupied dwellings?
• What is its proximity to the impacted area?
• Does the site have historical significance? Contact the State Historical Preservation Office,
U.S. Department of Interior and National Parks Service.
• Can the site easily be cleaned up after temporary use?
Understanding the local land use provides information as to the types of debris that will be
generated and offers insight as to the type of handling that would be necessary to manage the
debris safely. For example, rural areas may have more vegetative debris, whereas urban
residential areas may have more construction and demolition debris. Industrial areas may have
special environmental concerns compared to parks/recreation areas.12
24
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
• Consider the impact of noise, traffic, and environment.
• Look for good ingress/egress at sites to maximize efficiency of flow of traffic.
• Consider impacts on neighboring communities of trucks hauling to sites.
• Consider geological site conditions (stable ground, groundwater levels, soil or rock relatively
impervious). Is the area geologically stable?
• Relatively impervious ground conditions are preferable. Pervious soils (gravel or coarse
sand) and fractured rock will allow leachate to potentially contaminate groundwater.
• Abandoned quarries, which offer large open space, should not be used due to their
potential for exposing groundwater to the debris leachate.
• Consider prevailing winds that tend to carry air particulates and noise in a particular
direction
• Consider visibility from the surrounding area
• Avoid environmentally sensitive areas, including the following:
• Rare (threatened) and critical animals or plant species;
• Well fields and surface water supplies—there is the potential for runoff from hazardous
and toxic waste pollutants; and
• Historical/archeological sites12
Avoid locations near susceptible populations. Location must have access to roads, bridges,
power, communications and water. Consider truck routes and distance trucks must travel when
selecting a location.13
Waste staging areas should be located in the same area as, or next to, possible
decontamination areas. Siting waste management areas adjacent to decontamination areas will
eliminate the need to transport the waste from its original location to a decontamination
center. Double-handling of waste (i.e., moving the waste around without some process being
performed on the waste) should be reduced as much as possible.1
Waste management accumulation areas should be protected from inclement weather
conditions (e.g., flooding, ice, snow, heavy rains). Also, high humidity environments may cause
accelerated corrosion of storage containers.1'8
Higher activity wastes from the blast zone and areas immediately downwind of the blast zone
(high contamination zone) should be kept separate, sealed in appropriate containers, and
stored in the high contamination zone.4
Consider setting up sites for specific materials (e.g., concrete, bricks, metal, asphalt, etc.) that
do not threaten public health and safety.5
Ensure the site can hold rubble, natural debris such as organic waste, as well as conventional
waste.5
Measures should be taken to minimize multiple interim waste storage sites because in the
future, some, if not all, are likely to require decommissioning and remediation.2
If sufficient capacity is not available to store waste temporarily, local authorities must make
other plans, including:5
25
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
• expanding existing recycling, processing and disposal facilities to handle the increased
demands;
• hauling waste to intermediate sites and minimizing the amount of debris through recycling;
• identifying a temporary storage area at a landfill or vacant lot for recycling operations; and
• establishing recycling, processing mechanisms/facilities.
The best way to select a temporary storage site that incorporates environment, public health
and other issues is to conduct a full Rapid Environmental Impact Assessment.5
The planning staff needs to consider public acceptability when selecting a potential site. Public
acceptability is largely dependent upon the activities planned for the site. Around-the-clock
light and noise from equipment operation, dust, and traffic are generally tolerated early in a
disaster recovery operation but may have to be curtailed later. The planning staff is strongly
encouraged to notify citizens early about planned site activities and possible ramifications.9
Example:
Denver's Temporary Debris Management Sites:6
• 25 locations
• typically Denver parks
• Envisioned for catastrophic debris-generating event
• Selected for "conventional debris"
• Limited space available for segregation of waste streams
• One likely site having paved surface
• Facilitate post-operations cleanup
• Separated from residential areas.
Example: Temporary near-surface storage of large volumes of radioactive waste from the
Chernobyl NPP site and vicinity was located in the exclusion zone at distances of 0.5 to 15 km
from the NPP site. Unlike at Chernobyl, temporary facilities should be established with proper
design documentation, engineered barriers, and hydrological investigations. The temporary
storage facilities at Chernobyl were constructed without these considerations. At these
facilities, waste was stacked and stored in trenches 1.5 to 2.5 meters deep in sandy soil; the
radioactive material was overlain by a layer of alluvial sand 0.2 to 0.5 meters thick to avoid dust
spread. However, due to the lack of engineering control, retention capacity of the trenches
varied. Without proper design and engineering control and consideration of hydro-geological
conditions, radionuclide dispersion may threaten groundwater.7
References
1 USDHS, Key Planning Factors for Recovery from a Radiological Terrorism Incident,
September 2012.
2 International Atomic Energy Agency (IAEA) Report on Decommissioning and Remediation
after a Nuclear Accident, International Experts Meeting, 28 January -1 February, 2013,
Vienna, Austria.
3 IAEA, Manual for First Responders to a Radiological Emergency, 2006.
26
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
4 National Response Team (NRT) Quick Reference Guide: Radiological Dispersion Device,
December 2012.
5 United Nations Office for the Coordination of Humanitarian Affairs, Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
6 Wide Area Recovery and Resiliency Program (WARRP). Decon-13 Subject Matter Expert
Meeting, August 14, 2012.
7 Environmental Consequences of the Chernobyl Accident and Their Remediation: Twenty
Years of Experience, Report of the UN Chernobyl Forum Expert Group "Environment,"
August 2005.
8 Steinhausler, Chernobyl and Goiania Lessons for Responding to Radiological Terrorism,
2005.
9 FEMA 325 Debris Management Guide, July 2007.
10 Connecticut Dept. of Energy & Environmental Protection, Storm Event Preparedness and
Response Fact Sheet for Municipalities, Site Selection Guide for Temporary Debris Storage
and Reduction Sites, 2011.
11 Oregon Emergency Management, State of Oregon Debris Management Plan, Annex to the
State Emergency Operations Plan, April 2011.
12 FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online
training course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctype=R.
13 Janiec, Greg. Operational Considerations in Debris Management Planning. Presentation
prepared by Sovereign Consulting, Inc.
27
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.2 Site Ownership/Site Leasing
The planning staff should consider public lands first to avoid costly land leases. Existing disposal
or recycling facilities that are in close proximity to the disaster area are ideal locations for a site.
Nearby landfill and recycling center capacities need to be evaluated for site feasibility.
Applicant-owned sites such as parks, vacant lots, or sports fields that will not require extensive
repair costs should be considered as well. State-to-State or county-to-county agreements may
present possible solutions for public land use.
When use of public lands is not possible, the planning staff should develop criteria for
identifying potential private property locations for the site. Private land leases need to be
reviewed by the legal staff to avoid extensive damage claims upon site closeout.
The duration of the land lease agreement should be inclusive of all the time the applicant will
be present at the site, beginning with the baseline environmental study and ending once the
property owner takes back legal ownership.
The agreement should include a requirement to conduct a baseline environmental evaluation
of the site before the site is occupied and an environmental evaluation before returning the
property to the owner. Both documents may become an annex to the land lease agreement.
The land lease agreement should be for a specific time frame with the ability to extend the
lease if debris removal and processing activities are not completed.1
Site ownership:2
• Use public lands to avoid costly leases.
• Use private land only if public sites are unavailable.
• Have attorneys review leases to avoid closeout claims.
• Provide possible extensions to the lease if needed.
• Ensure the lease covers technical issues such as closure criteria, environmental issues.
References
1 FEMA 325 Debris Management Guide, July 2007.
2 FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online
training course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctype=R.
28
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.3 Length of Storage Time
Remove debris from the site in a timely manner.1
Significant liquid and solid wastes associated with CI/KR decontamination activities will be
generated during the first week after an event and will likely increase as the incident
progresses. Billions of tons of liquid and millions of tons of solid wastes associated with initial
cleanup operations may be generated beginning in the first month after an event. It is
anticipated that additional liquid and solid wastes will be generated throughout the response.
These wastes may need to be temporarily stored until long-term storage locations are
determined and/or permanent disposal can be accomplished.2
References
1 United Nations Office for the Coordination of Humanitarian Affairs Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
2 Wide Area Recovery and Resiliency Program (WARRP). Decon-13 Subject Matter Expert
Meeting, August 14, 2012.
29
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.4 Truck or Railcar Size/Equipment Needed
Not any type of truck can be utilized to haul radioactive waste. There are very specific
requirements of haulers of this type of waste. Refer to NRC and DoT regulations. There may not
be enough trucks that are currently licensed, certified and qualified to handle this amount of
waste available to haul the material. It is unlikely that a large quantity of trucks would be
available during the early phase of the response.
Use land/sea boxes, roll-offs, drums, totes, bins, etc. to contain the waste, or cover waste with
plastic tarps to keep wastes dry and prevent contaminant spread. Fukushima wastes were
containerized, the containers placed over bentonite (to absorb cesium) and covered with a
tarp.2
Trailer and tank capacities are type-dependent. Some examples of typical capacities include:
• A 48' open top semi-trailer can haul debris with a capacity of 50,000 pounds and 85 cubic
meters.5
• A 53' tanker can haul liquid with a capacity of 9,000 gallons.5
• A 40' open top semi-trailer can haul debris with a capacity of 58,600 pounds and 67.7 cubic
meters.6
Using a front end loader, it is possible to load eight 108-ton railcars per day with LLRWs, soils
and raffinate in steady-state operational batch mode. In an emergency situation, it is likely that
a facility could load more than eight railcars per day. Also, climate-controlled cabs for front end
loaders are recommended.4
Waste disposal facilities often use "rollovers" where the railcar is clamped into a device that
inverts the car upside down to empty contents. Not all railcars are made for such equipment
and railcar lids and liners (if any) have to be removed before rollover and reattached after
rollover.4
The following equipment is recommended for temporary storage activities:3
• Waste container boxes (e.g., B-25 waste box) available for transportation of debris
• Super Sacks available for debris handling
• Radioactive monitoring equipment
• Ludlum 12, 17, 19, 2241-2 meters
• Personal dosimeters
• High volume air samplers
Example (beyond early phase): An RDD incident producing 3 to 8 million tons of solid waste
would fill 30,000 to 80,000 railroad hopper cars (100 ton capacity) or 94,000 to 250,000 tri-axle
dump trucks (32 ton capacity). An RDD incident producing 16 million to 21 million tons of solid
waste would fill 160,000 to 210,000 railroad hopper cars (100 ton capacity), 400,000 to 525,000
semi-trailers (64,000 pound net capacity), or 500,000 to 656,000 tri-axle dump trucks.1
Example (beyond early phase): An RDD incident producing 15 to 36 million gallons of liquid
waste would fill 500 to 1200 railroad tank cars (30,000 gallon capacity) or 2,700 to 6,500 tanker
trucks (5,500 gallon capacity). An RDD incident producing 1.5 to 3 billion gallons of liquid waste
30
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
would fill 50,000 to 100,000 railroad tank cars (30,000 gallon capacity) or 275,000 to 550,000
tanker trucks (5,500 gallon capacity).1
References
1 USEPA Office of Homeland Security, WARRP Waste Management Workshop, Denver, CO,
March 15-16, 2012.
2 NRT Quick Reference Guide: Radiological Dispersion Device, December 2012.
3 WARRP. Decon-13 Subject Matter Expert Meeting, August 14, 2012.
4 Email correspondence with John Hall, USEPA ORD, National Homeland Security Research
Center. October 24, 2014.
5 C.H. Robinson Trailer Equipment Guide. Available at http://www.chrobinson.com/en/us/-
/media/ChRobinson/News-PDF/TruckloadEquipmentGuide.pdf. Accessed January 14, 2015.
6 Griffin & Company Logistics Container Information. Available at
http://www.wlgriffin.com/reference/container_info.pdf. Accessed January 14, 2015.
31
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.5 Waste Staging Site Size/Capacity
Large equipment requires large areas for storage. When planning for small scale equipment,
more but smaller sites are needed. Conveniently located sites will reduce travel time when
transferring debris to processing or management facilities and result in expedited debris clean-
up. Communities can also use these sites to distribute reusable or recycled products.1
The size of the site is dependent on the quantity of debris that is stored and processed. The site
should be large enough to safely accommodate processing of various debris materials, storing
heavy equipment, and maneuvering trucks and large processing equipment. Historic disasters
have shown that it takes 100 acres of land (on average) to process one million cubic yards of
debris. The U.S. Army Corps of Engineers (USACE) has found that approximately 60 percent of
the area will be used for roads, buffers, burn pits, household hazardous waste (HHW) disposal
areas, etc.6
A site requires sufficient area for the processing equipment and for the trucks to turn around in.
A site also requires sufficient area to keep materials segregated to avoid contamination and to
place materials that require special handling and transportation to a more appropriate recycling
or disposal site.7
Size depends on volume of debris to be collected and planned volume reduction methods.8
Sites typically range between 50 and 200 acres.
The following are assumptions used by USACE when determining the minimum size required for
debris storage:8
• Debris will be piled 10 feet (3.33 yards) high.
• One acre (4,840 square yards) of debris, 3.33 yards high, would equal 16,117 cubic yards
(cy).
• However, there are other factors in the design and use of the site that significantly impact
the required size:
• Approximately 60 % of the area will be used for roads, buffers, burn pits, HHW disposal
areas, etc.
• Therefore, the number result of dividing the forecasted amount of debris by 16,117 cy
must be increased by a factor of 1.66.
Sixty percent or more of the site will be designated for buffer zones and infrastructure;
therefore, a large site is necessary.9
The following statistics are from the DOE Fernald remediation for which approximately 900,000
cubic yards of low level DoT class 7 waste was dried and shipped to off-site disposal via rail:10
(Note: The DOE Fernald remediation was a much slower cleanup than what will need to be
done for a radiological incident.)
• Railcar load out facility enclosed in 35,000 square foot building (~ 1 acre), with waste
material holding bins for characterized waste, loading platforms, railcar weigh scale,
overhead crane for railcar lidding/delidding operations and railcar decontamination
equipment.
32
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
• Material Handling Building was 65,000 square foot (~l-l/2 acres).
• Approximately 100,000 square feet of pre-engineered building was installed. The entire
processing personnel area was 6 acres to include the loading, staging, drying, off gas,
laundry, change-out, locker rooms, laboratory, administrative areas, etc.
• Rail yard was 11 tracks covering approximately 7 acres - ~1300 ft by 200 ft.
• Each railcar was ~ 55 ft long, so Unit Trains were 1/2 mile on the short side (50 cars) to 2/3
mile on the nominal length (60-65 cars).
Example: Decontamination of a single facility in Loudoun County, VA (Department of State
Diplomatic Pouch and Mail Facility) generated more than 300 tons of debris waste and almost
79,000 gallons of wastewater from personnel decontamination alone. A wide-area incident may
include hundreds of similar buildings. It is recommended that piles of discarded debris be
staged at multiple sites throughout contaminated areas.2
Example: The Gioania event (a radioactive contamination accident after an old radiotherapy
source was stolen from an abandoned hospital site in the city) in 1987 resulted in ~123,601
cubic feet of topsoil waste that required storage, which was 150,000 times the volume of the
original source.3
Example: After the NPP event in Fukushima, Japan, storage capacity was sought for ~3 billion
cubic feet of soil. A facility capable of storing ~280 million tons of waste is expected to be built
by 2015. While the scale of the Fukushima accident likely exceeds the impacts from an RDD,
several aspects are relevant: cleanup goals affect the volumes of waste generated;
decontamination strategies affect waste volumes; there is likely to be public pressure to
accelerate cleanup.4
Example: After Hurricane Katrina, Mississippi Department of Environmental Quality (MDEQ)
authorized emergency debris sites as follows:5
• 288 Vegetative Debris Management Sites
• 16 Building Debris Disposal Sites
• 22 Mixed Debris Staging and Segregation Sites
An emphasis on the number of authorized emergency debris sites was placed on coastal
counties compared to inland counties. It should be noted that an RDD incident would likely
impact a much smaller geographic area than a Category 5 hurricane (Category 4 at landfall),
such as Katrina.
References
1 United Nations Office for the Coordination of Humanitarian Affairs Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
2 USDHS, Key Planning Factors For Recovery from a Biological Terrorism Incident, Summer
2012.
3 USEPA and USDHS, WARRP Decon-13: Subject Matter Expert (SME) Meeting Waste
Screening and Waste Minimization Methodologies Project, Final SME Meeting Report
Denver, Colorado August 14 - 15, 2012.
33
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
4 USEPA Office of Homeland Security, WARRP Waste Management Workshop, Denver, CO,
March 15-16, 2012.
5 Mayea, Ethan. Hurricane Katrina: Waste Tire Management Efforts, MDEQ Solid Waste
Branch.
6 FEMA 325 Debris Management Guide, July 2007.
7 State of California Integrated Waste Management Board, Integrated Waste Management
Disaster Plan Guidance for local government on disaster debris management, Chapter 4:
Temporary Storage (Pre-staging) Sites, January 1997.
8 FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online
training course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctype=R.
9 Janiec, Greg. Operational Considerations in Debris Management Planning. Presentation
prepared by Sovereign Consulting, Inc.
10 Email correspondence with Dave Lojek, USDOE Fernald Operable Unit 1 Team Leader.
October 2014.
34
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.6 Site Operations
Make use of standard hot-zone, warm-zone and cold-zone work practices to prevent the spread
of contamination.1 Make use of safety zones for first responders, which are Low-Radiation Zone
(<10-100 mR/hr); Medium-Radiation Zone (100-1000 mR/hr); High-Radiation Zone (1000-
<10,000 mR/hr); and Extreme Caution Zone (>10,000 mR/hr). Note that this will include
survey/decontamination stations for vehicles entering/leaving the staging area and
transitioning from one zone to another.
Temporary waste storage sites may need long-term monitoring, depending on waste stream,
even after radioactive waste has been removed for final disposal.4
Sites should have controls to mitigate storm water runoff, erosion, fires and dust, if possible.6
The condition of the temporary disposal sites should be documented in print and photos prior
to use. Depending on the radioactive waste to be staged there, it is advisable to assess the soil,
groundwater and/or surface water at a proposed staging area prior to receiving radioactive
waste and to re-establish pre-existing conditions.6
Areas to be used to process radioactive vegetation debris do not typically require groundwater
monitoring, but should be monitored for fires. Areas for mixed rubble or hazardous wastes may
need more extensive monitoring.6
Operations that modify the landscape, such as substrate compaction and over-excavation of
soils when loading radioactive waste for final disposal, adversely affect landscape restoration.9
Operational boundaries are the boundaries or areas that clearly define the difference in use
areas at the waste staging site. In establishing the operational boundaries, the site design staff
may consider using earthen berms, temporary barriers, or any other physical restriction to aid
traffic circulation and help keep debris amassing at the site to a minimum.
Common operational uses are:8
• Reduction
• Tipping areas (unloading)
• Loading areas for processed debris to go to its final disposition
• Drop-off centers for the general public (this may include vegetative, recycling, or
construction and demolition debris)
• HHW storage
• Monitoring tower locations at both the ingress and egress points
• Equipment, fuel, and water storage
The separation between all of the areas listed above needs to be clearly delineated and
defined. As operations proceed, the lines may be moved to accommodate either growing
demand for space or a reduction in preparation for closure.
Optimally, the designed traffic pattern should allow trucks to enter and exit through different
access points, as long as each is monitored. Haulers are typically paid by the volume of a load.
The load is evaluated when entering the site as a percentage of the full capacity of the truck.
Stationing monitors at ingress and egress points ensures every truck releases the entire load
35
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
prior to leaving the site. This avoids radioactive waste left in a truck from a previous load from
being counted again in a subsequent load.
The empty trucks that enter the site to remove the processed (reduced) radioactive waste
should enter and exit through an access point other than that of all other traffic. This reduces
the site management and debris monitor confusion regarding debris being deposited or leaving
the site.8
Other site considerations include:
• Establish and maintain buffer zones around the perimeter of the site but inside the
boundaries.9
• Construct containment berms as necessary to separate and contain various types of debris.
• Ensure that incoming materials are segregated based on volume reduction methods.
• Develop holding areas for ash, HHW, and fuels. Line these areas with plastic or other
approved liners.
• Implement an efficient process of keeping debris moving into the site, property separated
and reduced, and out of the site.
• Environmental monitoring at the Radioactive Waste Management Site should begin with
the onset of the operations.9
• Periodically take photographs of the operation, monitoring activities, etc.9
• Maintain up-to-date maps and sketches.
• Document changes, tests, problems, actions taken, and monitoring visits by other agency
personnel.
• Implement a cradle-to-grave waste and material tracking and reporting system. Tracking the
waste from cradle to grave helps increase transparency and aids in allaying community
concerns. Keep in mind security concerns regarding sensitive information.10
Insurance may be required prior to commitment of hazardous waste storage operations.
Additionally, regulations and permitting procedures for storage activities may need to take
advantage of state authorities that allow for emergency approvals. Most state regulations allow
for such emergency approvals.2
Occupational Safety and Health Administration (OSHA) worker protection and training may be
necessary for on-site workers. Operations also include pre- and post-sampling, dust control and
erosion control. Solid and hazardous waste permits may be required, as well as an
environmental impact assessment.11
Technology development will be required on a case by case basis to adapt existing treatment
and handling systems to manage the radioactive waste arising from an accident. These
technology developments can include, for example, systems for volume reduction, stabilization
and packaging.5
Radioactive waste volumes from an RDD incident could be significantly larger than the volumes
of LLRW typically generated annually in the United States from decommissioning activities, DOE
cleanup activities, and nuclear power production by the public and private sectors combined.
This radioactive waste situation emphasizes the importance of segregating waste by
36
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
radiological content and knowledge of available disposal options. Not all of the waste from an
incident will need to be handled as LLRW.3
Incoming loads should be inspected to ensure materials are handled properly and directed
properly. Estimate quantities of incoming materials based on type of haul vehicle and capacity.6
All recoverable materials should be separated into major categories such as concrete, bricks,
stones, metals, green waste, wood debris, white goods, etc. Keep materials as free from
contamination as possible to increase reuse and recycling potential.6
There may be shortages of trained radioactive waste management personnel (including those
with appropriate PPE) to characterize, treat, and dispose of radioactive waste properly. This,
however, does not lessen any agency or jurisdiction obligations to comply with federal, state, or
local government environmental laws, statutes, regulations, or ordinances. Regulatory and
disposal experts should be consulted when considering waiving any environmental
requirements.4
A mechanism will be needed to verify that contractors are qualified and comply with the
radioactive waste management processes.4
The public information staff must take advantage of every information vehicle available if
power, utilities, and other infrastructure have been damaged. Many times the best carriers of
information are the responders in the field. The general public recognizes its role and
frequently asks questions regarding the operations. Stocking the equipment and trucks with
flyers, pamphlets, and other print media allows responders to perform their duties while also
satisfying the public's need for information.9
Start a public information program immediately to notify the public and contractors of the site,
the materials accepted, and the hours of operation.6
Consider the following safeguards for hazardous waste bulking sites:6
• Covering areas with two layers of plastic sheeting, tarps, or a concrete pad.
• Fencing off area with T-posts and orange barricade fencing to prevent vandalism and illegal
dumping. Cordoning off nearby streets may discourage nuisance or illegal dumping.
• Posting signage that clearly identifies the temporary storage area, its operating hours, and
types of materials accepted and prohibited, and contact person.
• If possible, surrounding fenced off-area with absorbent booms and/or sandbags to absorb
potential leaks and prevent spills from seeping into the ground.
• Using wooden pallets to raise collection bins off the ground to determine if there are leaks.
• Consider the following safeguards for hazardous waste bulking sites (cont):6
• Providing adequate space for walking/carrying items between pallets.
• Segregating containerized gases, liquids, or solids by material type (e.g. corrosive waste,
reactive waste), place each material type in a separate bin or barrel, and label the bin or
barrel appropriately.
• Covering collection bins or barrels with plastic liners/lids or cover the entire hazardous
waste collection site with a tent to prevent water collecting in bins.
• Placing cylinders containing compressed gas upright with cap on and secured in place.
37
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
• Providing sufficient fire extinguishers for the site in case fire breaks out. If allowed by local
regulations, four fire extinguishers per 1000 square meters are recommended, placed at the
corners or in easily accessible locations.
References
1 Conference of Radiation Control Program Directors (CRCPD), Handbook for Responding to a
Radiological Dispersal Device - First Responder's Guide - The First 12 Hours, September
2006.
2 Nicholson, Legal Issues in Emergency Response to Terrorism Incidents Involving Hazardous
Materials, 2002.
3 USEPA, Technologies to Improve Efficiency of Waste Management and Cleanup After an
RDD Incident, Standard Operating Guidelines, October 2013.
4 Denver UASI All-Hazards Regional Recovery Framework, October 31, 2012, Version 1.1.
5 IAEA Report on Decommissioning and Remediation after a Nuclear Accident, International
Experts Meeting, 28 January -1 February, 2013, Vienna, Austria.
6 United Nations Office for the Coordination of Humanitarian Affairs Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
7 WARRP. Decon-13 Subject Matter Expert Meeting, August 14, 2012.
8 FEMA 325 Debris Management Guide, July 2007.
9 FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online
training course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctype=R.
10 USEPA Office of Resource Conservation and Recovery (ORCR). Pre-lncident All Hazards
Waste Management Plan Guidelines: Four Step Waste Management Planning Process
(Working Draft, Not Yet Published), Draft 2014.
11 Janiec, Greg. Operational Considerations in Debris Management Planning. Presentation
prepared by Sovereign Consulting, Inc.
38
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.7 Condition of Materials (Debris and Waste)
The amount of activity or level of contamination present on debris will be important in
determining the best methods for managing waste and debris. Debris found downwind of the
blast area will likely be contaminated with radiation radioactive material; however, other debris
found upwind of the blast area will likely have little to no contamination. The radioactivity of
the debris and waste should be measured, the potential for contaminating material handling
equipment considered, and the commingling of contaminated and uncontaminated waste and
debris avoided.1
An RDD may result in millions of tons of radiological contaminated solids and billions of gallons
of radiologically contaminated aqueous liquids. Most radioactive wastes (95 to 99+ %) will be
Class A LLRW. There will be smaller amounts of Class B or Class C LLRW solid wastes. Initial
waste streams will mostly be PPE, clothing and personal items from evacuees, and
decontamination water but cleanup wastes will follow shortly and need to be segregated.2
Except for the immediate area of the explosion (one block radius), RDD wastes should be
composed of undamaged materials, highly homogenous and not co-mingled debris:3
• Cars and residential property (anything not fixed)
• Trees and shrubs
• Building contents
• Tanks, drums, transformers, other hazardous waste
• Roof and siding
• Building materials
• Soils
• Concrete and asphalt
Another waste management activity that may be necessary during the initial hours is hot spot
removal. Hot spots are small areas with higher concentrations of radioactive contamination
than surrounding areas posing a greater threat to response workers and the public. Serious
consideration should be given to the location of a staging area(s) for this material because it has
the potential to cause risk to human health due to the higher levels of radiation. Other than
materials immediately impacted by a blast, the majority of wastes will likely be undamaged but
contaminated materials, amenable to segregation. Hot zone material should be kept separate
from lower-activity wastes. Segregation will minimize wastes and enable an increased amount
of alternate disposal pathways to be used for the lightly contaminated materials. Radioactive
waste segregation has the potential to achieve significant efficiencies in time and cost while at
the same time ensuring long-term protectiveness of the waste managed.1
An important consideration of waste management is that some of the radioactive waste piles
may contain human remains and animal carcasses, which will require special handling
procedures.1
Volume is a key consideration in waste management, transportation, and technical waste
processes (i.e., decontamination and treatment).Therefore, moisture content and
homogenization become critical factors for shipment. Also, it is more difficult to ship wet
materials than dry materials because the shipping conveyance must be water tight.
39
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Consideration should be given to air or solar drying and material mixing to achieve an optimally
compactable waste product for shipment.5
Plus or minus 5 % of optimum proctor density can be a common waste acceptance criterion.5
Product mixing and homogenization is also useful to optimize weight and volume in railcars.
Lighter uncompacted materials often "cube out" rail cars well before their rated load capacities
of 90 to 110 tons, meaning they exceed the volume of the rail car before the waste exceeds the
weight capacity of the rail car.5
Example: Analysis of the WARRP radiological scenario predicted types and quantities of
radiological waste that would be generated. The waste would likely include a variety of
aqueous and solid wastes, and the vast majority would be Class A LLRW, with minimal levels of
contamination.4
References
1 Planning Guidance for Response to a Nuclear Detonation, Second Edition, June 2010.
2 NRT Quick Reference Guide: Radiological Dispersion Device, December 2012.
3 USEPA/ORCR. All Hazards Waste Management Decision Diagram for Homeland Security
Incidents (Working Draft, Not Yet Published), Draft 2014.
4 WARRP. Decon-13 Subject Matter Expert Meeting, August 14, 2012.
5 Email correspondence with John Hall, USEPA ORD, National Homeland Security Research
Center. October 24, 2014.
40
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.8 Sites for Designated Materials
Considerations for a site include:1
• Back-up facilities in different States or Regions
• Capabilities of facility
• Pre-negotiated contracts
• Cost
• Anticipated community concerns
• Environmental Justice concerns
Consider setting up sites that handle certain designated materials only, such as inerts -
concrete, bricks, metal, soils, etc., since they can pose less of a health and safety threat. This
strategy can facilitate the collection and processing of materials.
A site will need sorting areas to stage and characterize rubble, scrap and soil. Large concrete
slabs are best suited for this purpose to permit easy pickup by front-loading machines.3
Office/break buildings, areas for changing into protective clothing, and storage of tools,
personal protective devices and radiation detectors, should be available on the site.3
When sites are being considered, make sure the site selection team includes a good cross
section of:4
• Local agencies; those with major responsibilities for some of the actions involved:
Department of Public Works, Solid Waste Management, Environmental Quality, for
example.
• Be sure State agencies are represented, particularly Radiation Control, Solid Waste, Air
Quality, Environmental Quality, and Emergency Management.
• Include local officials; mayor, member of city council, county administrator, or
representative.
Site neighborhood concerns include:4
• Around-the-clock light and noise (24-hour operations may be required at the onset of the
operation).
• Dust and Traffic. The USACE estimated that the amount of debris hauled during Hurricane
Andrew would fill trucks end-to-end from the Statue of Liberty in New York to the Golden
Gate Bridge in California and back to the St. Louis Arch.
• Emissions from combustion processes (e.g., volume minimization via incineration where
advisable).
• Runoff from hazardous and toxic waste (consider berms and holding ponds in design).
• Avoid residential areas; schools, churches, hospitals; other sensitive areas.
Possible (longer term) waste disposal sites (at the time of this publication) to consider:5
• EnergySolutions
• Waste Control Specialists (Andrews County, Texas).
References
41
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
USEPA Office of Homeland Security, WARRP Waste Management Workshop, Denver, CO,
March 15-16, 2012.
State of California Integrated Waste Management Board, Integrated Waste Management
Disaster Plan Guidance for local government on disaster debris management, Chapter 4:
Temporary Storage (Pre-staging) Sites, January 1997.
Report on the Status of the Adaya Nuclear Site and Recommendations for Health and Risk
Assessment, February 2011.
FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online
training course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctype=R.
Email correspondence with John Hall, USEPA ORD, National Homeland Security Research
Center. October 24, 2014.
42
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.9 Security and Signage
Sites should have limited access with only certain areas open to the public. Limit access to
ensure that the site is secure. Some types of waste that present higher levels of concern should
have additional storage controls and security measures.1'2'3'4
Fence off area to establish boundary for and technical control of area containing radioactive
material. Signage should include all proper radiological postings.1'2'3'4
Rail yard security may be considered for unit train staging and railroad exchanges, (i.e., CSX to
Burlington Northern).
References
1 IAEA Safety Guide No. WS-G-6.1, Storage of Radioactive Waste, http://www-
pub.iaea.org/MTCD/publications/PDF/Publ254_web.pdf
2 United Nations Office for the Coordination of Humanitarian Affairs Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
3 State of California Integrated Waste Management Board, Integrated Waste Management
Disaster Plan Guidance for local government on disaster debris management, Chapter 4:
Temporary Storage (Pre-staging) Sites, January 1997.
4 Email correspondence with John Hall, USEPA ORD, National Homeland Security Research
Center. October 24, 2014.
43
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
6.2.10 Ease of Accessibility / Travel Conditions
During the early phase, waste management should consist of supporting first responders by
removing debris that could cause an immediate threat to public safety (e.g., unstable
structures), clearing roadways, and removing fallen limbs and curbside debris that may hinder
emergency vehicle movement along access pathways and egress routes.1
Evaluate traffic logistics on and around the storage site.2
Conditions of entry roads and movement areas must be examined to ensure that large, heavy
equipment can readily traverse the areas. Some gravel, compacted roads may need to be
constructed.3
Make sure access roads are sufficient in number and size. Single lane unpaved access roads
increase cost as a result of delays due to restrictions required to allow loaded and empty trucks
to pass. In addition, poor weather conditions may make the access road impassable.4
Implement traffic control procedures. If there is a significant amount of debris, moving
truckloads of debris through the rest of the response and recovery traffic, residents, and
normal traffic can become a large logistics issue.5
Evaluating accessibility and terrain of various locations within a jurisdiction is critical to
determining the types of debris collection program that should be undertaken. Remote areas
may require storing the debris safely until accessibility is established.5
Zoning restrictions may be an issue, particularly for large vehicles, and highway weight
restrictions may vary based on time of year.6
Consider all modes of transportation, including vessel and rail, as well as possible differences in
restrictions for interstate highways and local roads. For certain waste streams, escorts may be
required.6
Rail sidings in the Eastern US can be limiting for unit train lengths (number of railcars).
Passenger trains have right of way and a unit train cannot be longer than the shortest siding en
route to the waste disposal facility.7
Rail cars from East of the Mississippi River slated for Western US disposal will undergo at least
one rail carrier exchange (e.g., CSX to Burlington Northern exchange in East St. Louis, IL).
Security for these rail yards may need to be considered.7
There are web-based traffic maps that are provided by many states; they are easy to access and
may contain useful information that could be used for the response.8
References
1 USEPA Office of Homeland Security, WARRP Waste Management Workshop, Denver, CO,
March 15-16, 2012.
2 United Nations Office for the Coordination of Humanitarian Affairs Environmental
Emergencies Section. Disaster Waste Management Guidelines. January 2011.
3 IAEA, Report on the Status of the Adaya Nuclear Site and Recommendations for Health and
Risk Assessment, February 2011.
44
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
State of California Integrated Waste Management Board, Integrated Waste Management
Disaster Plan Guidance for local government on disaster debris management, Chapter 4:
Temporary Storage (Pre-staging) Sites, January 1997.
FEMA. 2014. Debris Management Planning for State, Tribal and Local Officials. Online training
course E202, offered by the Federal Emergency Management Agency, Emergency
Management Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctvpe=R.
USEPA/ORCR. Pre-lncident All Hazards Waste Management Plan Guidelines: Four Step
Waste Management Planning Process (Working Draft, Not Yet Published), Draft 2014.
Email correspondence with John Hall, USEPA ORD, National Homeland Security Research
Center. October 24, 2014.
Indiana Department of Transportation, Traffic Wise, Accessed November 24, 2015
http://www.in.qov/indot/2420.htm.
45
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
7. ESTIMATED WASTE QUANTITIES UNDER THE WARRP RDD SCENARIO
In order for first responders to assess potential activities within the first 72 hours it may be
useful to put the scenario into context in terms of what the intermediate and late stage
cleanups will be dealing with. This section presents a description of hypothetical radiological
release scenarios along with potential quantities and characteristics of waste the might be
generated during the response.
DHS, in close coordination with EPA, DoD, DOE, HHS, and the Denver Urban Area Security
Initiative (UASI), initiated the WARRP in February 2011. WARRP was designed to develop
guidance to reduce the time and resources required to recover a wide urban area (specifically,
Denver) following a chemical, biological, or radiological incident, including meeting public
health requirements and restoring critical infrastructure (CI), and key resources (KR) (both
civilian and military) and high-traffic areas. The WARRP RDD scenario described for the Denver
urban area involves two RDD attacks: one at the U.S. Mint in downtown Denver, Colorado, and
another at the Anschutz Medical Campus in Aurora, Colorado. The scenario assumes that tens
of thousands of people are exposed at various levels and that hundreds immediately die from
blast-related trauma. The primary fallout area is within tens of miles of the blast, although
some of the radiological agent may be carried hundreds of miles. The downtown release
scenario potentially impacts more than 20 square miles and 32,000 buildings (which include 82
million square feet of indoor space), while the Aurora release scenario impacts fewer buildings
and people but contaminates a much larger area (DHS, 2012a). Both bombs were identical in
explosive power and amount of radioactivity, but the difference in the plumes is due to the
entrainment of contamination by the high-rise downtown Denver buildings.
This RDD scenario discussion focuses on the U.S. Mint (downtown Denver) scenario. In this
scenario, higher concentrations of Cesium-137 (137Cs) were deposited immediately around and
downwind of the blast. Figure 3a shows the release scenario and levels of contamination at the
U.S. Mint within the first 72 hours. (In the Aurora scenario, the cesium was spread out over a
far larger area.) Based on this scenario, some tools that EPA has been developing to assist in
wide-area remediation activities were used to estimate the quantity and residual activity of the
waste generated from the hypothetical RDD incident at the U.S. Mint as described above. The
Incident Waste Assessment and Tonnage Estimator (l-WASTE) tool (EPA, 2011a) was used to
estimate the building contents, and the Waste Estimation Support Tool (WEST) (EPA, 2012a)
was used to estimate building stock, building composition and square footages, and the
makeup of the outdoor areas. WEST makes extensive use of the Federal Emergency
Management Agency's (FEMA's) Hazards U.S. Multi-Hazard (Hazus-MH) loss estimation model
(FEMA, 2010). Information on PPE waste generated from response operations was based on
information derived from the Bio-response Operational Testing and Evaluation (BOTE) program
(Lemieux et al., 2011). It must be caveated that every discipline has different procedures and
different clothing used to prevent personal contamination and information generated from the
BOTE program may have limited applicability to a radiological incident.
46
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
In the discussion on the following pages, the estimated contamination levels are used solely for
development of the discussions on the quantity, makeup, and residual radioactivity of the
waste. The estimated contamination levels should not be construed to be cleanup levels. For
example, the 15-millirem-per-year dose level used to determine what is contaminated is not
specified as a cleanup level by any federal program. In this scenario, there may be extensive
contamination beyond the drawn plumes, and areas outside the drawn plumes may require
decontamination as well.
C**np g
Figure 3a. WARRP RDD scenario releases at U.S. Mint.
Figure 3b shows how weather affects plume variability. Weather data from surrounding
weather stations were used to analyze fallout patterns at noon on the 15th of each month in
2006. These images are not meant to portray ail possible fallout patterns and do not illustrate
the U.S. Mint scenario; however, they do illustrate the complexity and variability of plume
patterns (Buddemeier, 2009).
47
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Buildings © District of Columbia (GS GIC), © 2008 Europa Technologies, Image © 2008 Sanborn, £ 20Q8Tele Atlas
Figure 3b. Example of 12 different fallout patterns for Washington, DC.
A major wastewater treatment plant that serves approximately one million people in Denver
and the surrounding area is situated within the plume impact zone shown in Figure 3a,12
Contamination in this area may impact the ability to receive and treat wastewater. For
combined systems, rain water runoff could transport the contaminant to both disperse the
contaminant outside the area and to the wastewater treatment plant. For separate systems,
storm drains could also disperse the contaminant outside the area impacted by the plume. If
wastewater treatment is compromised, downstream water intakes for drinking water systems
could be more highly contaminated than the facility is able to handle, which might necessitate
implementing a temporary pre-treatment step or even shutting down the downstream water
intakes and providing drinking water from another source.
Figure 4 shows the estimated number of affected structures in the primary contaminated area
according to building use. The following assumptions about the affected infrastructure were
used; (1) the number of schools and hospitals was determined from the Hazus-MH model
output; (2) all small wood buildings and mobile homes were assumed to be residences; (3) the
rest of the general building stock was assumed to be offices (99 %) and hotels (1 %); and (4)
percentage breakdowns of building size were assumed to be small (50 %), medium (30 %), and
large (20%) (FEMA, 2010).
Based on these assumptions, two different hypothetical remediation scenarios were developed,
using WEST to investigate the impact of different decontamination and demolition strategies on
the total amount and characteristics of the waste. Both scenarios assume that all affected areas
at 15 millirem or higher were remediated. It is possible that areas contaminated at levels below
15 millirem will also be remediated, but for the purposes of this hypothetical waste estimate,
12 The wastewater treatment plant is just south of the intersection of I-76 and I-270.
48
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
they were not included. The "Extensive Decontamination" option included a significant amount
of demolition and washing of outdoor areas, coupled with extensive interior decontamination.
The "Limited Decontamination" option included less demolition, washing, and interior
decontamination than the "Extensive Decontamination" option. Some of the following figures
demonstrate the impact of these two hypothetical scenarios.
Figure 5 shows the estimated quantities and sources of waste from the affected areas. Figure 6
shows the estimated composition of the waste from the affected areas. Figure 7 shows the
estimated average activity of the waste generated from the cleanup. Figures 5 through 7 also
illustrate the differences between the "Extensive" and "Limited" decontamination strategies.
Due to the overwhelming quantities of certain categories of waste materials potentially
generated from the outlying regions of the plume, the differences between the two
decontamination strategies chosen for this example may not appear to be significant for some
categories of waste generated closer to the blast point. In addition, the WEST tool, in its current
incarnation, assumes that whatever cleanup process is used achieves the stated cleanup goals,
which may not be the case, particularly when comparing disparate cleanup approaches.
The upper end estimate ("Extensive Decontamination" option) of three billion gallons of liquid
waste from demolition and decontamination operations shown in Figure 5 represents roughly 4
% of Denver's annual water usage, suggesting that delivery of wash water in quantities
necessary for the cleanup may be problematic, and that finding ways to reuse wash water and
minimize its discharge as wastewater may be a critical aspect of the response. In addition, the
waste estimate suggests that most solid waste was generated from only a few streams, with
soil, concrete, ceiling tile, carpet, electronics, furniture, and paper constituting a significant
fraction of the waste.
49
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Rad Scenario - Number of Structures
100,000
10,000
1,000
£
3
100
10
1
II
III
«
o
H
C
1
u>
4>
47
s
£
S
JS
HI
tz
"y
£
y
CP
&
na
IL
3?
ra
U.
5
w
c
XI
ft
_
u>
1
Ul
y
o
5
h_
£
"O
£
Q_
s
m
SE
>
HI
N
£
Figure 4. WARRP RDD scenario - estimated number of contaminated structures in area
bounded by <15-millirem contamination zone.
50
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Rad Scenario - Waste Source
LIQUIDS (Total = 1.5 -3 billion gallons)
SOLIDS (Total * 16-21 million tons)
l.E+10
l.E+09
l.E+08
l.E+07
l.E+06
l.E+05
l.E+04
l.E+03
l.E+02
l.E+01
1.E+00
si OD
I Limited Decon
i Extensive Decon
Figure 5, Estimated quantities and sources of waste from WARRP RDD scenario in area
bounded by <15-millirem contamination zone.
51
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Rad Scenario - Waste Distribution
10,000,000
c
,o
1,000,000
100,000
10,000
i Limited Decon
Extensive Decon
Figure 6. Estimated breakdown of solid waste from WARRP ROD scenario in area bounded by
<15-millirem contamination zone.
52
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
2500
2000
cr>
,£ 1500
G
a.
¦§ 1000
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
8. REFERENCES
A. Nisbet, et al., UK Recovery Handbooks for Radiation Incidents: 2009, Health Protection
Agency, Chilton, 2009, pp. 3.
B.R. Buddemeier and M.B. Dillon, Key Response Planning Factors for the Aftermath of Nuclear
Terrorism. August 2009. Available at: https://narac.llnl.qov/uploads/IND ResponsePlanninq LLNL-
TR-410067web.pdf. accessed March 24, 2015.
DHS (2008a). National Incident Management System. Department of Homeland Security.
December 2008. Available at: http://www.fema.qov/pdf/emerqencv/nims/NIMS core.pdf. accessed
February 28, 2015.
DHS (2006). U.S. Department of Homeland Security, National Planning Scenarios, Version 21.3,
Final Draft, March 2006. Available at: http://publicintelliqence.net/national-planninq-scenarios-version-
21 -3-2006-final-draft/. accessed February 28, 2015.
DHS (2013). National Response Framework, Second Edition, May 2013.
http://www.fema.gov/national-response-framework/. accessed March 2, 2016.
DOE (2012a). Federal Radiological Monitoring and Assessment Center Monitoring Manual
Volume 1, Operations DOE/NV/25946-1554 July 2012.
EPA (2013), Protective Action Guides and Planning Guidance for Radiological Incidents - Draft
for Interim Use and Public Comment, in PAG Manual, US Environmental Protection Agency,
2013.
EPA (2012a). Radiological Dispersal Device (RDD) Waste Estimation Support Tool (WEST)
Version 1.2 (Final Report, Spreadsheet, GIS Scripts). EPA-600/R-12/594.
EPA (2011a). I-WASTE (Incident Waste Assessment and Tonnage Estimator). Available at:
http://www2.erqweb.com/bdrtool/loqin.asp. accessed February 28, 2015.
FEMA (2014). Debris Management Planning for State, Tribal and Local Officials. Online training
course E202, offered by the Federal Emergency Management Agency, Emergency Management
Institute. Accessed December 10, 2014, at
http://training.fema.gov/emicourses/crsdetail.aspx?cid=E202&ctvpe=R
FEMA (2010). HAZUS-MH Version 1.4. Department of Homeland Security, Federal Emergency
Management Agency. Available at: http://www.usehazus.eom/forums/viewthread/132/#143. accessed
February 28, 2015.
FEMA (2008). Nuclear/Radiological Incident Annex. Federal Emergency Management Agency.
Available at: http://www.fema.qov/pdf/emerqencv/nrf/nrf nuclearradioloqicalincidentannex.pdf. accessed
February 28, 2015.
Lemieux, P., J. Wood, T. Nichols, C. Yund, E. Silvestri, J. Drake, S. Minamyer, M. lerardi, M.
Meltzer, B. Amidan and S. Rossberg (2011). BOTE Preliminary Results: Cost Analysis.
Presentation for EPA's Decontamination R&D Conference, November 1-3, 2011.
54
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
APPENDIX A: RADIOLOGICAL CONTAMINATION MITIGATION THROUGH
TECHNOLOGIES FOR CONTAINMENT AND GROSS DECONTAMINATION WASTES
Based on input from the stakeholder workshop and the three-city meetings, the first
responders who were in attendance indicated that they would not be intentionally focused on
any waste management activities during the first 72 hours. This is why waste management
activities should be planned out prior to the incident and documented, trained, and exercised
on ahead of an incident. In this manner, they become an inherent part of the early phase
response process, not just an afterthought.
In addition to the activities described previously, Radiological Contamination Mitigation (RCM)
can be accomplished through containment and gross decontamination. Containment
technologies for RCM help prevent resuspension, migration, and movement of radioactive
solids from a surface, but do not remove them from the surface. Gross decontamination
technologies for RCM remove radioactive contaminants from surfaces, potentially reducing
radiation exposure. The selection of site-appropriate containment and gross decontamination
approaches will reduce the waste management burden. To develop effective and efficient
cleanup strategies, a systems approach should generally address containment, gross
decontamination, and waste management simultaneously. Implementing these strategies will
expedite and minimize cleanup by improving cleanup efficiency, reducing waste volume,
maximizing the segregation of waste into homogeneous waste streams, and separating higher-
activity materials from lower-activity materials.
Mitigation may implement the same technologies used for decontamination, but in accelerated
or different manner than used in decontamination for reoccupancy. However, planning for
mitigation has distinct elements as planning for decontamination, and selection of mitigation
approaches may influence choices for decontamination approaches, potentially impacting the
timeline and resource requirements of decontamination, both positively and negatively. In the
worst case, improper mitigation approaches make decontamination of an area to return it to its
former use impossible. It may also greatly complicate waste management, for instance, by
inadvertently creating hot spots through ill-considered staging of waste.
Participants in the stakeholder workshops and the three city meetings were asked their
preference about which containment and gross decontamination technologies to emphasize;
their responses helped to focus on-going research efforts into the development and application
of these technologies. At the time of writing of this SOG, this research is on-going and will be
presented in the application being developed as part of the project. When available, this
information will be available through the application, as well as conventional avenues.
Table A-l lists containment technologies considered by Stakeholder Workgroups. Table A-2 lists
gross decontamination technologies considered by the Stakeholder Workgroups. The
technologies in Table A-2 were considered in conjunction with a number of options/approaches
for containing contaminated water resulting from the use of the gross decontamination
technologies (Table A-3). Finally, stakeholders were interested in a number of surfaces to which
gross decontamination might be applied (Table A-4).
A-1
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Table A-l. Containment Technologies considered by Stakeholder Workgroup
No.
Containment Technology
1
Water application/ fogging nozzle
2
Fire-fighting foam: Wet foam (protein, fluoroprotein, aqueous film-forming)
3
Gels/Polymers (e.g. DeconGel, ANL Supergel, NEI WES Strip)
4
Decon Foams (InstaCote Autofroth, Global Matrechs, NuCap, SNL AFC-380 and SF-
200, CTRI CASCAD SDF, Dow FrothPak, Celcore GeoFill)
5
Montmorillonite, kaolinite, illite
6
Chloride Salts(CaCl2, MgCh w or w/o road salt)
7
Hazmat materials SDF-200 (in addition to typical foams)
8
Dry firefighting foam (high expansion)
9
Dust Wetting Agents (e.g. propylene glycol products)
10
Rad-Specific Epoxys (e.g. InstaCote CC Epoxy SP, InstaCote M-25 [ML])
11
Rad-Specific Acrylics (e.g. InstaCote CC Strip, CC Wet and CC Fix, Bartlett Stripcoat
TLC and Polymeric Barrier System, Isotron RADblock, ALARA and IsoFix)
12
Commercial Paint
13
Dust Surface Crusting Agents (e.g. acrylics)
14
Fire-extinguishers: CO2; Purple K (potassium bicarbonate)
15
Mulch
16
Gravel
17
Dust Binding Agents (e.g. lignin, emulsions)
18
Sand
19
Cakes (e.g. AGUA A3000)
20
Lignin
21
Imported Soil (non-local, non-contaminated)
22
Straw
23
Road oil
24
Emulsified Petroleum Resins
A-2
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Table A-2. Gross Decontamination Technologies considered by Stakeholder Workgroup
No. Gross Decontamination Technology
Additives to water used for fire hosing, high pressure washing, or garden hosing
1 that help remove contamination and allow on-site collection and treatment of
wash water.
2 Fire hose (low pressure, high flow)
Additives to water used for fire hosing, high pressure washing, or garden hosing
^ that help remove contamination but allow release of water from site to sewer
system or the environment. Downstream exposure to radiation is possible unless
downstream treatment is feasible.
4 Debris removal (by "hand", by street sweepers, and other mechanical means)
5 High pressure washers (high pressure, low flow)
6 Scrubbing (prior to fire hosing, high pressure washing, or garden hosing)
7 Garden hose (low pressure, low flow)
Table A-3. Approaches to contain water generated from gross decontamination technologies
listed in Table A-2
No. Gross Decontamination Technology Containment Approaches
1 On-site waste water containment option: Berm
2 On-site wash water containment option: Vacuuming runoff
3 On-site waste water containment option: Storage ponds/tanks
A-3
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Table A-4. Surfaces of interest to Stakeholders for possible application of gross
decontamination technologies
No.
1
Asphalt (roadways)
2
Brick (buildings)
3
Concrete (roadways)
4
Granite (building and floors)
5
Asphalt and composition roofing materials
6
Tarmac
7
Tar roofs
8
Exterior cement board on buildings.
9
Lawns
10
Exterior vinyl siding on buildings.
11
Dirt
12
Painted metal on vehicles
13
Glass (windows)
14
Exposed wood (pressure treated)
15
Exposed wood (other construction materials)
16
Shattered Glass
17
Slate shingle roofing
18
Stucco
19
Exterior paint on buildings
20
Railroad rails and gravel beds
21
Metal roofing material
22
Clay tile roofing
23
Soils and rocks near shoreline
24
Wood roofs
25
Muddy surfaces
26
Limestone
A-4
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
It should be noted that the mitigation technologies presented in Tables A-l and A-2 overlap
with technologies potentially used for decontamination as summarized in documents such as:
• US EPA, 2006, Technology Reference Guide for Radiologically Contaminated Surfaces,
EPA-402-R-06-003, https://www.epa.gov/sites/production/files/2015-
05/documents/402-r-06-003.pdf. Accessed March 8, 2016.
• US EPA, 2007, Technology Reference Guide for Radioactively Contaminated Media EPA
402-R-07-004, http://www.epa.gov/sites/production/files/2015-
05/documents/media.pdf. Accessed March 8, 2016.
• ITRC, 2008, Decontamination and Decommissioning of Radiologically Contaminated
Facilities, http://www.itrcweb.org/GuidanceDocuments/RAD5.pdf. Accessed March 8,
2016.
• Public Health England, 2015, UK recovery handbooks for radiation incidents,
https://www.gov.uk/government/publications/uk-recovery-handbooks-for-radiation-
incidents-2015. Accessed March 8, 2015.
Table A-5 replicates the UK Handbook summary of "management options" along with their
purpose, which is similar to the information presented by EPA. The reader is encouraged to visit
the Rad Decon "app" and supported materials for the latest information on the technologies
and topics summarized in the text and tables above.
A-5
-------
Early Phase Waste Staging for Wide Area Radiological Releases Operational Guidelines and Recommendations
Table A-5. UK Handbook's Listing of Management Options for Decontamination Plani
No.
Purpose
Management Option
1
Protection
Control workforce access
2
Protection
Impose restrictions on transport
3
Protection
Permanent relocation from residential areas
4
Protection
Restrict public access
5
Protection
Temporary relocation from residential areas
6
Remediation
Cleaning vehicle ventilation systems and vehicle wheel washing
7
Remediation
Collection of leaves
8
Remediation
Cover grass/soils with clean soil/asphalt
9
Remediation
Demolish/dismantle and dispose
10
Remediation
Fixative/strippable coatings
11
Remediation
Grass cutting and removal
12
Remediation
Manual and mechanical digging
13
Remediation
Modify operation/cleaning of ventilation systems
14
Remediation
Natural attenuation (with monitoring)
15
Remediation
Plowing methods
16
Remediation
Pressure and fire hosing
17
Remediation
Reactive liquids
18
Remediation
Roof cleaning including guttering and downpipes
19
Remediation
Snow/ice removal
20
Remediation
Storage, covering, gentle cleaning of precious objects
21
Remediation
Surface removal (buildings)
22
Remediation
Surface removal (indoor)
23
Remediation
Surface removal and replacement (roads)
24
Remediation
Tie-down
25
Remediation
Topsoil and turf removal
26
Remediation
Treatment of walls with ammonium nitrate
27
Remediation
Treatment of waste water
28
Remediation
Tree and shrub pruning and removal
29
Remediation
Turning paving slabs
30
Remediation
Vacuum cleaning
31
Remediation
Water-based cleaning
A-6
-------
vvEPA
United States
Environmental Protection
Agency
PRESORTED STANDARD
POSTAGE & FEES PAID
EPA
PERMIT NO. G-35
Office of Research and Development (8101R)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
------- |