Download version 0.1 of EM 1110-35-1 Management Guidelines for Working with Radioactive and Mixed Waste.pdf

Download version 0.1 of EM 1110-35-1 Management Guidelines for Working with Radioactive and Mixed Waste.pdf
CEMP-DE
DEPARTMENT OF THE ARMY
U.S. Army Corps of Engineers
Washington, DC 20314-1000
Manual
No. 1110-35-1
EM 1110-35-1
1 July 2005
Engineering and Design
MANAGEMENT GUIDELINES FOR WORKING WITH
RADIOACTIVE AND MIXED WASTE
1. Purpose. This engineer manual (EM) contains planning and management guidelines to
be used for United States Army Corps of Engineers (USACE) work with radioactive
waste, either alone or combined with hazardous or toxic components. This manual
primarily describes regulatory and management responsibilities and their relation to the
Technical Project Planning (TPP) process and the Project Management Business Process
(PMBP) applied to USACE activities at radioactive waste sites. This manual also
disseminates USACE policies and provides guidance on how to accomplish those
responsibilities. This manual is not intended to provide detailed technical
recommendations or sophisticated scientific procedures. The manual will necessarily
incorporate some technical information to provide background for the regulatory and
management responsibilities. In addition to the Department of Defense (DOD) branches,
these responsibilities are defined and enforced by other Federal agencies, including the
Nuclear Regulatory Commission (NRC), the Department of Energy (DOE), the
Environmental Protection Agency (EPA), the Department of Transportation (DOT), and
the Occupational Safety and Health Administration (OSHA). While most of the guidance
included will be applicable to work performed outside the United States, other regulatory
agencies, dose limits, and radioactive handling and disposal regulations may be
applicable.
2. Applicability. The guidelines within this manual are applicable to all USACE elements
and major subordinate commands (MSC) having responsibility through governmental
interagency agreement or by assignment from Headquarters (HQ) USACE for the
remediation of sites contaminated with radioactive materials. These guidelines are
applicable to the accomplishment of both the Military and Civil Works missions of the
USACE. Strictly chemical or biological aspects of sites are not addressed except in
passing reference to their component part of mixed waste.
This manual supersedes EM 1110-35-1, 30 June 1997 and EM 1110-1-4002, 30 June
1997.
DEPARTMENT OF THE ARMY
U.S. Army Corps of Engineers
Washington, DC 20314-1000
CEMP-DE
EM 1110-35-1
Manual
No. 1110-35-1
1 July 2005
Engineering and Design
MANAGEMENT GUIDELINES FOR WORKING WITH
RADIOACTIVE AND MIXED WASTE
TABLE OF CONTENTS
Paragraph
Page
Chapter 1. Introduction
Purpose
Applicability
Distribution Statement
References
Scope
Units, Definitions, and Conversions
1-1
1-2
1-3
1-4
1-5
1-6
1-1
1-1
1-1
1-1
1-1
1-2
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
2-9
2-1
2-2
2-2
2-2
2-2
2-3
2-3
2-4
2-4
3-1
3-2
3-3
3-1
3-2
3-2
Chapter 2. Radioactive and Mixed Waste Project Requirements
Introduction
Health Physicist Involvement
Chemist Involvement
On-site Radiochemistry Labs
Risk Assessor Involvement
Considerations for Cleanup Level Development
Disposal Options
Transportation
Public Perception
Chapter 3. Technical Project Planning (TPP) Approach to Managing
Sites Contaminated with Radioactive and Mixed Waste
TPP Section 1.1 Prepare Team Information Package
TPP Section 1.1.1 Identify the Team Members
TPP Section 1.1.2 Identify the Customer’s Goals
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Paragraph
TPP Section 1.1.3 Gather Existing Site Information
TPP Section 1.1.3.5 Conduct Site History Interviews
TPP Section 1.2.2 Identify and Document Project
Objectives
TPP Section 1.3.2 Define Courses of Action for
Achieving Site Closeout
TPP Section 2.1 Determine Data Needs
Sample Quantity
Page
3-4
3-5
3-6
3-3
3-3
3-3
3-7
3-3
3-8
3-9
3-6
3-7
4-1
4-2
4-3
4-4
4-1
4-1
4-1
4-2
5-1
5-2
5-3
5-4
5-1
5-1
5-2
5-3
5-5
5-6
5-7
5-8
5-3
5-4
5-4
5-4
6-1
6-2
6-3
6-4
6-5
6-1
6-1
6-3
6-3
6-3
7-1
7-2
7-1
7-1
Chapter 4. Health and Safety
Introduction
Responsibilities
Programs and Plans
Radiation Protection Items Addressed in the SSHP
Chapter 5. Risk Assessment
Introduction
Risk Assessment and Dose Assessment Comparison
Role of Risk Assessment in Regulatory Programs
Regulatory Guidance for Risk Assessments and
Dose Assessments
CERCLA
RCRA Guidance
NRC Guidance
Considerations for Project Risk Assessments
Chapter 6. Sampling
Data Quality Objectives (DQO)
Scanning
In-Situ Measurements
Down-hole or Well Logging
Sampling Surface Soils
Chapter 7. Characterization
Introduction
Chemical and Radioactive Contaminants
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Paragraph
Site Characterization
Waste Characterization
Site History and Waste Pedigree
Quantifying Contaminated Materials
Other Media - Air, Water, Sediments
Page
7-3
7-4
7-5
7-6
7-7
7-2
7-2
7-5
7-5
7-5
8-1
8-2
8-3
8-1
8-1
8-3
9-1
9-2
9-1
9-2
9-3
9-12
9-4
9-5
9-6
9-17
9-25
9-27
10-1
10-2
10-3
10-4
10-5
10-6
10-7
10-8
10-9
10-10
10-11
10-12
10-13
10-14
10-15
10-1
10-1
10-1
10-1
10-1
10-2
10-2
10-2
10-2
10-3
10-3
10-3
10-4
10-4
10-4
Chapter 8. Radioactive Waste
Classification
Waste Definitions
Waste Disposal Facility Criteria
Chapter 9. Primary Regulatory Processes
Introduction
Environmental Response Authorities for Radioactive
Waste or Mixed Waste
Roles and Responsibilities for Regulating Radioactive
Material
Other Major Environmental Statutes and Regulations
Summary of Radiation Standards
Miscellaneous Criteria
Chapter 10. Remedies and Innovative Technologies
Introduction
Attenuation through Decay
Decontamination
Soil Volume Reduction
Soil Washing
In-situ Phytoremediation
Ex-situ Soil Treatment
Equipment and Debris
Cutting and Sawing
Incineration
Building Demolition
Hydroblasting
Paint Removal
Scarification
Steam
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Paragraph
Page
10-16
10-17
10-4
10-4
11-1
11-2
11-3
11-4
11-5
11-6
11-7
11-8
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11-1
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12-2
12-3
12-4
12-4
12-4
13-1
13-2
13-1
13-1
Drilling and Spalling
Disposal
Chapter 11. Transportation
Introduction
Determining if Packages are Radioactive for Shipping
Packaging
Marking
Labeling
Manifesting
Placarding
Mixed or Co-Mingled Waste
DOT Required Security Plans
Chapter 12. Disposal
Introduction
Characterization of Materials
Identify and Coordinate with Potential Disposal Facilities
Compare Transportation and Disposal Costs of Viable
Facilities
The Off-site Rule
Facility Regulators
Transportation Requirements
Disposal Contracts
Disposal Options Available as of January 2003
USACE and DA Coordination
Chapter 13. Multi-Agency Radiation Site Survey and
Investigation Manual (MARSSIM)
Introduction
Data Life Cycle
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Page
APPENDICES
Appendix A - References and Bibliography of Regulatory Documents,
Regulations and Laws
A-1
Appendix B - Radiation Control Agency Points of Contact
B-1
Appendix C - Technical Information on Radioactive Materials,
Decay, Measuring Techniques, and Instrumentation
C-1
Appendix D - Typical Remediation Site Characteristics
D-1
Glossary
Glossary-1
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LIST OF TABLES
Page
Table 9-1. Major Radiation Standards Summary Table
9-26
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LIST OF FIGURES
Page
13-1. Data Life Cycle Applied to a Final Status Survey
13-3
13-2. Flow Diagram for Designing a Final Status Survey
13-4
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CHAPTER 1
Introduction
1-1. Purpose. This engineer manual (EM) contains planning and management guidelines to
be used for United States Army Corps of Engineers (USACE) work with radioactive waste,
either alone or combined with hazardous or toxic components. This manual primarily
describes regulatory and management responsibilities, provides guidance on accomplishing
those responsibilities, and explains their relation to the Project Management Business Process
(PMBP) and Technical Project Planning (TPP) applied to USACE activities at radioactive
waste sites. Additionally, this manual will promote USACE policies to ensure Corps-wide
application across all programs. This manual is not intended to provide detailed technical
recommendations or sophisticated scientific procedures. The manual will necessarily
incorporate some technical information to provide background for the regulatory and
management responsibilities. In addition to the Department of Defense (DOD) branches,
these responsibilities are defined and enforced by other Federal agencies, including the
Nuclear Regulatory Commission (NRC), the Department of Energy (DOE), the
Environmental Protection Agency (EPA), the Department of Transportation (DOT), and the
Occupational Safety and Health Administration (OSHA).
1-2. Applicability. The guidelines within this manual are applicable to all USACE elements
and major subordinate commands (MSC) having responsibility through governmental
interagency agreement or by assignment by HQUSACE for the remediation of sites
contaminated with radioactive materials. These guidelines are applicable to both the Military
and Civil Works missions of the USACE. Strictly chemical or biological aspects of sites are
not addressed except in passing reference to their component part of mixed waste. While
most of the guidance included will be applicable to work performed outside the United
States, other regulatory agencies, dose limits, and radioactive handling and disposal
regulations may be applicable.
1-3. Distribution Statement. Approved for public release; distribution is unlimited.
1-4. References. References are at Appendix A. Referenced documents throughout the text
are hyperlinked to internet available copies when possible.
1-5. Scope.
a. Intended Audience. This document is intended to assist Project Managers in the
development of Project Management Plans and supporting documents that will lead to the
successful restoration of sites contaminated with radioactive material. Guidance is included
to ensure that each Project Delivery Team (PDT) is established with the necessary disciplines
and perspectives. Individuals asked to work on radioactively contaminated sites may find the
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document useful in understanding and fulfilling their role as members of the PDT. Various
terms, regulations, and processes used in the restoration of radioactively contaminated sites
are described to facilitate effective communication between the PDT members and
stakeholders.
b. Contents.
• Chapter 1 explains the purpose, scope and intended audience of this guidance
document. It lists some important units, quantities and conversions that are necessary to fully
understand and work on remediation of radioactively contaminated sites.
• Chapter 2 explains how the presence of radioactive waste affects the necessary
actions and associated management of a project.
• Chapter 3 explains the TPP approach to managing remediation at sites contaminated
with radioactive materials.
• Chapter 4 discusses health and safety concerns relative to a radioactive site.
• Chapter 5 describes the conceptual site model and risk assessment.
• Chapter 6 describes sampling of radioactive materials.
• Chapter 7 describes characterization of sites.
• Chapter 8 describes characterizing radioactive waste.
• Chapter 9 addresses the primary regulatory processes involved at radioactive
remediation sites.
• Chapter 10 addresses remedies and innovative technologies that may be used at
radioactive remediation sites.
• Chapter 11 explains the procedures and issues involved in transportation of
radioactive materials.
• Chapter 12 discusses options and methods of disposal of radioactive materials.
• Chapter 13 discusses the Multi-Agency Radiation Site Survey and Investigation
Manual (MARSSIM) Final Status Survey (FSS).
• Appendix A provides references and bibliography of regulatory documents,
regulations and laws.
• Appendix B provides contact information for Federal and state radiation control
agencies.
• Appendix C includes technical information on radioactive materials, decay,
measuring techniques, and instrumentation.
• Appendix D lists some typical remediation site characteristics.
1-6. Units, Definitions, and Conversions. Several systems of units are applicable to USACE
radioactive materials sites. The following is a brief description of the units, what they
measure, and how they will be used on USACE sites. Conversions between different
systems of units are included where appropriate. A more complete explanation may be found
in EM 385-1-80.
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a. Radioactivity or Activity. Radioactivity is unstable atomic nuclei becoming more
stable by emitting energy. The types and amounts of energy emitted are characteristic of the
radioactive material. The radioactivity or activity of a material is the rate of decay per unit
time. There are two systems that are used to measure activity: the US system and the
System International (SI). In this manual, when reporting activity, the US system units will
be listed first, followed by the SI unit in parentheses.
(1) US System. Activity is measured using the curie (Ci). 1 Ci is 3.7 × 1010 decays
per second (1 gram of pure radium has 1 Ci of activity).
(2) SI. Activity is measured using the becquerel (Bq). 1 Bq is 1 disintegration per
second.
1 Ci = 3.7 × 1010 Bq
1 Bq = 2.7 × 10–11 Ci
(3) Specific Activity (activity per unit mass). This is reported as Ci/g (Bq/kg). Note
that DOT requires SI units to be entered on shipping papers and labels. US customary units
may accompany the SI units in parentheses.
(a) Activities and specific activities may use metric prefix abbreviations as follows:
Prefix Abbreviation Quantity
Tera
T
1×1012
Giga
G
1×109
Mega
M
1×106
Kilo
k
1×103
Milli
m
1×10–3
Micro µ
1×10–6
Nano
Pico
1×10–9
1×10–12
n
p
(b) Several related units may be encountered on USACE sites. Their acceptability
should be determined by the USACE health physicist assigned to the site.
b. dpm. Disintegrations (decays) per minute is often used in referring to surface
contamination, most often as disintegrations per minute per one hundred square centimeters
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(dpm/100 cm2); dpm can be converted to Bq or Ci. Some survey instruments purport to
present data in dpm. This can only be done correctly under very specific circumstances.
These circumstances and the accuracy of the readings must be verified by a health physicist.
c. cpm. Counts per minute (radiation interactions with the detector) is often reported
for hand held instrument surveys. Under certain very specific circumstances, cpm can be
converted to dpm. A health physicist must be consulted to ensure that an accurate conversion
is performed.
d. (Ionizing) Radiation (as used here). This is the energy emitted from radioactive
material traveling from one point to another in the form of photons or particles. Depending
upon how and where it is measured, there are a number of units used to quantify radiation.
The standard units used at USACE sites are the roentgen (coulomb per kilogram), rad (gray),
and rem (sievert).
e. Exposure. This is the amount of ionization in air produced by x- or gamma radiation
with energies less than 3 MeV (mega electron volt). Exposure is the most commonly
measured parameter of radiation. It is measured in roentgen (R). One R is equal to 2.58×10-4
coulomb of electrical charge produced in one kilogram (C/kg) of air.
f. Exposure Rate. This is the readout used by many field survey instruments. It
commonly uses a fraction of roentgen per hour (R/hr), usually milliroentgen per hour
(mR/hr), or micro roentgen per hour (µR/hr).
g. Absorbed dose. This is the energy deposited in matter by radiation. It is measured
in rad or gray (Gy).
1 rad = 100 erg/g = 0.01 Gy
1 gray = 1 J/kg = 100 rad
1 R in air is about equal to 1 rad in soft tissue.
h. Dose Equivalent. This is the absorbed dose in soft tissue multiplied by a quality
factor. The quality factor normalizes the harm done by different types of radiation. The dose
equivalent is a measure of the biological damage expected from absorption of radiation.
(1) Typical quality factors are:
• Beta/gamma radiation ........1
• Alpha radiation.................20
• Neutron radiation .............10
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(2) Dose equivalent is measured in rem (sievert [Sv]).
100 rem = 1 Sv
1 Sv = 100 rem
(3) For x-ray/gamma radiation.
1 R = 1 rad = 1 rem (1 Sv = 1 Gy)
(4) For alpha radiation.
1 rad = 20 rem (1 Gy = 20 Sv)
i. Radioactive Waste. A generic term for wastes containing radioactive materials.
Regulatory agencies have different definitions for different types of radioactive wastes. The
NRC only regulates source, byproduct, and special nuclear materials. The EPA regulates the
hazardous component of mixed wastes. States may regulate other radioactive materials and
radioactive wastes.
j. High-Level Radioactive Waste (HLW). The NRC defines High-Level Radioactive
Waste as 1) irradiated reactor fuel, 2) liquid wastes resulting from operation of the first cycle
solvent extraction system, or the equivalent, and the concentrated wastes from subsequent
extraction cycles or equivalent in a facility for reprocessing irradiated reactor fuel, and 3)
solids into which such liquid wastes have been converted (10 CFR 60). In layman’s terms,
HLW is spent fuel, or spent fuel reprocessing wastes. USACE does no work with HLW at
present.
k. Low-Level Radioactive Waste (LLRW). LLRW is source, byproduct, or special
nuclear material waste not classified as HLW, transuranic waste, spent nuclear fuel, or
byproduct material as defined in section 11e.(2) of the Atomic Energy Act. In layman’s
terms, LLRW is NRC regulated waste that is not HLW, transuranic waste, or uranium or
thorium mill tailings.
l. Transuranic Waste (TRU). TRU is waste materials contaminated with alphaemitting nuclides with an atomic number greater than 92, half-lives greater than 20 years, and
in concentration greater than 100 nCi/g of waste at the time of assay (40 CFR 191).
m. Uranium Mill Tailings Radiation Control Act (UMTRCA). Enacted to ensure
investigation and remediation of past uranium and thorium mine and mill tailings and
regulation of tailings at currently licensed sites.
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n. Uranium or Thorium Tailings (11e.(2) materials). The tailings or wastes produced
by the extraction or concentration of uranium or thorium from any ore processed primarily
for its source material content (Atomic Energy Act). This designation only applies to tailings
generated during or after 1978. This designation is sometimes incorrectly applied to tailings
from the extraction of rare earth elements, which are often co-located in the same ores as
uranium and thorium, or to the tailings from the extraction of radium. For legal reasons,
those tailings generated prior to 1978 are referred to as “residuals from uranium or thorium
ore processing prior to 1978.”
o. Mixed Waste. An NRC regulated radioactive waste containing source, byproduct,
or special nuclear material (LLRW, 11e.(2) or HLW) mixed with an RCRA (Resource
Recovery and Conservation Act) listed or characteristic hazardous material.
p. Combined or Commingled Waste. Any radioactive waste mixed with any hazardous
substance. Mixed waste is a subset of combined or co-mingled waste.
q. DOT Radioactive Material. A material with a total activity concentration exceeding
70 Bq/g (2000 pCi/g) (49 CFR 173.403). Note, this definition shall change under DOT and
NRC harmonization rulemaking on 1 October 2004 to agree with the international definition
of radioactive material. The international definition of radioactive material shall mean any
material containing radionuclides where both the activity concentration and the total activity
in the consignment exceed the values specified in the table in 49 CFR 173.436 or values
derived according to the instructions in §173.433.
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CHAPTER 2
Radioactive and Mixed Waste Project Requirements
2-1. Introduction.
a. Radioactive materials have been used by the DOD and civilians for nearly 100
years. Radioactive commodities and radioactive wastes have been found on all types of
projects. On BRAC (Base Realignment and Closure) and IRP (Installation Restoration
Program) projects, radioactive commodities are the most common type of radioactive waste.
These commodities may include:
• Dials and gauges on vehicles and equipment illuminated with radium paint.
• Electron tubes and diodes containing small quantities of radioactive materials used
extensively in radar and fire control equipment.
• Radioactive tritium illuminators used in exit signs and fire control devices.
• Thorium used in radiation detection equipment and as an alloy.
• Magnesium-thorium, used in the manufacture of aircraft and missile parts.
b. Depleted uranium (DU-natural uranium with the fissionable component reduced or
removed) is used in armor piercing penetrators, high-density armor, radiation shielding, and
aircraft counterweights. A website containing information on all the commodities used in
DOD is available from the Wright–Patterson Air Force Base site. Hospitals and laboratories
use a very extensive list of radioactive materials, sometimes in liquid scintillation vials, and
often combined with human or animal tissue or fluids. Nuclear reactors have a defined mix
of source materials, activation products, and fission products. Nuclear weapons assembly
and maintenance facilities may have uranium, plutonium, and tritium contamination, and the
Formerly Used Sites Remedial Action Program (FUSRAP) sites may have uranium or
thorium ores and mill tailings and their associated decay progeny. Superfund sites have
encountered the widest variety of radionuclides, ranging from radium processing tailings to
transuranics used in sealed source manufacturing.
c. The USACE approach for all projects is to follow the guidance and methodology
outlined in Project Management Business Process (PMBP). Hazardous Toxic and
Radioactive Waste (HTRW) projects follow EM 200-1-2, and when addressing a release of a
hazardous substance to the environment, follow the Comprehensive Environmental,
Response, Compensation, and Liability Act of 1980 (CERCLA) approach. On radioactive
materials sites USACE applies guidance found in the Multi-Agency Radiation Site Survey
and Investigation Manual (MARSSIM).
d. PMBP provides a means of ensuring that the right people, with the right skills and
the right tools, work effectively to complete a project to the satisfaction of the customer, the
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regulators, and stakeholders. TPP (Technical Project Planning) outlines an iterative fourphased approach for ensuring that the project objectives are identified, data collection is
efficient, and the project progresses towards site closeout. CERCLA provides a process for
ensuring authority to conduct projects with public input, and regulatory oversight.
MARSSIM provides guidance on meeting the final status survey and closing out a site.
Projects involving radioactive material can be approached in the same way as other
hazardous materials projects, but with some of the following additions to the team and
modifications of the plan.
2-2. Health Physicist Involvement.
a. Health Physicists (HPs) are technical experts in radioactive materials and radiation.
They can provide expert advice on identifying, sampling, handling, transporting, and
disposing of radioactive materials, measurement of radiation levels and doses, the ecological
and biological effects of exposure to radiation, and the applicable laws, regulations, and
guidance concerning radiation and radioactive materials. A USACE project HP should be
assigned very early in the project planning process, and may need to be involved in both the
decision-making processes and execution throughout the project. Contractors will often be
required to have HP staff and HP technicians.
b. ER 385-1-92 requires the use of Qualified Health Physics personnel for Remedial
Design activities at HTRW sites. Qualified personnel must meet education and experience
requirements listed in EM 385-1-80. The addition of certified health physicists (CHPs), HPs,
and HP techs to a project can significantly increase project costs.
2-3. Chemist Involvement. The project chemist will need to be acquainted with the different
methodologies used for identifying and quantifying radioactive materials. Approved
methods, limits of detection, radionuclide emissions, and appropriate wet chemistry can be
significantly different when radionuclides are involved. Analytical laboratories should be
USACE validated and must be notified in advance that potentially radioactive samples are to
be submitted. The lab will need to ensure appropriate contamination control measures are
used for the radioactive samples. This is in addition to the chemical analyses that may be
required. ER 1110-1-263 sets laboratory data quality requirements. These factors may
increase lab turn around times and analytical costs.
2-4. On-site Radiochemistry Labs. A number of projects have found it economical to have
an on-site radiochemistry lab instead of contracting an off-site lab for routine radiochemistry
analyses. An on-site lab will provide a more rapid turn around for sample analyses.
2-5. Risk Assessor Involvement. To address the complexities of a risk-informed approach to
site clean-up, a risk assessor will need to assist on-site remediation decisions. The data needs
of risk assessors are often different from other team members and may require additional
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sampling and analyses. Where appropriate, a risk-informed regulatory approach can also be
used to reduce unnecessary conservatism in purely deterministic approaches, or can be used
to identify areas with insufficient conservatism in deterministic analyses and provide the
bases for additional requirements or actions. Risk-informed approaches lie between the riskbased and purely deterministic approaches.
2-6. Considerations for Cleanup Level Development. How clean is clean? This
fundamental question must be answered in all environmental remediation projects. It must
be answered at the time when the decision is made as to what response is needed at a site,
and it must be answered again at the end to determine if the required response has been
completed and is successful in operation. The answers to this question are found in a
complex analysis of technical and legal factors established in the laws governing
environmental response action projects.
a. CERCLA requires that response actions be conducted in compliance with the
implementing regulations promulgated by the Environmental Protection Agency, the
National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300
(NCP). The NCP includes a list of hazardous substances, including radioactive elements and
compounds. In addition, if other hazardous substances or pollutants and contaminants are
present, then CERCLA also applies to the cleanup of these other contaminants. CERCLA
authorizes the decision maker for the lead Federal agency to respond through removal or
remedial actions when the release or threat of release of a hazardous substance has created or
may create an imminent and substantial danger to humans or the environment. Remedial
actions provide the permanent remedy necessary to prevent or minimize the release so that
the hazardous substances or pollutants and contaminants do not migrate to cause substantial
danger to present or future public health or welfare or the environment. Removal actions are
required to contribute, to the extent practicable, to the efficient performance of any long-term
remedial action in responding to a release or threatened release.
b. Chapter 9 describes the regulatory processes that authorize USACE to clean up a
site. The primary environmental response authority that USACE follows when addressing a
release of a hazardous substance to the environment is CERCLA.
2-7. Disposal Options.
a. Disposal options for radioactive materials will vary from readily disposable locally,
to no immediate disposal options at all, depending on the type, quantity, concentration, and
pedigree of the radioactive materials. Very early in the planning process and well before any
execution, a disposal plan must be prepared. Kansas City District has a number of pre-placed
contracts for disposal of radioactive waste that may be accessed by all of USACE. The
project HP should be able to assist with initial estimates of potential disposal sites.
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b. Low-Level Radioactive Waste (LLRW) is also under the control of the originating
state’s Low-Level Radioactive Waste Compact. The compacts were originally developed in
1985 to construct and operate radioactive waste disposal facilities within their boundaries.
Currently, there are 10 approved compacts and three active LLRW disposal facilities. Only
two of the three disposal facilities may accept Classes A, B, and C radioactive waste. The
Hanford, Washington, facility only accepts LLRW from the Northwest and Rocky Mountain
compacts, but will accept non-NRC regulated wastes from all states. The Envirocare (Utah)
facility accepts Class A LLRW, 11e.(2), and non-NRC regulated wastes from all regions of
the United States. The Barnwell, South Carolina, facility accepts LLRW from all generators
in the United States except the Rocky Mountain and Northwest compacts. Beginning in
2008, Barnwell will only accept LLRW from the Atlantic Compact states. These compacts
may control the import and export of LLRW to or from their compact, and may assess fees
for import or export. In some cases, payment of these fees by the Federal Government may
violate fiscal law. The appropriate Office of Counsel should be consulted for guidance on
this matter. The Army Field Support Command (AFSC) of Army Materials Command
(AMC) is the operating agency for the Executive Agent for radioactive waste from DOD
activities. All disposal actions for DOD wastes need to be coordinated with AFSC through
the USACE Hazardous, Toxic and Radioactive Waste Center of Expertise (HTRW-CX).
Radioactive wastes generated by Civil Works activities, such as FUSRAP, may not be
considered DOD wastes. Additional guidance on disposal is furnished in Chapter 9.
2-8. Transportation. Transportation requirements for radioactive materials, wastes, and
samples are substantially different from transportation of other types of DOT hazardous
materials. Department of Transportation (DOT) radioactive materials regulations are listed
in 49 CFR 173.401 (Subpart I) et seq. The project HP will be familiar with transportation
requirements. Certain states also charge a fee to transport radioactive waste through them.
In some cases, payment of these fees by the Federal Government may violate fiscal law. The
appropriate Office of Counsel should be consulted. Additional guidance on transportation is
furnished in Chapter 8.
2-9. Public Perception.
a. Most projects involving radioactive materials will receive increased public interest.
PMBP requires the project delivery team (PDT) to develop a communications plan. The plan
requires input and assistance from the Public Affairs Office. Past experience has shown that
addressing all concerns in a truthful and open manner is the simplest method of allaying
public concerns. The HTRW-CX and the Radiation Safety Support Team (RSST) have
developed a number of fact sheets that are available for general use by USACE, our
customers, contractors, and regulators.
b. The communications plan will identify the project stakeholders’ problems, concerns,
and issues. It will then establish an internal and external communication strategy and
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determine the information needs of all PDT members and stakeholders: who needs what
information, when they will need it, how it will be given to them, and by whom.
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CHAPTER 3
Technical Project Planning (TPP) Approach to Managing Sites
Contaminated with Radioactive and Mixed Waste
3-1. TPP Section 1.1 Phase I - Prepare Team Information Package. In addition to the TPP
guidance, there are a number of guidance documents on various aspects of working with
radioactive materials. The Project Manager’s (PMs) guides for TPP, and Radioactive
Materials and seven Engineer Pamphlets (EPs) specifically address work with radioactive
materials. While the Engineer Circulars (ECs) are specifically oriented toward Formerly
Utilized Sites Remedial Action Program (FUSRAP) site remediation, the guidance will help
ensure that sound radiation safety principles are applied at any site. The following Engineer
publications address work with radioactive materials. A brief description of each is included.
a. EM 200-1-2 Technical Project Planning Process. Describes the process for
identifying project objectives and designing data collection programs at all Hazardous, Toxic
and Radioactive Waste (HTRW) sites.
b. ER 385-1-80 Ionizing Radiation Protection. This is the Engineer Regulation for
working safely with radioactive materials.
c. EM 385-1-80 Radiation Protection Manual. Provides explanation and guidance on
methods of complying with ER 385-1-80.
d. ER 385-1-92 Safety and Health Requirements for HTRW Sites. Identifies
documents and procedures required for executing HTRW projects.
e. EP 415-1-266 Resident Engineer Management Guide (REMG) For Hazardous,
Toxic, And Radioactive Waste (HTRW) Projects. Provides requirements of which resident
engineers must be aware regarding remedial design activities and response actions involving
HTRW, and ordnance and explosives response actions.
f. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).
Provides detailed guidance for planning, implementing, and evaluating environmental and
facility radiological surveys conducted to demonstrate compliance with a dose or risk based
regulation. It is a consensus document prepared with concurrence of the EPA, NRC, DOE,
and DOD.
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3-2. TPP Section 1.1.1 Phase I - Identify the Team Members.
a. A diverse group of USACE Technical, Management, Legal, and Public Affairs
personnel, as well as stakeholders, regulators, and contractors, are required for the Project
Delivery Team (PDT). Guidance on establishing the team is provided in the
Project Management Business Process (PMBP) Team Establishment procedure. The PM will
need to identify the decision makers, the data users, and the data implementers needed for the
project. The decision makers may include the PM, the customer, and the regulators.
Regulators may include Federal agencies: the Nuclear Regulatory Commission (NRC), the
Environmental protection Agency (EPA), or the Occupational Safety and Health
Administration (OSHA). Twenty-nine states are NRC agreement states, in which the state
office performs the oversight duties of the NRC. Most states also have a Department of
Environmental Protection and Department of Health, which are concerned with radioactive
materials in the environment and potential human exposure to radiation. State regulatory
agencies do not usually have jurisdiction to regulate Federal facilities, but the final
disposition of the property may be subject to state regulatory oversight. Ensure that the
USACE Office of Counsel is included in the TPP team to determine which regulatory
agencies have which oversight responsibilities.
b. The data users may include a radio-chemist, a health physicist (HP), an Industrial
Hygienist (IH), a risk assessor, and quality assurance personnel for each discipline.
c. Stakeholders may include the local city, county, and state community, site owners,
site workers and contractors, and trade unions, as well as local and national environmental
organizations.
3-3. TPP Section 1.1.2 Phase I - Identify the Customer’s Goals.
a. Once the customer has been identified, ensure that the entire TPP team understands
exactly what the customer envisions at the completion of the project, and what the customer
sees as the role of USACE in the project.
b. The customer’s concept of site closeout may range from removal and disposal of all
radioactive and hazardous materials and a survey to allow the site to be released without
restrictions (unrestricted release), to treatment, on-site storage, or on-site disposal of the
materials to allow for limited reuse of the site (restricted release). When a restricted release
is contemplated, land use controls (LUCs) must be considered. The objective when
implementing LUCs is to ensure that land use remains compatible with the remedial action
goals, and that the remedy remains protective of human health and the environment. The
customer’s schedule requirements and site budget must also be considered at this time.
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3-4. TPP Section 1.1.3 Phase I - Gather Existing Site Information. This operation, coupled
with Paragraph 3-5, is the equivalent of the MARSSIM Historical Site Assessment, and the
CERCLA Preliminary Assessment. In addition to the normal avenues, site information may
be obtained from a wide variety of other sources. Atomic Energy Commission or Nuclear
Regulatory Commission licenses and amendments, Army radiation authorizations, Air Force
radiation permits, local land use permits, as well as the site owner or operator’s records may
provide information on the past activities at the site. Additionally, USACE archivists are
available who are experienced in gathering documents relating to sites. If possible, attempt
to obtain facility operating procedures and inventories, and define the receipt, use, storage,
and disposal areas for the hazardous and radioactive materials on the site. Capture a
description of all the background literature into a single document, and ensure that the
background information is available to all data users and implementers. Appendix D lists
contaminants of concern and items of interest on some typical sites where remediation may
take place.
3-5. TPP Section 1.1.3.5 Phase I - Conduct Site History Interviews. Consider not only
former and present site workers, but also past and present regulators and inspectors. Many
sites using radioactive materials also had some form of area dose monitoring. These records
may also prove valuable in estimating potential hazards at the site.
3-6. TPP Section 1.2.2 Identify and Document Project Objectives. Most project objectives
are a consequence of governing statutes and applicable regulations. Identifying and
interpreting these statutes and regulations varies quite widely from site to site, among
regulatory agencies, and even among regional offices within the same agency. Chapter 9
looks in depth at the existing statutes and regulations that are commonly applicable to
radioactive waste sites. The primary regulations used for remediation of radioactive
materials at a site are:
•
•
•
•
•
10 CFR 20 NRC Subpart E
10 CFR 40 NRC
40 CFR 300 CERCLA
40 CFR 192 UMTRCA
State Regulations
After review by counsel, the applicable regulations should be included in this document.
This document should specifically identify all impacted areas. An impacted area is one
where there is a potential for radioactive contamination. These areas need to be bounded,
spatially and temporally. The document must also identify the potential radioactive
contaminants, and identify the executable project stages to site closeout.
3-7. TPP Section 1.3.2 Define Courses of Action for Achieving Site Closeout. A release
criterion is a regulatory limit expressed in terms of dose (mSv/year or mrem/year) or risk
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(cancer incidence or cancer mortality). The terms release limit or cleanup standard are also
used to describe this expression. A release criterion is typically based on the total effective
dose equivalent (TEDE), risk of cancer incidence (morbidity), or risk of cancer death
(mortality) and generally cannot be measured directly. Exposure pathway modeling is used
to calculate a radionuclide-specific predicted concentration or surface area concentration of
specific nuclides that could result in a dose (TEDE) or specific risk equal to the release
criterion. This concentration is termed the derived concentration guideline level (DCGL).
Exposure pathway modeling is an analysis of various exposure pathways and scenarios used
to convert dose or risk into concentration. In many cases screening level DCGLs can be
obtained from responsible regulatory agency guidance based on conservative modeling input
parameters, while other users may elect to take into account site-specific parameters to
determine DCGLs. In general, the units for the DCGL are the same as the units for
measurements used to demonstrate compliance (e.g., Bq/kg or pCi/g, Bq/m2 or dpm/100
cm2). This allows direct comparisons between the survey results and the DCGL. While
exposure pathway models, such as RESRAD or RESRAD-BUILD, can provide a defensible
starting point, stakeholders must concur with the exposure model parameters used as well as
with the DCGLs determined. Other factors, such as ARARs (applicable or relevant and
appropriate requirements), and public opinion, may set DCGLs at different quantities. The
TPP and communication processes are meant to ensure that all interests are consulted and a
consensus DCGL is reached that is acceptable to all stakeholders.
a. If the site is contaminated above the screening levels, the next step is to determine
the DCGLs. Clean-up criteria provided by the EPA are given in units of risk, which cannot
be measured. NRC criteria are provided in units of dose. DCGLs are the contaminant
concentrations, which can be measured, that, when entered into an exposure model, yield a
dose or risk that can be compared to the guidance provided by the regulatory authority.
DCGLs are better explained in Paragraph 3-10. These DCGLs are the concentrations of
contaminants below which the average concentration must fall for the project to be
considered for release and closure. DCGLs will contain four units: an average radionuclide
concentration that the site average concentration will not exceed, an area over which this
concentration may be averaged, a maximum concentration that hot spots will not exceed, and
the maximal area of these hot spots. Note that the DCGLs depend on the site conditions and
the exposure models used. DCGLs may not be even in the same order of magnitude between
different sites. For example, the DCGL determined for a site located in a residential area was
35 pCi/g while the DCGL for the same contaminant located in an industrial area was set at
1950 pCi/g.
b. For the project to be viewed as a success by all stakeholders, the ideal scenario is
reaching a consensus value for the DCGLs. Federal and state regulators, as well as the lead
agency at the site, the customer, and the other stakeholders, should all agree on the DCGLs.
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c. The most common method of determining a starting point for DCGLs for a site is
through the use of the RESRAD and RESRAD-BUILD dose modeling programs. These
programs provide a method for calculating the dose to a recipient from the soil or building
surface contamination concentrations, or both. The programs provide very conservative
default parameters that may be used or modified if site-specific data are available for the
parameters. These programs have both been approved for use by the NRC, EPA, DOD, and
DOE.
d. When default parameters are not used, documentation explaining why the new value
is considered appropriate must be included in the DCGL development report. Many default
parameters will be changed on the basis of actual site conditions. For example, area of
contamination, depth of cover, depth of contamination, depth to ground water, distance to
nearest surface water, etc., can be referenced back to the site description and geological and
hydrogeological reports. The report determining those actual site conditions must be
referenced in the documentation of the parameter change.
e. NRC and USACE regulations also require all remediation to meet ALARA (doses as
low as is reasonably achievable). This means that the DCGL will be the maximally allowed
average contamination concentration, but the project will strive to remediate all media to as
low a level of residual contamination as is reasonably achievable, taking into account the
various social and economic factors affecting the site. However, if a site is remediated to
NRC screening levels, it is considered to have met all ALARA requirements. Here, if there
is a contaminant on-site that warrants any further investigation or remediation, decisions
have to be made on what needs to be determined to select the method of remediation.
f. There are a number of methods that have been used to remediate sites. The primary
method found to be cost effective and that meets the expectations of the regulators and the
public, so far, is excavation and off-site disposal. A few sites have been allowed to use burial
in place. There are also a few innovative technologies that have been investigated at
different sites. The most common reduces waste volume using soil sorting and washing or
segmented gate systems. Some efforts at bioremediation have been studied and shown to be
effective in pilot studies.
g. The basic objective for radioactive waste sites is completion of a final status survey
indicating that the Derived Concentration Guideline Levels (DCGLs) have been met at each
impacted area. The phases necessary to reach this point will have interim objectives, and the
interim objectives will have different data needs. Common problems are overestimating the
amount and type of data actually needed for completion of a phase, and not ensuring that all
data can be shared between phases for use in the final status survey. Another is project
creep, where subsurface radioactive materials not discovered during the initial
characterization are found during remediation and the remediation ‘chases’ the contamination
into greater than expected volumes of contaminated soils.
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3-8. TPP Section 2.1 Determine Data Needs. During the characterization phase, data
gathered during the historical site assessment are used to determine potential radioactive and
hazardous contaminants, and potentially impacted areas. From these data, a preliminary site
conceptual model is constructed. From the site conceptual model, potentially impacted areas
are selected. Data gaps will exist and additional information concerning the actual quantity,
horizontal and vertical extent of contamination, the radionuclides actually present on-site,
and the natural background concentrations of the radionuclide contaminants will be needed.
Once samples are gathered and analyzed, and these data are available, the remediation phase
data needs change. Isotopic analyses, necessary to determine the radionuclides of concern,
may no longer be necessary and less expensive survey and analysis methods can be used. If
no site work that could substantially concentrate or dilute the contaminants in the waste
stream was done, the data from the characterization sampling and from the remediation
surveys and sampling can be used to characterize the waste stream, lowering the total number
of samples necessary. During the final status survey phase, the data needs may change again.
Surveys and samples from the characterization and remediation phases may be used to show
that the potentially impacted areas do in fact meet the DCGLs. Additional survey and
samples will be needed to verify screening levels. A number of regulatory agencies have
determined screening levels for site evaluations in the PA/SI (Preliminary Assessment/Site
Inspection) and RI/FS (Remedial Investigation and Feasibility Study) stages of the
investigation. The EPA has developed a web based Preliminary Remediation Goals (PRGs)
calculator, and the NRC has released NUREGs providing guidance on using certain
computer models to determine surface soil and building surface screening levels.
a. EPA PRGs for radionuclides are tools used to evaluate soils contaminated with
radioactive materials at sites with various future land uses. PRGs are not national cleanup
standards. PRGs alone do not trigger the need for response actions or define “unacceptable”
levels of radionuclides in soil. In this guidance, “screening” refers to the process of
identifying and defining areas, radionuclides, and conditions, at a particular site, that do not
require further attention. Generally, at sites where radionuclide concentrations fall below the
appropriate PRGs, no further action or study is warranted. Where radionuclide
concentrations equal or exceed PRGs, further study or investigation, but not necessarily
cleanup, is warranted.
b. By their nature these values will always be extremely conservative, sometimes to the
point of being a fraction of background concentrations of a radioactive contaminant.
c. For example, uranium has a widely ranging background concentration depending on
the rock/soil type. The National Council on Radiation Protection reported an average soil
concentration of 1.8 pCi/g in its Report No. 94. The NRC NUREG-1757, Vol. 2 provides a
U-238 plus progeny soil screening level of 0.5 pCi/g above background. The NRC assumes
parameters based on a residential farmer scenario. Though not necessarily directly
comparable to the NRC value, the EPA PRG calculator provides default PRGs for an
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agricultural scenario and a residential scenario. The default PRG values for U-238 plus
progeny are 0.00147 pCi/g (agricultural), and 0.742 pCi/g (residential).
d. Should the average of all contaminant samples be less than the selected screening
value, the site may be ready for closeout with no further action, provided the samples are of
sufficient quality and number to meet the statistical tests provided in the MARSSIM.
3-9. Sample Quantity.
a. The number of samples required to adequately characterize a site or an incremental
portion of a site, such as an operable unit (OU), depends on a number of variables. The NCP
defines an OU as a discrete action that is an incremental step toward comprehensively
addressing site problems. If one contaminant is present on-site, or a single decay chain is
present on-site, the primary driver for the number of samples required to reach a certain
confidence interval will depend on the variance of the total batch of samples. The confidence
interval is the range of values with a specified probability (e.g., 90 or 95%) that the set
contains the true value of the parameter tested.
b. The variance is the square of the standard deviation of the sample population. In
general, the larger the variance is, the greater the number of samples needed. Additionally,
as the number of contaminants increase, the number of samples required may also increase.
When multiple radioactive contaminants coexist on a site, the clean-up criterion may require
that a sum of fractions be used to determine compliance, i.e., for n radionuclides of
concentration C:
n
Cx
≤1
∑
DCGL x
x =1
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CHAPTER 4
Health and Safety
4-1. Introduction. This Chapter provides an introduction to the health and safety
requirements unique to radioactive and mixed waste site remediation. HTRW health and
safety requirements are described more fully in ER 385-1-92, ER 385-1-80, EM 385-1-80,
and EM 385-1-1.
4-2. Responsibilities.
a. USACE has the primary responsibility for ensuring the health and safety of USACE
personnel on-site and ensuring that all contractors on-site follow USACE accepted health and
safety procedures. USACE and the contractor share the responsibility of ensuring that work
performed on-site does not endanger the public on-site or off-site, in addition to protecting
the environment. All personnel on-site are responsible for maintaining exposures to radiation
as low as is reasonably achievable (ALARA). All personnel on-site are required to read and
comply with the Site Safety and Health Plan (SSHP).
b. Many sites are under control of other agencies prior to USACE involvement. Where
other agencies have the lead, that agency’s safety and health program and plan will be
followed by USACE and contractor personnel until responsibility for site safety has been
turned over to USACE. The USACE PM may then elect to retain the existing safety and
health program and plan, if it is in compliance with Federal, state, and local, as well as
USACE, regulations, or elect to construct a USACE safety and health plan.
c. Some sites may be owned or operated by commercial parties. The operator or owner
may have existing safety and health programs and plans, and may be regulated by other
Federal agencies. USACE has a Memorandum of Understanding with the Nuclear
Regulatory Commission (NRC) concerning USACE work at sites regulated by the NRC.
Here again, the USACE PM may elect to retain the existing safety and health program and
plan, if it is in compliance with Federal, state, and local, as well as USACE, regulations, or
elect to construct a USACE safety and health plan. USACE may have no regulatory
authority over the private owner and, therefore, no authority to impose an adequate health
and safety plan. If the private owner objects, and USACE believes health, safety, and
environmental protections to be inadequate, Federal and state agencies with jurisdiction must
be notified.
4-3. Programs and Plans.
a. Contractors. All contractors shall have a written SHP (Safety and Health Plan) that
addresses all aspects of HTRW worker health and safety.
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b. Site Safety and Health Plan (SSHP). For each HTRW site, contractors shall have a
written SSHP that addresses all expected hazards, and the methods proposed to mitigate
those hazards that may be encountered on the site. The SSHP shall address all items
discussed in ER 385-1-92, Appendix C. If portions of the contractor’s SHP are referenced in
the SSHP, those portions of the SHP shall be attached as appendices to the SSHP.
4-4. Radiation Protection Items Addressed in the SSHP. In addition to addressing the health
and safety items for HTW sites, the SSHP must address the following items that are unique
to radiation sites. These items shall be integrated with the rest of the SSHP to ensure
coordination of all health and safety issues on-site.
a. USACE Personnel.
(1) USACE will provide the work plan, scope of work, site safety and health plan, etc.,
which will be reviewed by qualified health physics personnel who are trained in accordance
with ER 385-1-92.
(2) USACE will provide site representatives who are trained according to
EM 385-1-80.
b. Contractor Personnel.
(1) The contractor will provide a certified health physicist, responsible for the review
and implementation of all documents and procedures related to radiation protection.
(2) The contractor will provide a sufficient number of radiation protection technicians
(sometimes referred to as HP techs) who are trained as required (meeting health physics
personnel requirements) in EM 385-1-80 to perform surveys, monitoring, and safety
oversight on-site.
c. Contractor Dosimetry Responsibility.
(1) The contractor has two options concerning dosimetry.
(a) One alternative is that the contractor will monitor personnel exposures, provide
appropriate external dosimetry to all personnel exposed to external sources of radiation
(gamma or neutron radiation), and provide a method for dose determination for personnel
who may become internally contaminated with radioactive materials.
(b) The other alternative is that the contractor will provide measurements and
documentation that external or internal contamination could not result in doses to the
individuals that exceed 10% of the annual TEDE.
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(2) Common methods for meeting dosimetry requirements include providing
thermoluminescent dosimeters or film badges to all personnel who enter the exclusion zone,
and monitoring the air in the exclusion zone and documenting that the airborne
concentrations of radionuclides are below 10% of the derived air concentrations listed in
10 CFR 20, Appendix B.
(3) Should a bioassay program be required, personnel should receive a baseline
bioassay prior to entering the exclusion zone, periodic bioassays as determined by a health
physicist, and a termination bioassay at the end of the project. Bioassay methods depend on
the radionuclide and chemical form of concern and may include fecal sample analysis,
urinalysis, organ counting, or whole body counting.
d. USACE Dosimetry Responsibility. USACE will provide appropriate dosimetry for
USACE personnel. Dosimeters will be furnished and analyzed by the U.S. Army Ionizing
Radiation Dosimetry Program at Redstone Arsenal in Alabama. Should bioassays be
required for USACE personnel, these will be coordinated through the U.S. Army Center for
Health Promotion and Preventive Medicine, at Aberdeen Proving Ground, Maryland.
e. Equipment.
(1) The contractor will provide surveying equipment capable of detecting the type and
intensities of radiation expected on-site and to the limits of precision required in Data Quality
Objectives (DQO) for personnel protection and cleanup of the site as specified in the work or
safety plans.
(2) The contractor will provide monitoring equipment capable of accurately measuring
the external radiation dose expected on-site.
f. Procedures. The contractor shall provide procedures that ensure that doses to on-site
personnel and the general public are kept ALARA. These procedures will include, as
appropriate:
(1) Limiting the time individuals are exposed to external radiation.
(2) Maintaining as much distance as reasonably possible between personnel and the
sources of external radiation.
(3) Providing shielding, when necessary, to lower exposure to ionizing radiation.
(4) Surveying procedures to stop the spread of contamination from the exclusion zone.
(5) Monitoring procedures to ensure that contamination is not released from the site.
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(6) Decontamination procedures to ensure that site worker doses are maintained
ALARA and to minimize the amount of contaminated waste generated.
g. Emergency Contacts. The emergency contacts listed in the SSHP must include the
appropriate NRC region or agreement state contact if licensable radioactive materials are
involved, the appropriate EPA region or state contact, and the Radiation Protection Officer
for the USACE District and Division. For work on a military installation, the installation
Radiation Safety Officer shall also be included.
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CHAPTER 5
Risk Assessment
5-1. Introduction. Risk assessments are a required element of CERCLA and RCRA site
investigations. They are used on both non-radiological and radiological chemical
environmental restoration projects to determine whether a site poses a potential threat to
human health and the environment. Information from a risk assessment is used to
demonstrate whether a site warrants further investigation, whether a removal or remedial
action is warranted, or if a site may be closed with no further action. Dose is frequently
assessed for radionuclides because many standards that regulate radionuclides, such as those
issued by the Nuclear Regulatory Commission (NRC), which are based on radiological dose.
However, CERCLA guidance requires that risk be assessed as part of site investigations.
Differences between dose assessment and risk assessment are discussed below.
5-2. Risk Assessment and Dose Assessment Comparison.
a. In many ways, risk assessments and dose assessments are synonymous with one
another. In both risk assessments and dose assessments, measurements of constituents of
potential concern are used together with exposure assumptions to develop the “dose” that a
receptor may receive. The meaning of the word “dose” is part of what distinguishes
radionuclide from non-radiological chemical risk assessment. In chemical risk assessment
“dose,” or intake, means the mass of a substance taken into an organism through all pathways
(such as inhalation, ingestion, absorption, etc.) per unit body weight per unit time and is
usually expressed as mg/kg per day. This is combined with toxicity information to develop
estimates of excess cancer risk, or a hazard index for non-carcinogenic risk. In terms of
radiological risk, dose means energy imparted by ionizing radiation to matter per unit mass.
This may be expressed in units of rad. Radiological dose assessments generally express dose
in units of mrem/year; for example 1 rad of gamma radiation will produce 1 rem dose
equivalent. Dose assessments estimate dose imparted to an organism by combining exposure
information with radionuclide-specific characteristics. Dose will be a function of the type of
radiation emitted by particular radionuclides and the frequency and duration of exposure of
organisms to that radiation. Another difference between chemical and radionuclide risks is
that radionuclide exposure estimates must consider an additional pathway, exposure to
radiation that has sufficient energy to penetrate the skin. This is called the external pathway.
b. As stated above, information from a risk assessment or dose assessment is used to
determine whether a site is safe, or whether it requires further action. The site risk
assessment is used to develop remediation goals under CERCLA when there are no ARARs
available, or when ARARs are not protective owing to multiple contaminants or pathways of
exposure to contaminants. Remediation goals based on a dose assessment are used as
components of many regulations, specifically, the NRC’s Final Rule for Radiological Criteria
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for License Termination (10 CFR 20, Subpart E) and to develop supplemental standards
under the Health and Environmental Protection Standards for Uranium and Thorium Mill
Tailings (40 CFR 192, UMTRCA). The following paragraphs further discuss the roles and
procedures for dose and risk assessments in regulatory programs that commonly cover
USACE projects where radionuclides contamination occurs.
5-3. Role of Risk Assessment in Regulatory Programs. There are certain instances, such as
Work for Others on nuclear decommissioning projects, where USACE work may be carried
out under direct regulation by the NRC. Most USACE environmental restoration projects
with radionuclide contamination, however, will follow CERCLA with NRC regulations as a
potential ARAR. The paragraphs below discuss the CERLCA process and how risk
assessment is used in the various stages. Some projects may be regulated by the Resource
Conservation Restoration Act (RCRA); the role of risk assessment or dose assessments in
projects regulated by RCRA is functionally equivalent to that of CERCLA. The processes
followed by RCRA are similar to those of CERCLA, except that different terminology is
used.
a. At sites regulated by CERCLA, the first step after discovery of a site is preparation
of a Preliminary Assessment/Site Inspection (PA/SI). The objectives of an SI are to
eliminate from further consideration any releases that do not pose a threat to human health or
the environment, to collect data to initially characterize any releases, and to identify any
immediate threats to public health or the environment. A screening level risk assessment is
used during the PA/SI stage to meet these objectives.
b. At the end of the PA/SI, EPA applies a scoring system known as the Hazard
Ranking System (HRS) to determine if a site should be listed on the National Priorities List
(NPL).
c. Performance of the HRS is EPA’s responsibility and is generally not done by
USACE or by DOD. However, site investigations should be designed to ensure that adequate
data are available for EPA to conduct the scoring. Though DOD does not use the HRS, it
does use a system for ranking sites for resource allocation and prioritization called the
Relative Risk Ranking System. It is not a risk assessment, but does consider factors common
to risk assessment, such as migration pathways, contaminant hazard, and receptors.
d. The purpose of the Remedial Investigation (RI) phase of the CERLCA process is to
collect data to characterize the nature and extent of contamination and to quantify risks to
human health and the environment in a baseline risk assessment. Results of the risk
assessment are used to determine the contaminants, the media, and the areas of the site that
require an evaluation of remedial alternatives in the Feasibility Study (FS). Risks are
considered to be unacceptable if the non-cancer hazard quotient is above one or if excess
cancer risk is above 10-4 (40 CFR 300), or if ARARs are exceeded. In the FS remedial
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alternatives are developed, screened, and analyzed, and potential remedies are evaluated
against the nine criteria outlined in the NCP, as further discussed in Paragraph 9-2.
e. The first two criteria for evaluating remedial alternatives, overall protection of
human health and the environment, and compliance with ARARs, relate to protectiveness of
the remedy and to determination of remediation goals. The discussion of overall
protectiveness in an FS will draw upon the analysis of other criteria, such as long-term
effectiveness, short-term effectiveness, and attainment of ARARs. Long-term effectiveness
considers the amount of residual risk remaining after a remedial alternative is implemented.
For some projects this evaluation may require that a quantitative residual risk assessment be
prepared. A residual risk assessment entails estimating residual concentrations of
contaminants of concern, with a subsequent calculation of risk from exposures to those
levels. For many projects, though, a qualitative evaluation of how remediation goals will be
attained will suffice. The FS needs to discuss whether the analyzed remedial alternatives
meet the ARAR or risk-based criteria for protectiveness.
5-4. Regulatory Guidance for Risk Assessments and Dose Assessments. EM 200-1-4, Risk
Assessment Handbook Volume I: Human Health Evaluation (1999) and EM 200-1-4 Risk
Assessment Handbook Volume II: Environmental Evaluation (1996) provide an extensive
discussion of available guidance for human health and ecological risk assessments at sites
regulated by CERLCA and RCRA. The reader is referred to these documents for more
information. The discussion presented in the following paragraphs will focus on issues and
guidance that are unique to radiological risk assessments and dose assessments.
5-5. CERCLA.
a. EPA has issued several guidance documents for conducting human health and
ecological risk assessments. Chapter 10, “Radiation Risk Assessment Guidance,” of Risk
Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (RAGS
Pt. A) (EPA 1989) covers data collection and evaluation, exposure and dose assessment,
toxicity assessment, and risk characterization for sites contaminated with radionuclides.
Chapter 4 of RAGS Pt. B Development of Risk-based Preliminary Remediation Goals (EPA
1991) presents standardized exposure equations for calculating preliminary remediation goals
(PRGs) for radionuclides under residential and commercial/industrial land uses. When the
PRG document was developed, EPA recommended that the equations be used with default
exposure parameters to develop values for screening sites in the initial stages of the
CERCLA process, as well as with site-specific information for developing PRGs in the FS.
In 1996, though, EPA released Soil Screening Guidance, which gives equations to develop
soil screening levels (SSLs) for screening sites with non-radiological contaminants. SSLs are
based on residential use and also address contaminants leaching from soil to ground water,
whereas the PRG calculations do not consider leachability. In 2000, EPA followed this
document up with a document specific for radionuclides, Soil Screening Guidance for
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Radionuclides (EPA 2000), which contains equations for calculating screening levels for
radionuclides. The equations for exposures to soil supercede the residential equations
contained in RAGS Pt. B. An electronic tool for running the calculations, the EPA PRG
Calculator, is located at http://epa-prgs.ornl.gov/radionuclides/.
b. An ecological risk assessment must also be conducted on CERCLA sites. The
guidance for ecological risk assessments at CERLCA sites is titled Ecological Risk
Assessment Guidance for Superfund: Process for Designing and Conducting Ecological Risk
Assessments (EPA 1997).
c. Information regarding toxicity values for radiological risk assessments, additional
models, and other information relative to risk assessment for radionuclides, may be obtained
at EPA’s radiation website http://www.epa.gov/radiation/.
5-6. RCRA Guidance. As stated above, RCRA human health assessments generally follow
CERCLA guidance. There is no guidance regarding risk assessments or dose assessments
specific to radionuclides available for the RCRA program.
5-7. NRC Guidance. Standards for Protection Against Radiation, Radiological Criteria for
License Termination, and NRC decommissioning standards at 10 CFR 20.1401-1403 give
dose requirements for restricted and unrestricted land use. The standard also requires that the
dose assessment determine the peak annual total effective dose equivalent (TEDE) to the
average member of the critical group expected within the first 1000 years. The NRC has
developed draft guidance for performing dose assessments to show compliance with their
standards and also developed the D and D computer code to perform dose assessments.
Another computer code, RESRAD, is available that may be used to assess doses. RESRAD
has certain advantages over D and D and is preferred by health physicists for assessing doses.
The model may be downloaded at Argonne National Laboratory’s website at
http://web.ead.anl.gov/resrad/home2/.
5-8. Considerations for Project Risk Assessments. Since many USACE projects will follow
the CERCLA process, the following paragraphs discuss aspects of CERCLA screening-level
and baseline risk assessments that will be unique for projects where radionuclide
contamination is confirmed or suspected. Further information on risk assessments may be
found in Volume I of EM 200-1-4 and Volume II of EM 200-1-4 (USACE 1996, 1999).
a. Screening-Level Risk Assessments. To determine whether a site requires further
investigation and to identify areas that may pose an immediate threat to human health and the
environment, a screening-level risk assessment is carried out as part of the SI. The first step
of this process is preparation of a preliminary conceptual site model (CSM) for both human
and ecological receptors. A preliminary CSM should be prepared when scoping the PA/SI,
using whatever site information is available at the time, and the CSM should be modified as
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more site-specific information is gathered. EM 1110-1-1200 provides guidance for preparing
CSMs for human receptors, and integrates ordnance and explosives or hazardous, toxic, and
radioactive waste. Guidance for preparing CSMs for ecological receptors with case study
examples may be found in EM 200-1-4.
b. Human Health Screening. Human health screening level risk assessments are
typically conducted by comparing the highest detection against health-based screening levels.
Screening levels are media concentrations derived by back-calculating from protective risk
values and conservative exposure parameters. To develop screening levels for radionuclides
and other carcinogens, the risk value is set at the lower (most protective) end of the
acceptable risk range, 1×10-6, one in one million excess cancer risk. Screening levels are
frequently called risk-based concentrations (RBCs), or PRGs. The EPA’s PRG calculator
should be used to develop radionuclide screening levels for this purpose. At this stage it is
appropriate for screening levels to be conservative and it is important to note that that they
should not be used as remediation goals for cleaning up a site, as they do not consider sitespecific factors. Remediation goals should be based upon results of a site-specific risk
assessment or ARARs. Owing to the nature of their effects on biological organisms,
radionuclides present at background concentrations may fail a screen against health-based
levels. Therefore, it is imperative that the assessment determines whether radionuclides have
be released and whether they are present above background levels before a recommendation
is given for further investigation or for a removal action.
c. Guidance for Conducting Screening Level Ecological Assessments. Guidance for
conducting screening level ecological assessments may be found in ERAGS (EPA 1997) and
in Volume II of EM 200-1-4 (USACE 1996). An excellent discussion of screening level and
baseline ecological risk assessments is presented in the Tri-Service Remedial Project
Manager’s Guide for Ecological Risk Assessment (Simini et al. 2000). The DOE (DOE
2002) has developed a technical standard that contains spreadsheets that are useful for
calculating dose to ecological receptors. The standard and spreadsheets can be downloaded
at http://tis.eh.doe.gov/techstds/standard/std1153/1153.htm. The standard includes a graded
method for evaluating sites that starts with a very generic whole-site approach. This is not in
strict accordance with USACE and EPA guidance, and it is not necessary to follow the
standard’s approach in its entirety. The DOE recently published a companion software tool,
RESRAD-BIOTA Release 1.0, to assist in implementing the technical standard and will be
useful for many projects. It would be uncommon for an ecological risk assessment to go
beyond the screening-level stage on a radionuclide site. If a baseline ecological risk
assessment is performed, it needs to follow USACE and EPA guidance.
d. Baseline Risk Assessment. Baseline risk is defined as risk that might exist if no
remediation or institutional controls were applied to the site (EPA 1989). Baseline risk
assessments are a required element of CERCLA remedial investigations, whose results help
determine whether remedial alternatives need to be evaluated in the FS to mitigate risk. A
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well-designed risk assessment will provide the project manager with sufficient information to
make future risk management decisions regarding the site. Such information that should
clearly be presented are the media, contaminants, exposure pathways, and specific areas at
the site that are contributing to unacceptable risk. The primary adverse effect associated with
most radionuclides are their potential for causing cancer; however, there are others, such as
uranium that may cause other effects based upon its non-radiological chemical properties, in
this case causing kidney damage. The risk assessment needs to express both excess cancer
risk and non-cancer risks posed by potential exposures to contaminants at the site.
e. Dose Assessment. A dose assessment may be run concurrently with the risk
assessment, and it is recommended that this be done if 10 CFR 20 Subpart E is a potential
ARAR for the site. The preferred tool for assessing dose is RESRAD. RESRAD is widely
accepted by the health physics community and has the capability to calculate risk and dose as
well as modeling fate and transport in a single model. This model has been used on many
USACE projects for estimating both dose and risk posed by radionuclides. However, there
are differences between using this model and CERCLA guidance for risk assessments that
the project delivery team needs to be aware of; these are discussed below. The EPA has
recently developed an electronic calculator, similar to the risk-based radionuclide PRG
calculator, to provide dose compliance concentrations for demonstrating compliance with
dose-based ARARs at CERCLA sites. The dose calculator is located on-line at http://epadccs.ornl.gov/radionuclides/. As USACE health physicists and risk assessors gain
experience with these new tools, the lessons learned will be shared through the appropriate
communities of practice.
f. RESRAD. Within a single interface, RESRAD has the capability to account for
factors such as erosion, leaching, and radiological decay and in-growth that are involved with
predicting risk of future exposures, also termed a prospective risk assessment. While it is
common to consider such factors as contaminants leaching from soil to ground water, ground
water movement and ground water discharge in CERCLA risk assessments, it is not standard
practice to erode surface soils to reveal contaminants in the subsurface. RESRAD default
parameters will model exposures out to 1000 years to demonstrate compliance with NRC and
DOE regulatory requirements. For a CERCLA baseline risk assessment, this is not
necessary, though estimating the year of peak risk attributable to radionuclide decay alone
may be useful. Another factor that must be considered is that RESRAD defaults to
conservative exposure scenarios, such as a subsistence farmer and fisherman, while
CERCLA risk assessments generally do not include such scenarios unless there is sitespecific information suggesting that these are likely future land uses. The project risk
assessor, health physicist, and hydro geologist need to work together with regulatory
stakeholders to determine the appropriate parameters for the risk assessment and to determine
if other fate and transport models are preferred to those in RESRAD before doing the
radiological risk assessment.
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CHAPTER 6
Sampling
6-1. Data Quality Objectives (DQO).
a. DQO are statements made to ensure sample taking is focused on achieving the
objectives of the study. They define the type of data to collect, the conditions for collecting
the samples, the decision error limits, the quantity of samples taken, and the required quality
of the analyses. The MARSSIM (Appendix D) outlines the DQO process - seven steps used
to ensure that the data gathered provide information that will allow an informed decision to
be made about the next action to take at a site. An example of a good DQO is the following:
(The purpose of this walkover survey is to determine if there is elevated 122 keV
gamma radiation from Co-57 contamination in this area, and if so where it is and
how elevated it is.) DQO: Identify potential small areas (100 cm²) of Co-57
surface soil (<15 cm) contamination in the survey unit with a 95% confidence limit
using radiation detection equipment and scanning methods with an estimated ScanMDC below the Co-57 screening level of 8.7 pCi/g [EPA PRG for residential soil].
Each potential area will be considered contaminated if the result of a direct
measurement exceeds the critical level, Lc, calculated from background
measurements in a reference area similar to the survey unit using values of 0.05 for
alpha and beta errors.
b. This DQO could be met through by implementing a survey procedure like the one
that follows:
100% of the surface area will be surveyed using a 2”x 2” Sodium Iodide detector
held 1 meter above the surface and moved at 2 inches per second. The detector is
capable of measuring 5 µR/hr gamma radiation in the 80 to 180 keV energy range
(850 cpm = 1 µR/hr). The survey meter is calibrated with the detector to read out in
units of µR/hr. Background has been previously determined to be 12 µR/hr (10,200
cpm). The required level of confidence is 95% for detecting true positives and
0.05% of finding false positives. The minimum detectable count rate for the ideal
observer is computed to be 10,531 cpm (12.4 µR/hr). The action level for this
survey is set at 12.4 µR/hr. Each location where a reading of 12.4 µR/hr or greater
is detected will be flagged with a pin flag. Each flagged point will be resurveyed
for 1 minute and the readings and location recorded in the survey log.
6-2. Scanning. There are a number of types of scanning done at HTRW sites-area scanning,
building surface scanning, soil surface scanning, and excavation surface scanning. Scanning
is performed by passing a field instrument at a set distance and slow speed over an area
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suspected of having radioactive contamination. Scans can detect some alpha and many beta
emitting radionuclides on a surface and most gamma emitting radionuclides on the surface or
a few centimeters below the surface scanned. Methods for doing scans vary a little for each
type of scan.
a. Area Scanning. This is usually done to determine if an area is safe to access. This
scan may find areas of high gamma radiation, which could pose a hazard to workers in the
area. This type of scan is usually performed inside buildings where large quantities of
radioactive materials are used, or where radiation generating devices are in use. For an area
scan, a gamma ray detecting probe is held 1 meter off the floor and the radiation readings are
monitored throughout the room. The readings will be used by health physics personnel to
determine work procedures in the room.
b. Building Surface Scans. This type of scan is used to determine if there is radioactive
contamination on building surfaces or debris, or possibly infused into the building material or
debris. The instrument selected for a building surface scan depends on the radiation emitted
by the contaminant. Surface scanning instruments preferentially have a large window
detector, allowing more surface area to be scanned at one time. The detector is held very
close to the surface to be scanned. This detector is moved slowly over a prescribed
percentage of the surface area. For final status survey of class 1 areas, see Chapter 13 for a
discussion of area classification, this is typically 100% of the surface, and 25% of the total
surface for class 2 areas, areas. Additionally, a wipe or smear survey is usually done in
conjunction with a building or debris scan to determine if the contamination is removable. A
health physicist will need to ensure that the combination of the type and size of the detector,
the distance from the surface, and the speed that the detector is moved are such that the
instrument will be capable of detecting contaminants at a low enough concentration to meet
the survey goals. The building or debris surface scan should result in a report detailing the
total square footage of the building or debris surface, the total square footage that was
contaminated above the action level, the average level of contamination and the highest level
of contamination measured, and whether the contamination is removable of non-removable.
c. Soil Surfaces. Soil surfaces are scanned similarly to building surfaces but may
present other problems. Vegetation may need to be removed. Soil surfaces may be rugged,
making it difficult to maintain the detector at a set distance from the surface. As with
building scans, soil scans may detect gamma-emitting radionuclides a few centimeters deep
in the soil. Most radionuclides would not be detectable at depths below a few centimeters
unless they are present in large quantities. A health physicist can calculate the depth to
which the instrument can detect a certain quantity of a specific radionuclide.
d. Excavation Surfaces. These are scanned in the same manner as soil surfaces. Open
excavations are usually scanned to determine if further excavation is necessary. As before, if
a sufficient thickness of soils is between the detector and the contaminant, the instrument will
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not be capable of detecting it. If an excavation is scanned and no contamination is detected,
and the excavation is backfilled with clean fill, it can be expected that no contamination will
be detected if the backfilled excavation is re-scanned.
6-3. In-Situ Measurements. These are made using a sodium iodide (NaI) detector or a high
purity germanium (HPGe) detector in conjunction with a spectrum analyzer. This system
will allow a spectrum of all gamma radiations to be recorded and analyzed. Most of these
systems can identify the source radioisotope of each gamma radiation measured. Some
systems have incorporated algorithms to enable the system to quantify the contaminants of
concern, and attempt to determine the depth in the soil at which the contaminant is present.
These systems are very complex and careful evaluation will be needed to provide a level of
confidence in their measurements.
6-4. Down-hole or Well Logging. Another form of scanning is down-hole logging. In this
situation, a detector is lowered into the borehole and a record of the measurements vs. the
depth of the detector is recorded. This method can sometimes locate the depth that a
contaminated layer of soil is at relative to the ground surface. It can also sometimes locate
hotspots within the ground. Down-hole logs are influenced by a number of factors, including
soil density, moisture content, and soil type. Ensure that the individual interpreting the
survey is experienced in accurate down-hole survey interpretation techniques.
6-5. Sampling Surface Soils. This is commonly done at locations where scanning indicates
elevated radiation levels. This is called biased sampling. A grid may be set out over the site
and soil samples taken at selected grid nodes. Additionally, random surface soil samples
may be taken to verify remediation effectiveness. A surface soil sample, usually about 1
kilogram, is removed and packaged then forwarded to a lab for analysis.
a. Subsurface soil sampling is usually done with a coring device. A soil core from the
surface to a set depth is taken and soil from a certain layer is removed form the core, usually
homogenized, and sent to the lab for analysis. Subsurface sampling may be achieved by
other means, such as removing the cover or topsoil with a shovel or backhoe, then taking a
soil sample at a specific depth. Often the contaminant is excavated to a prescribed depth,
then samples of the soils in the bottom or on the sides of the excavation are taken to confirm
that all the contaminated soil was removed from the site. Subsurface sampling may be
necessary to determine the three-dimensional extent of contamination at a site.
b. As with all grab samples, care must be taken in the interpretation of surface and
subsoil results. Biased sampling may indicate the areas and the maximum concentrations of
a contamination a site, but is not representative of the site as a whole. Gridded samples may
provide the best indicator of the site-wide conditions, but must be evaluated using statistical
tools to ensure that enough samples were taken to have an acceptable level of confidence in
the results. Subsurface samples are more difficult to acquire and so are more expensive.
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Excavation sampling must consider the safety requirements for potential sloping and shoring
before an individual is allowed into the excavation. All gridded sampling relies on the
assumption at the contaminant is distributed over the site in some manner. Problems in
interpretation can arise when the contaminant is heterogeneous over a site rather than
homogeneous. A heterogeneously distributed contaminant is one where larger pieces of the
radioactive contaminant are randomly scattered over a site, with little or no continuous
contamination of surrounding soils. In this case, statistics based on a distribution break
down.
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CHAPTER 7
Characterization
7-1. Introduction. Characterization refers to three separate tasks that are part of the
CERCLA process: site characterization, contaminant characterization, and waste
characterization.
7-2. Chemical and Radioactive Contaminants. Radioactive materials can pose two separate
hazards to human health at a site. They may be hazardous chemicals, and they also decay
and emit ionizing radiation. The chemical hazard posed by an element is the same regardless
of whether a stable or radioactive isotope is involved. The chemical hazard depends on the
molecular complex to which the atom is affixed. Regardless of the chemical form, if the
isotope is radioactive, the molecular form will emit radiation, and, therefore, be hazardous.
Besides its chemical toxicity, the molecular form will determine its transportability in the
environment.
a. A contaminant’s characteristics can change over time. Chemical degradation occurs
in many contaminants over periods of months or years. Radioactive decay transmutes the
radionuclide from one element to another, which in turn can alter the way it behaves on the
molecular level and also how it is transported in the environment. For example, radium-226
is often found in water-soluble compounds that can be dissolved and percolate through the
soil column to ground water. Radium-226 decays to radon-222, an inert gas that may rise
through the soil column and disperse in the air, but is also highly water soluble. Radon-222
decays to a number of short-lived decay products, all of which are solids and will attach
electro-statically to dust particles in the air, further allowing air migration, or they will be
washed out of the air by precipitation, and reenter the soil. In summary, the contaminant can
change atomic form, change the radiations emitted, change chemical form, change fate and
transport methods, and change chemical and radio toxicity over time.
b. For these reasons, it may be necessary to characterize both the radioactive and the
chemical/molecular form of the suspected contaminants and to determine how these
characteristics change over time. When this characterization is too complex or too expensive
to determine, it is necessary to make some assumptions about how the characteristics will
change and how these changes will affect transportation and exposure pathways in the
environment. It is important to ensure that, whenever any assumptions are made, they are
fully documented in the characterization report, and that an estimate of their reliability be
incorporated in the report.
c. Samples taken and analyzed during the site characterization may be useful during
the waste characterization. If the actions generating the waste stream do not greatly alter the
type or concentration of the contaminants, site characterization sample results may be used
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for waste characterization. It is important to know the disposal site’s waste acceptance
criteria and the required sample analyses to ensure that site characterization sample analyses
will be acceptable to the disposal site. This will aid in decreasing the number of samples
being analyzed over the entire life of the project.
7-3. Site Characterization. This is the quantitative description of the site properties that
influence the determination of risk to human health or the environment from a contaminant
present at the site. The site characterization includes an investigation of the physical nature
of the site and the contaminants at the site. It attempts to define the sources of the
contamination, and determine the nature and extent of the contamination. It also seeks to
identify exposure pathways and potential receptors for the risk assessors. As a corollary to
this, it also is used to identify areas that are not contaminated. All sampling and
characterization should be oriented toward provision of data necessary to complete the final
status survey, and reach closure of the project.
a. The physical characteristics of the site may include geophysical and hydrogeological
parameters, as well as the site use and accessibility in the past, present, and future. It also
includes characterization of the volumetric distribution or dispersion of the contaminants or
contaminant at the site.
b. The site characterization is attempting to answer the questions: What is the
contaminant on-site? What are its radiological as well as its chemical characteristics? Where
is the contamination? What is the pattern or distribution, if any, of the contaminants? What
are the actual and potential modes of transport of the contaminant in the environment? Who
are the potentially exposed populations? What are the routes of exposure?
c. Site characterization is described further in EPA CERCLA guidance. Important
differences in site characterization on radioactive sites that may manifest themselves are the
variations in radionuclide pathways from the standard chemical pathways. Especially the
decay chain radionuclide series, where there is a change in physical form that accompanies
the decay, such as solid radium-226 decaying to gaseous radon-222. There is also the change
in chemical form and in chemical reactivity that will affect pathways. After most decays, the
radionuclide is left in an ionized state, which is chemically highly reactive.
d. Contaminant characterization, a subtask of site characterization, describes the
physical, chemical, and radiological parameters of the contaminants as they exist at the site.
7-4. Waste Characterization. Waste characterization defines the waste stream containing the
contaminants as it will be delivered to the disposal facility. Waste characterization can be a
multi-stage process. On many sites, large numbers of site characterization samples are taken
of soils and debris. In most cases the act of removing and packaging the contaminated soil or
debris does not significantly alter the radioactivity of the waste. In these cases we can use
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the site characterization sample data to contribute to the waste characterization data. This
will significantly lower the number of samples and analyses needed on the waste stream. If
this is the case, it is important to ensure that the site characterization sample data are of the
same caliber needed for waste characterization. Additionally, removal and packaging
methodology that ensures that concentrations of radioactive contaminants in the soil and
debris are not significantly altered needs to be included in the data package.
a. The concentration, activity, and chemical form of the contaminant may have altered
because of some remedial, removal, or other actions taken at the site, or on the waste stream.
When this is the case, a more stringent waste-characterization sampling program will be
required to ensure adequate confidence in the level of activity in the waste and the
homogeneity of the waste.
b. For disposal, waste streams may sometimes be combined to allow for more
economical transportation and disposal. While radioactive waste streams may be combined
and the average concentration of radionuclides in one waste stream may be lowered by the
combination, waste may not be diluted to become unregulated. Both waste streams must
meet the waste acceptance criteria of the proposed disposal site to be blended. If one waste
stream does not, it should not be blended. Waste will not purposefully be mixed with
uncontaminated soils to lower its radioactive concentration. In the process of remediation,
some clean material is unavoidably collected along with the contaminated material; this is
acceptable and is not considered blending.
c. The following is an example: A site contains a radioactive waste burial pit. The
remediation method chosen was to remove the soils covering the pit, segregate these soils
from the waste in the pit, excavate the waste in the pit, try to treat 10 cubic yards of the waste
with a new technology that minimizes the waste volume, and ship all waste to disposal
facilities. A characterization survey is conducted to determine the radionuclides present,
their concentrations at various locations and depths, and their volumetric extent at the site.
Assume the 85 characterization samples showed that the soil covering is uniformly
contaminated with very low concentrations of radioactive waste and can be disposed of at an
RCRA Subtitle C facility. In the process of excavating the contaminated soils, the buckets
sometimes cut a few inches deeper into uncontaminated soils, incorporating some
uncontaminated soil into the waste stream. This generated 2500 cubic yards of waste. This
particular RCRA facility requires one confirmatory sample per 100 cubic yards of waste, so
25 confirmatory samples are required for this waste stream.
(1) The waste excavated from the pit is known from the characterization sampling to
be uniformly contaminated but with a much higher activity. This 10,000 cubic yards of
material must go to an NRC licensed radioactive waste disposal facility. The facility requires
five confirmatory samples be taken from the entire waste stream. They also have additional
testing when the waste reaches their site. If this testing reveal concentrations vastly different
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from those presented by our sampling, the shipment will be returned to the originating site.
To ensure we meet the waste acceptance criteria for the site, we use the information collected
during the characterization of the site, applicable to this waste stream. These 200 subsurface
soil samples show the radionuclide concentration to be a total of 3400 pCi/g ± 1200 pCi/g at
a 95% confidence level. The five confirmatory samples varied between 2500 and 4200 pCi/g
with a mean value of 3250 pCi/g. Site and process knowledge, combined with the
confirmatory samples, provides excellent confidence that excavation and handling
procedures did not significantly alter the radioactive contaminant concentration of this waste
stream.
(2) The 10 cubic yards of the pit waste that are treated resulted in a volume reduction
of 60%; 30 samples taken from the 6 cubic yards of ‘cleaned’ waste show that the
radionuclide concentration is lower than the remediation goal for the site. With the
concurrence of the site regulators, it may be disposed of on-site as fill. The remaining 4
cubic yards are sampled twice and both samples show the radionuclide concentration has
been increased.
(3) This site has three radioactive waste streams: the 2500 cubic yards of slightly
contaminated soil covering, the 10,000 cubic yards of pit contents, and the 4 cubic yards of
treated waste. Total samples taken of each waste are as follows:
(a) For the 2500 cubic yard soil covering, 85 characterization samples and 25
confirmatory samples were taken.
(b) For the 9,994 cubic yard pit contents, 200 characterization survey samples and 5
confirmatory samples were taken.
(c) For the 4 cubic yards of treated pit contents, 2 samples were taken. The 4 cubic
yards was then blended in with the 9,990 cubic yards of the original pit contents, and was
calculated to not significantly change the content of the pit radionuclide concentrations.
d. In summary, the site characterization will have identified the radioisotopes, and
provided a range of concentrations in each waste stream, and an estimated volume of each
waste stream. To meet disposal facility requirements and USACE quality control, additional
samples needed to be taken and analyzed to ensure that the waste, excavated and ready for
transport to the disposal facility, has not been inadvertently altered through the remediation
process. The information gathered from these samples is combined with the information
from the characterization and any other surveys and is used to define the waste. By ensuring
that all the surveys have similar data quality, we can combine the results and achieve a very
reliable statistical estimate of our confidence in the data.
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7-5. Site History and Waste Pedigree. A comprehensive site history can be very helpful in
determining potential radioactive contaminants. If materials arrive as ores, and were smelted
on the site, the residuals may contain both parent and progeny decay products. If material
was already refined, parent or certain progeny may not be reasonably expected at the site.
Potential areas of contamination can be determined if knowledge of the physical flow of
materials in, around, and off the site is known. Soil and water extraction processes, wells, or
surface water systems used at a site may have contributed to technically enhanced NORM
(naturally occurring radioactive materials). All these processes and materials movement may
help explain the presence and migration of contaminants on and off the site. Additionally, it
is important to know the site history to characterize and classify the radioactive material.
7-6. Quantifying Contaminated Materials. A characterization study and interpretation of the
data collected should yield the following information:
• The range and extent of contamination at the site.
• Each radionuclide present on-site.
• The range of concentrations of each radionuclide on-site.
• The volume and mass of soil expected to exceed site screening levels/PRGs.
• The total activity and concentration of the radioactivity in soil exceeding site
screening levels/PRGs.
• The volume and mass of debris to exceed site screening levels/PRGs.
• The total activity and concentration of the radioactivity in or on debris exceeding
site screening levels/PRGs.
• The activity, concentration, and volume of the highest ‘hot-spot’ in soils on the site.
• The concentration and total activity expected to remain in the soil on the site.
• The concentration and total activity expected to remain on or in buildings or debris
left on the site.
All of the above data shall be quality controlled and of an accuracy and precision to be
acceptable as MARSSIM final status survey compatible data. By conforming to MARSSIM
Data quality objectives, these data can be combined meaningfully with all the other data
obtained on the site and the waste to provide a better statistical accuracy to the data.
7-7. Other Media - Air, Water, Sediments. Depending on the site, air, surface water, or
ground water may require characterization. The primary difference in characterization is that
these measurements are normally provided in activity per unit volume, as opposed to activity
per unit mass.
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CHAPTER 8
Radioactive Waste
8-1. Classification.
a. The NRC regulates only source, byproduct, and special nuclear materials. Waste
classification starts with determining if the material is NRC regulated.
b. Licensable source material is defined as: (1) uranium or thorium in any physical or
chemical form, or (2) ores containing one twentieth of one percent (0.05%) by weight of
uranium or thorium or any combination thereof. Source material in any chemical mixture,
compound, solution or alloy in which the source material is less than one twentieth of one
percent (0.05%) by weight is considered an unimportant quantity of source material. Source
material does not include special nuclear material.
c. Special nuclear material is plutonium, uranium-233, material enriched in uranium233 or uranium-235, or anything else the NRC determines is special nuclear material but
does not include source material.
d. Byproduct material is defined in a number of regulations. Byproduct material is 1)
any radioactive material yielded in or made radioactive by exposure to the radiation incident
to the process of producing or utilizing special nuclear material, and 2) the tailings and
wastes produced by the extraction or concentration of uranium or thorium from ore processed
primarily for its source material content, including waste from uranium solution extraction
processes. Byproduct material does not include source material or underground ore bodies
depleted by solution extraction.
8-2. Waste Definitions.
a. Congress defines high-level radioactive waste as the highly radioactive material
resulting from the reprocessing of spent nuclear fuel, including liquid waste produced
directly in reprocessing and any solid material derived from such liquid waste that contains
fission products in sufficient concentrations; and other highly radioactive material that the
NRC, consistent with existing law, determines by rule requires permanent isolation. The
latter includes spent nuclear fuel. Low-level radioactive waste is radioactive material that is
not high-level radioactive waste, spent nuclear fuel, or 11e.(2) byproduct material from
uranium or thorium mining/milling operations; and NRC, consistent with existing law,
classifies as low-level radioactive waste [42 USC 10101]. Additionally, NRC has ruled that
it does not regulate uranium and thorium mining and milling wastes/tailings generated before
1978.
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(1) The importance of these definitions and regulatory authorities to USACE is in the
available methods for disposal of each type of waste. There is no present disposal option for
high-level radioactive waste, or for transuranic waste not owned by DOE. Low-level
radioactive waste is subject to regulation by the various state radioactive waste compact
authorities as well as the NRC. Low level radioactive waste may be disposed of only in a
compact authorized radioactive waste repository: one in Barnwell, South Carolina, or the
other in Richland, Washington, or, with the permission of the compact, at Envirocare of
Utah. DOE transuranic waste may be disposed of only at the Waste Isolation Pilot Plant in
New Mexico.
(2) If the waste is not high-level or low-level radioactive waste, or transuranic waste,
there may be other options for disposal.
b. Depending on the pedigree of the waste, the radionuclides involved, the
concentrations of the radioactive materials and any hazardous waste constituents in the
waste, other disposal options may include properly permitted or licensed RCRA landfills,
hazardous waste disposal facilities, uranium mills, and uranium or thorium tailings ponds.
Each individual disposal facility has its own waste acceptance criteria and the selection is a
very complex decision that should be delegated to radioactive waste experts within USACE.
The health physicists at the HTRW-CX have experience with many types of waste disposal
and can assist any District. The Kansas City District has a number of pre-placed disposal
contracts available for use by all USACE Districts and some outside agencies. While
Districts are not obligated to use the Kansas City contracts, a good rule of thumb is that, for
waste quantities under 3000 cubic yards, the use of the pre-placed contracts will usually be
less expensive than the costs of the bidding process for other disposal sites and resulting
disposal fees.
c. Another consideration is radioactive waste owned by DOD. The DOD Executive
Agent for radioactive waste has been designated as the lead for disposal of these materials.
All disposal of DOD-owned radioactive materials or waste must be coordinated with the
Executive Agent through the HTRW-CX to comply with NRC and DOD licenses and
authorizations. Radioactive wastes generated by Civil Works activities, such as FUSRAP,
may not be considered DOD wastes.
d. Radioactive waste disposal regulations are very complex and some of the regulatory
methods and procedures have not yet been set. It is also important to coordinate any
characterization of waste and selection of disposal options with the HTRW CX to ensure that
an action at one site is not setting a precedent that will affect disposal options at other
USACE projects.
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8-3. Waste Disposal Facility Criteria. Each waste disposal facility has its own waste
acceptance criteria and lists what characteristics must be evaluated and what limits they
allow on each contaminant. The common data that must be supplied on all materials for
disposal include the following:
•
•
•
•
•
•
•
•
•
Waste generator
Location of waste generator
Physical state of the waste
Medium contaminated
Radionuclide or radionuclides present
Activity and concentration of each radionuclide
Total weight and total volume of the waste
Co-mingled hazardous substances
Quantity and concentration of hazardous substances
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CHAPTER 9
Primary Regulatory Processes
9-1. Introduction. This chapter will provide the project manager (PM) and project delivery
team with an overview of the primary regulations and requirements that USACE and their
contractors will follow while executing environmental restoration of sites contaminated with
radioactive waste or radioactive waste that is commingled with either CERCLA hazardous
substances or RCRA hazardous waste. Once the preliminary determination has been made
that a response action is warranted, two important and related questions must be answered for
every environmental remediation project:
• What regulatory authority governs this response action?
• What are the cleanup levels that must be achieved for the contaminants of concern
for the remedy to be protective of human health and the environment?
a. To determine the cleanup criteria, it is essential to determine the regulations that
apply to the site, as well as which Federal or state regulatory agency has the authority and
responsibility for enforcing the regulations. This chapter will discuss the primary restoration
programs that USACE follows when cleaning up radioactive waste or mixed waste
contaminated sites. The responsibilities of the two major Federal agencies that regulate the
environmental restoration activities will also be briefly discussed:
• The Nuclear Regulatory Commission (NRC) is responsible for decommissioning of
licensed facilities under the Atomic Energy Act (AEA).
• The Environmental Protection Agency (EPA) has regulatory authority over sites
under two separate environmental programs - CERCLA and RCRA.
In addition, there may be situations where more than one Federal regulatory agency or
multiple offices from the same Federal agency may have responsibility for regulating
different contaminants or activities at a site.
b. Characterization of the type of radioactive material or waste is a very important
component of determining which regulatory authorities govern the management of
radioactive material. The characterization process must examine the processing history of
the waste as well as the type and quantity of radionuclides present. Chapter 1 of this manual
contains definitions for the common types of radioactive wastes or materials that USACE
may encounter. In some situations, radioactive waste is characterized by what isn’t present
instead of what is present (e.g., LLRW). The term “mixed waste” is defined in the Federal
Facilities Compliance Act as waste that contains both RCRA hazardous waste and AEA
regulated, source, byproduct or special nuclear material.
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c. An excellent resource when dealing with radioactive contamination is the MultiAgency Radiation Survey and Site Investigation Manual (MARSSIM), which was developed
collaboratively by four Federal agencies having authority and control over radioactive
materials (DOD, DOE, EPA, and NRC). Appendix C of MARSSIM provides an overview of
the statutory authorities and regulations that are the responsibility of each Federal agency. It
is interesting to note that the EPA, NRC, and DOE derive their respective authorities for
promulgating regulations, standards, and orders from many of the same statutes.
d. A comprehensive explanation of all the regulations and administrative and
procedural requirements that USACE must comply with will not be included in this chapter.
However, a brief discussion will be provided on the primary environmental statutes and
regulations that pertain to the restoration of the radioactively contaminated sites. The PM
will need to coordinate with the appropriate disciplines of the project delivery team (e.g.,
Office of Counsel, health physicist, risk assessor, regulatory, etc.) to determine if there are
unique or additional requirements (e.g., state regulations) applicable to the specific project.
9-2. Environmental Response Authorities for Radioactive Waste or Mixed Waste.
a. Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA)[42 USC 9601 et seq.]. CERCLA, commonly referred to as “Superfund,”
established a national program for responding to uncontrolled releases of hazardous
substances into the environment from abandoned waste sites. CERCLA hazardous
substances are defined as any substance designated or listed under the Clean Air Act, the
Federal Water Pollution Control Act, the Toxic Substances Control Act, and the Resource
Conservation and Recovery Act. CERCLA will be the primary restoration program that
USACE will typically utilize to execute an environmental response action for sites that have
been contaminated with radioactive waste or mixed waste. However, if USACE does work
for others that operate under an NRC or agreement state license, the activities will be
conducted under the NRC regulations. On NRC licensed sites where USACE is
contemplating a FUSRAP cleanup under CERCLA, a Memorandum of Understanding
(MOU) may be needed to minimize the potential for dual regulation. The current NRCUSACE MOU for FUSRAP sites is described in Section 9-3d.(1) below.
(1) Authority. CERCLA provided broad Federal authority to respond directly to
releases or threatened releases of hazardous substances, pollutants, and contaminants that
may endanger public health or the environment. For non-governmental National Priorities
List (NPL) sites, undergoing a CERCLA remediation, EPA is the lead enforcement agency.
Executive Order 12580, Superfund Implementation, dated 23 January 1987, as amended by
Executive Order 13016, dated 28 August 1996 delegated many of the authorities of the
President established in CERCLA to DOD, as well as other Federal agencies. One such
authority is that DOD is the lead Federal agency for response actions at both NPL and nonNPL DOD installations. This includes the authority to select remedies, subject to the
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concurrence of EPA if it is an NPL site [CERCLA, Section 120(e)]. USACE also has lead
agency authority to select remedies at FUSRAP sites, regardless of whether the site is DOD
or not [Pub. L. 106-60 section 611]. CERCLA applies to radiological events at DOD and
DOE facilities, but does not apply to releases from NRC-licensed facilities subject to the
requirements of the Price Anderson Amendment (Section 170) of the AEA-essentially
nuclear power plants.
(2) Applicability. Radionuclides are considered hazardous substances under CERCLA
by virtue of their listing as Hazardous Air Pollutants (HAPs) under the Clean Air Act (CAA),
where they are listed in Appendix B to the List of Hazardous Substances (40 CFR 302.4). It
is important to understand that hazardous substances and hazardous waste have specific
meanings and are not synonymous. All RCRA hazardous wastes are by definition CERCLA
hazardous substances, but not all hazardous substances are hazardous wastes. It is important
to note that CERCLA excludes radionuclides that are considered source, byproduct, or
special nuclear materials from the definition of “release” if from a nuclear incident as defined
by the AEA, if such release is subject to requirements with respect to financial protection
established by the NRC (Price Anderson Amendment Act of 1988-42 USC 2210 et seq.) or
any release of source, byproduct, or special nuclear material from any processing site
designated under UMTRCA (42 USC 7911 et seq.).
(3) Implementing Regulations. CERCLA response efforts are guided by the National
Oil and Hazardous Substances Pollution Contingency Plan commonly referred to as the NCP
(40 CFR 300). The NCP are the regulations that EPA has promulgated to implement
CERCLA. The NCP establishes the criteria, methods, and procedures that must be followed
to investigate contamination and determine if a response action should be taken at a site to
protect human health or the environment.
(4) Process. In section 120(c) of CERCLA (42 USC 9620), Congress required EPA to
develop a list of all Federal facilities that ever stored, treated, disposed of, released or spilled,
or are currently generating, treating, storing or disposing of hazardous wastes, or have
released a hazardous substance in a reportable quantity. The list, which EPA maintains, is
called the Federal Agency Hazardous Waste Compliance Docket. CERCLA establishes the
requirements for actions on sites listed on the docket. Once a Federal facility is listed on the
docket, a preliminary assessment (PA) must be conducted at the facility. If, after completing
the PA and consulting the NCP requirements, further action is warranted, the facility must
perform a site inspection (SI). After completion of the PA/SI, EPA may elect to score the
site using the hazard ranking system (HRS). If the HRS is high enough (> 28.5), EPA will
determine whether to make the site an NPL site. A NPL site must initiate a remedial
investigation and feasibility study (RI/FS) no later than six months after inclusion on the
NPL. Upon completion of the RI/FS, the Federal facility must enter into an Interagency
Agreement with EPA within 180 days and commence on-site remedial action within 15
months. After the RI/FS has been completed, a proposed plan must be presented to the
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public with an opportunity for comments to be received and considered by the agency, after
which a record of decision (ROD) will be prepared and signed. Compliance with the NCP is
required regardless of whether the Federal facility or site is on the NPL. This means the
administrative and procedural requirements of the NCP must be followed. The site must
have appropriate site investigation and characterization, analysis of remedial alternatives, and
selection of a protective and cost-effective response action. The public must be allowed an
opportunity to comment on any response action, even if there is no further action required. A
further explanation of the CERCLA process is provided in Appendix F of MARSSIM and
paragraph 1.3 of EM 200-1-4. Districts are encouraged to coordinate early with regulators to
identify a single regulatory framework to guide the environmental restoration process. To
minimize potential duplication of efforts by states, tribes, and the EPA, it is important that
the lead regulator be clearly identified and communicated to all parties for each site. States
or tribes should generally be the lead regulator for environmental investigations and response
at non-NPL sites. In certain circumstances, EPA may serve as lead regulator where the state
or tribe requests it or when EPA chooses to exert its lead regulator role. In instances where
EPA assumes lead regulatory agency authority, roles should be documented and all parties
notified. If USACE is performing work for others that are under an NRC or agreement state
license, the lead regulator role may be the NRC or the agreement state.
(5) Cleanup Criteria. The CERCLA process [Section 121(d) of CERCLA (42 USC
9621)] requires that a “degree of cleanup” be determined for the remedial action. In
determining what remedial action is necessary and appropriate, the lead agency must
consider the nine criteria established by CERCLA, Section 121, and implemented in 40 CFR
300.430.(e). All CERCLA response actions must determine the applicable or relevant and
appropriate requirements (ARARs) for remediation of the site. Once they are identified, the
substantive elements of those ARARs must be determined, including all the conditions and
alternatives to their application. The NCP does provide relief from strict compliance with the
ARARs if certain conditions exist or can be met through a formal process to waive the
ARAR [40 CFR 300.430(f)(1)(ii)(C)]. The ARAR analysis must determine if a requirement
is a promulgated and legally enforceable Federal environmental law or regulation, or state
environmental or facility locating law or regulation. The requirement must contain
substantive criteria pertaining to the hazardous substances or pollutants or contaminants or
the circumstances of their release at the site.
(a) The requirement is applicable if it specifically addresses the contamination or
release at the site [40 CFR 300.5]. Another way to evaluate this is to pose the question; if the
CERCLA permit waiver for on-site activities did not exist, would the regulator be able to
impose the standard through a permit or other regulatory approval process? The ARAR
analysis process should include a legal analysis by the District Office of Counsel to
determine whether the requirement specifically addresses a hazardous substance, pollutant,
contaminant, remedial action, location or other circumstance found at a CERCLA site. The
District is cautioned against accepting or developing a “laundry list” of statutes or regulations
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that do not meet the CERCLA definition of an “Applicable” or “Relevant and Appropriate”
requirement.
(b) The requirement may also be an ARAR if it is relevant and appropriate to the
contaminants or the circumstances of their release, even if not applicable. Fundamentally,
the law or regulation must address situations sufficiently similar to the circumstances of the
release or the remedial action, and be well suited to the site. There are a number of factors
that must be considered in making the determination whether a requirement is relevant and
appropriate for the site [40 CFR 300.400(g)(2)]. It is very important to note that CERCLA
and the NCP are very definitive that only state standards that are promulgated, are identified
by the state in a timely manner, and are more stringent than Federal requirements may be
ARARs for a CERCLA response action. In accordance with DERP and the NCP, USACE
must formally request that the lead regulatory agency and support agency identify their
potential ARARs for a particular site. The District should request the regulator agency
provide the citation and explanation as to why they have identified a specific requirement as
a potential ARAR for the site.
(6) Response Actions. CERCLA authorized two kinds of response actions to be taken
where hazardous substances have been released or there is a potential for a release into the
environment: removal actions (short-term) and remedial action (long-term).
(a) Removal Action. The removal action is intended to address actual or threatened
releases in a prompt manner to protect human health and the environment. The removal
action is to abate, prevent, minimize, stabilize, mitigate, or eliminate the threat to human
health or the environment. Typically, the removal action is used to eliminate an imminent
hazard to human health or the environment. Removal actions shall, to the extent practicable,
contribute to the efficient performance of any anticipated long-term remedial action with
respect to the release concerned. Removal actions, unlike remedial actions, are not required
to comply (or waive) all ARARs except to the extent practicable considering the site
conditions. It is important to remember that removal actions don’t necessarily always require
removal of the contamination and may be erecting a fence to protect the public or providing
an alternate drinking water source to the public. EPA has categorized removal actions, under
CERCLA and the NCP, in three ways:
•
•
•
Emergency removal actions (within hours of discovery)
Time-critical removal actions (initiated within 6 months)
Non-time critical removal actions (planning and evaluation takes 6 months or
longer)
The NCP requires public involvement in the removal process, through the administrative
record process, public notices, and other mechanisms. Removal actions can take place at any
time during the entire CERCLA process. An engineering evaluation and cost analysis
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(EE/CA), which serves as a decision document, is required for non-time critical removal
actions.
(b) Remedial Action. The remedial action process is used under CERCLA to address
actual or threatened releases of hazardous substances that are serious, but not immediately
life threatening or dangerous to the environment. Remedial actions are typically conducted
after several years of investigation, evaluation of alternatives, and selection of a permanent
final remedy. The NCP provides the implementing regulations for conducting the
preliminary assessment (PA) and site inspection (SI) to determine if further site investigation
and characterization is necessary. The remedial investigation (RI) is the CERCLA phase that
can be considered the site characterization phase, in which the nature and extent of
contamination is determined and potential risks and exposure pathways are evaluated to
determine if there are unacceptable risks to human health and environment. The next phase
is the feasibility study (FS), which may be conducted concurrently with the RI. The FS is the
process to evaluate potential remedial alternatives to clean up the site. An important aspect
of the RI/FS process is to identify the potential ARARs for determining the cleanup standards
that must be achieved, as well as what impacts the ARARs may have on the possible remedy
alternatives. The nine criteria are used in the remedy selection process and it is important to
note that the selected remedy must be protective of human health and the environment and
comply with ARARs. This manual will not provide a comprehensive explanation of the
individual tasks that must be accomplished in preparing the PA, SI, RI, FS, proposed plan,
and ROD. EPA provides a guidance document on the necessary steps in performing a RI/FS
on a CERCLA site (EPA/540/G-89/004.
(7) Important Aspects of the CERCLA Process.
(a) Lead Agency Authority. The NCP provides a definition for “lead agency” in 40
CFR 300.5 that is very important when executing a CERCLA response action. In the case of
a release of hazardous substance, pollutant, or contaminant, where the release is on or the
sole source of the release is from, any facility or vessel under the jurisdiction, custody, or
control of DOD or DOE, then DOD or DOE will be the lead agency (as appropriate). The
Federal agency maintains its lead agency responsibilities whether the remedy is selected by
the Federal agency for non-NPL sites, or by EPA and the Federal agency (NPL sites), or by
EPA alone under CERCLA section 120 (NPL site where there is non-concurrence). USACE
acts as lead agency for several programs that are under their “jurisdiction, custody, or
control.” This includes the FUSRAP and FUDS programs where USACE has been officially
designated as the lead agency for the selection of the remedy. USACE may act as lead
agency at the request of the Commanders for installation restoration program (IRP) sites and
Base Realignment and Closure (BRAC) facilities.
(b) Permit Waiver for On-site Activities. CERCLA [Section 121(e)] and the NCP are
very specific that no Federal, state or local permit shall be required for the portion of any
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removal or remedial action that is conducted entirely on-site, where such response action is
selected and carried out in compliance with the CERCLA process. CERCLA response
actions do not need to comply with administrative requirements such as administrative
reviews, certifications, permitting, manifesting, reporting, and record keeping. However,
substantive requirements, which are non-administrative, relating to numerical cleanup levels,
required technology, emission control limitations, and other standards, must be complied
with. The permit waiver does not preclude the response action from complying with an
ARAR numerical standard that applies to the planned action.
(c) Use of “To Be Considered” (TBC) Documents. In the process of evaluating
remedial alternatives, a lead Federal agency may consider other governmental documents
that do not rise to the level of an ARAR. The NCP [§300.400(g)(3)] does make provisions
for the use of advisories, criteria, or guidance developed by EPA (e.g., OSWER Directives),
other Federal agencies or states that may be useful in developing CERCLA remedies. The
designation and use of TBCs is a discretionary matter for the lead agency, and it should be
carefully used, so as not to elevate to enforceability those guidance or policy statements that
are not useful to support a decision on a remedy. Generally, TBCs should only be used when
ARARs do not exist for a site, and only if they are not inconsistent with the nine criteria
mandated by CERCLA for the remedy selection process.
(d) Removal Action as a Final Remedy. The general perception established by the
NCP and understood by the public and the regulators is that the removal action is an interim
measure taken to eliminate an immediate or potential hazard to human health or the
environment. The removal action, to the extent practicable, is to contribute to the efficient
performance of any anticipated long-term remedial action with respect to the release of
hazardous substances. Unlike remedial actions, which must comply with (or invoke or
justify a waiver) all ARARs, removal actions comply with ARARs only “to the extent
practicable considering the exigencies of the situation.” The removal action has a number of
procedural requirements that do not correspond to the level of detail that is required of a
remedial action. A few of the major items are as follows:
• Public participation is more limited and compressed during a removal action.
• The removal action does not perform a comprehensive site characterization to
determine nature and extent of contamination in all media and all potential pathways of
exposure.
• Human and ecological risk assessment is generally abbreviated.
• Removal action does not generally provide a screening and detailed evaluation of
remedies.
The NCP does require an engineering evaluation and cost analysis (EE/CA) for non-time
critical removal actions but it does not share some of the important features (freezing
ARARs, site closeout, etc.) of the ROD for a remedial action. Therefore, a removal action is
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not the response action of choice for a final remedy. However, where circumstances dictate
such an approach, e.g., time is of the essence, substantive CERCLA criteria for removal
actions are met, and removal of the hazardous substance to unrestricted use levels does not
compromise safety and is not significantly more costly or time consuming than cleanup to
less conservative levels, a removal action to final remedy levels may be appropriate. If a
removal action is being planned as a final remedy, it would be important to obtain approval
from the USACE chain of command. Upon approval, the public and regulators should be
provided early notification of the intention for the removal action to be a final remedy. The
removal action should identify and comply with all ARARs that pertain to the response
action as well as not take advantage of ARAR waivers as a subsequent remedial action would
not be anticipated. The removal action should include a comprehensive site investigation to
determine the nature and extent of contamination (e.g. soil, ground water, etc.) to ensure that
the selected action protects human health and the environment. The removal action should
be followed by a no further action record of decision to achieve site closeout. Removal
actions taken by EPA, under the Superfund program, have a money ($2 million) and time (12
months) limitation. If the site is not on the NPL, DOD is not necessarily limited by these
restrictions as they apply to the use of Superfund money, but based on the previous factors,
complex and expensive response actions should still be performed as remedial actions, with
the remedial investigation, feasibility study, proposed plan, and record of decision in
accordance with the NCP.
b. Resource Conservation and Recovery Act (RCRA)[42 USC 6901 et seq.].
(1) Authority. RCRA is the primary Federal statute regulating the generation,
transportation, treatment, storage, and disposal of solid and hazardous waste. RCRA was
enacted by Congress to require proper management of waste generated at existing facilities.
RCRA has kept in stride with current waste management issues and problems by way of
Congressional amendments, the most notable being the Hazardous and Solid Waste
Amendments (HSWA). Under provisions of HSWA, Congress established the authority for
corrective action requirements at permitted or interim status hazardous waste management
facilities. Mixed waste, as defined in Chapter 1, contains radioactive and hazardous waste.
A dual regulatory framework exists for mixed waste, with the EPA or the RCRA-authorized
states regulating the hazardous waste and the NRC or NRC agreement states, or possibly
DOE, regulating the radioactive waste.
(2) Applicability.
(a) The RCRA Corrective Action program provides EPA (or authorized state) with the
authority to require a current owner or operator of a hazardous waste management facility to
take corrective action at a facility seeking a permit where there has been a release of a
hazardous waste or constituent at the facility, regardless of when waste was disposed of at the
facility, and to require work beyond the facility boundary where necessary to protect human
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health and the environment. It is important to note that under the RCRA regulations, source,
special nuclear material, and byproduct material (as defined by the AEA) are expressly
excluded from the definition of solid waste, and, thus from regulation under RCRA as a
hazardous waste.
(b) Over the past two decades, EPA, the NRC and state agencies have identified a
number of naturally occurring materials that, because of human activity, may present a
radiation hazard to people and the environment. This material is called technologically
enhanced naturally occurring radioactive material (TENORM). TENORM is generally
defined by the National Academy of Science as “any naturally occurring material not subject
to regulation under the Atomic Energy Act whose radionuclide concentrations or potential
for human exposure has been increased above levels encountered in the natural state by
human activities.” RCRA does not generally exempt this material from regulation, except it
exempts solid waste, including TENORM produced from the extraction, beneficiation, and
processing of ores and minerals (Bevill exclusion) and oilfield wastes from regulation as
hazardous wastes. Some states consider pre-1978 ore processing residuals to be TENORM
and subject to RCRA, however, USACE holds that these residuals meet the statutory
definition of source material and are, therefore, exempt from RCRA. If the uranium and/or
thorium content of the residuals exceeds 0.05% by weight, the residuals would become
regulatable source material.
(3) Implementing Regulations. Unlike CERCLA, which imposes remediation
requirements by establishing cleanup criteria with ARARs, the RCRA remediation process
has never been codified federally. Comprehensive corrective action regulations, also known
as “the Subpart S Initiative” were proposed on 27 July 90, 55 FR 30798, but were never
finalized. The objective of the proposal was to establish Federal corrective action standards
against which state programs could be assessed when determining whether to authorize them
to manage the RCRA corrective program for their state. However, EPA has since authorized
the majority of states for corrective action, even without the regulations. RCRA allows states
to develop and administer hazardous waste programs that are at least as stringent as the
Federal RCRA law.
(4) Closure. The cleanup standard for RCRA closure requires the owner or operator of
an RCRA interim status or permitted treatment, storage or disposal facility (TSDF) to close
in a manner that:
• Minimizes the need for further maintenance.
• Controls, minimizes, or eliminates post-closure release or migration of hazardous
waste and other hazardous constituents into the soil, air, or water (ground water or surface).
• Protects human health and the environment to the extent necessary.
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One method of obtaining RCRA closure of the TSD unit or facility is achieved by leaving the
wastes in place, which is referred to as closure-in-place. The second method is to remove the
hazardous waste and decontaminate any releases or spills to equipment, structures, or the
soil. This method is referred to as closure by removal or decontamination (also known as
“clean closure”) and would not leave any contamination.
(5) Corrective Action. RCRA requires correction action for releases of hazardous
waste or hazardous waste constituents from a solid waste management unit (SWMU) at
TSDFs with a permit and those seeking a RCRA permit or approval of final closure. For
example, a military installation may have a permit to store hazardous waste and would be
subject to a corrective action if hazardous waste was spilled or released from the storage area.
Note that only one regulatory authority, either Federal or state, shall possess RCRA
corrective action authority. The goal of corrective action is to control or eliminate risks to
human health and the environment. Risk-based decision-making is used to ensure protection
of human health and the environment. RCRA corrective actions tend to be governed by
media cleanup standards, which are similar to CERCLA ARARs. Media cleanup standards
are the concentrations of a hazardous constituent that a remedy must achieve in a specific
medium (e.g., soil, water). A cleanup standard may be based on promulgated Federal or state
standards or developed through a site-specific risk assessment.
(6) Risk-Based Clean Closure.
(a) This closure method is a blend of the RCRA closure and the corrective action
programs. A treatment, storage or disposal (TSD) unit can be considered clean-closed if it
meets the risk-based standards appropriate under CERCLA cleanup or a RCRA corrective
action. This method draws upon the removal and decontamination aspects of RCRA closure.
EPA still requires the removal of the hazardous wastes and liners under this method, but it
would not require that all contamination be removed. Limited amounts of hazardous
constituents may remain in the media, provided the contaminants are below concentrations
that would present a risk to human health or the environment. The second part to this process
is the use of risk-based standards to determine your cleanup levels, which determine the level
of decontamination that must be achieved for closure.
(b) The permittee/respondent may propose media cleanup standards. The standards
must be based on promulgated Federal and state standards, risk derived standards, all data
and information gathered during the corrective action process (e.g., interim measures, RCRA
facility investigation, etc.) or other applicable guidance documents. If no other guidance
exists for a given contaminant and media, the permittee/respondent shall propose and justify
a media cleanup standard. The final media cleanup standards are determined by the
implementing agency when the remedy is selected and documented in the Statement of
Basis/Response to Comments or permit modification. It would be advisable to always
propose media standards to the regulators instead of relying on the implementing agency to
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set the media standards for the corrective action. (Refer to MARISSIM, Appendix F, for
explanation of CERCLA and RCRA process).
c. Atomic Energy Act of 1954, as amended (AEA) [42 USC 2011 et seq.]. This Act is
the fundamental U.S. law on the civilian and military uses of source, byproduct, and special
nuclear material. The Act requires that civilian uses of nuclear materials and facilities be
licensed, and it empowers the NRC (AEC’s co-successor) to establish by rule or order, and to
enforce, such standards to govern these uses as in order to promote the common defense and
security and protect health and safety of the public. Commission action under the Act must
conform to the Act’s procedural requirements, which provide an opportunity for hearings and
Federal judicial review in many instances. The NRC regulatory responsibility pertains to the
commercial operations involving radioactive material that are not associated with nuclear
weapons development or research, or military uses of nuclear power. Their responsibility
extends primarily to the commercial power industry, medical industry, and other commercial
applications of radioactive material.
(1) DOE (AEC’s co-successor) authority under the AEA extends to source material,
special nuclear material, and byproduct material under the control or jurisdiction of the
Secretary of Energy, and a limited number of specified programs, including nuclear weapons
production and research related to national security interests. DOE is also the lead Federal
agency in the remediation of legacy contamination at Federal facilities that were and remain
engaged in those types of activities.
(2) EPA has the general responsibility for ensuring that all other Federal agencies
remediate hazardous substances to levels that are protective for the public and the
environment. EPA is provided the authority to issue applicable environmental radiation
standards to protect human health and the environment from radioactive materials in the
general environment outside the boundaries of the facilities under the control of the NRC.
d. Defense Environmental Restoration Program (DERP)[10 USC 2701 et seq.].
Congress created the Defense Environmental Restoration Account (DERA) when it enacted
Section 211 of Superfund Amendments and Reauthorization Act (SARA) -also known as
DERP. Although DERA is not limited to sites on the EPA NPL, per the statute, hazardous
substance response activities funded by the DERA must be carried out subject to, and in a
manner consistent with, Section 120 of CERCLA. DOD environmental managers should be
aware of the significance of that limitation, particularly when EPA or state regulators insist
the cleanup be conducted pursuant to RCRA corrective action or state requirements other
than CERCLA. If regulators demand cleanup efforts that are inconsistent with CERCLA
Section 120, DERA funds will not be available to support those activities. District legal
counsel should be a part of the project delivery team when addressing which cleanup
authority should be followed. DERP does not apply to Civil Works facilities in accordance
with DOD policy.
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(1) It is important to note that the DERP statute [10 USC 2705] requires that EPA and
appropriate state and local authorities must receive prompt notice from DOD under the
following conditions:
• Discovery of releases or threatened releases of hazardous substances at a facility.
• The extent of the threat to public health and the environment that may be associated
with any such release or threatened release.
• Proposal made by the Secretary to carry out response actions with respect to any
such release or threatened release.
• The initiation of any response action with respect to such release or threatened
release and the commencement of each distinct phase of such activities.
(2) The DERP statute requires that EPA and state and local authorities shall have an
adequate time to comment on notices and proposals for response actions (removal or
remedial) and that investigations and cleanup actions be consistent with CERCLA and the
NCP. The DERP statute also requires that the program be carried out in consultation with
EPA (10 USC 2701).
e. Army Reactor Program. The Army Reactor Program has designated USACE as
responsible for nuclear reactor engineering, design, construction, and decommissioning
design and implementation. USACE is also responsible for assisting, when requested, in
compliance and environmental restoration projects for deactivated reactors. The Department
of Army, under the provisions of the AEA (Section 110), self regulates under the Army
Reactor program. The Army’s reactor policy is to “follow to the maximum extent possible,
the regulations of the U.S. Nuclear Regulatory Commission and the recommendations of the
National Council of Radiation Protection and Measurements” (AR 50-7). The Army Reactor
Program is designed to ensure that Army reactors are designed, constructed, operated,
maintained, and decommissioned per U.S. national standards. When NRC regulations and
Army Reactor regulations prescribe the same or similar requirements, the NRC regulations
will be followed with notifications through command channels. If an Army reactor is also
NRC licensed, then the NRC regulations will be followed with documentation provided to
the Army Reactor Office.
9-3. Roles and Responsibilities for Regulating Radioactive Material.
a. Federal Agencies.
(1) EPA’s radiation protection responsibilities originate from both the AEA and
several environmental statutes. Under Reorganization Plan No. 3, which became law on 2
December 1970, EPA was made responsible for establishing applicable environmental
standards for the protection of the general environment from radioactive material. EPA was
provided the research, monitoring, promulgating regulations, and enforcement authorities for
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media-specific chemical and radioactive pollutants. However, the transfer of radiation
protection responsibilities to EPA was more limited than other pollutants because the Atomic
Energy Commission (AEC) retained the responsibility for implementing and enforcement of
radiation standards. Under the AEA, these standards were defined as “limits on radiation
exposures or levels, or concentrations or quantities of radioactive material in the general
environment outside the boundaries of the facilities that were regulated by the AEC” (later
became the NRC).
(a) It is important to note that over the 30 years of existence, EPA has gained or
asserted enforcement authority for some radioactive materials under several environmental
statutes that Congress passed subsequent to the AEA. Through enactment of new statutes
(e.g., Clean Air Act, Safe Drinking Water Act, CERCLA), EPA has been given additional
responsibility to regulate certain activities or aspects of radioactive materials. EPA has
established multiple offices within their agency that may be responsible for implementing
regulations, depending on the environmental media and statute. When USACE is executing
a radioactive or mixed waste restoration project, it is important to understand which EPA
offices are administering the different implementing regulations.
(b) A comprehensive explanation of the statutory authorities of EPA and the individual
offices responsibilities may be found in Appendix C of MARSSIM. An additional
publication that discusses EPA’s authorities and responsibilities for the past three decades is
EPA 402-B-00-001.
(2) The NRC is an independent regulatory agency, created by the Energy
Reorganization Act of 1974. Congress abolished the AEC and made the NRC responsible
for ensuring the protection of the public’s health and safety in association with the operation
of commercial nuclear power plants and fuel cycle plants, medical, industrial, and research
applications of nuclear materials. Their authority includes protecting the public’s health and
safety as well as the environment with the storage, transportation, and disposal of nuclear
materials and waste.
(a) NRC issued regulations establishing standards for the decommissioning of facilities
regulated under NRC licenses. These standards are mainly codified at 10 CFR Part 20,
Subpart E, and provide radiological criteria for termination of licenses. They apply to
facilities decommissioned under 10 CFR Part 30, governing the licensing of byproduct
materials, Part 40, governing the licensing of source material, and Part 70, governing the
licensing of special nuclear material. The criteria are excluded from application to uranium
and thorium recovery facilities subject to 10 CFR Part 40, Appendix A.. The
decommissioning standards establish criteria for license termination with unrestricted use,
license termination under restricted conditions, and allow the submission of alternate criteria
for license termination. A facility is considered to be acceptable for unrestricted use if
residual radioactivity exceeding background results in a total effective dose equivalent
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(TEDE) of 25 millirem (mrem) per year, including ground water sources of drinking water,
and must further reduce residual radioactivity to ALARA levels. The requirement for an
ALARA analysis is provided in 10 CFR Section 20.1402 and 20.1403, but this new section
provides that this analysis must also consider detriments from decontamination and waste
disposal, such as deaths from transportation accidents. A facility will be considered
acceptable for restricted use if the levels of residual radioactivity are ALARA, there are
legally enforceable institutional controls that will assure the TEDE will not exceed 25 mrem
per year and will not impose undue burdens on the local community, and, if the institutional
controls fail, the TEDE is ALARA but not more than 100 mrem per year.
(b) Projects not regulated directly by NRC, may be subject to CERCLA or RCRA.
The NRC regulations may not be “applicable” but under CERCLA, they may be “relevant
and appropriate” and used to develop clean-up levels. The NRC standard titled,
“Radiological Criteria for License Termination,” 10 CFR Part 20, Subpart E, may be relevant
and appropriate for sites that were previously licensed or handled a licensable type of
radioactive material. It may also be an ARAR if it is well suited to the particular site in
accordance with Section 121 of CERCLA and the NCP. This regulation uses a dose
assessment to establish criteria for license termination and release of the property. For
unrestricted release of property, the acceptable total effective dose equivalent (TEDE) is 25
mrem/year above background and as low as is reasonably achievable (ALARA).
(c) NRC allows a party to propose alternate criteria for decommissioning if it is
protective of public health and the environment, and the dose from all man-made sources
combined, except medical, would be no more than 100 mrem per year. The alternative must
include institutional controls as described in Section 1403, and achieve ALARA levels using
the analysis described above. A licensee must submit a plan, demonstrate public
participation in the development of the plan, and obtain approval from the Commission based
on NRC staff recommendations.
(3) The DOE is responsible for developing and implementing a national energy policy
and for developing new energy sources for domestic and commercial sources. DOE is also
responsible for management of the U.S. nuclear weapons program and production facilities
and obtains its basic authorities from the AEA of 1954. The DOE nuclear weapons program
responsibilities encompass the Stockpile Stewardship Program (now handled by the National
Nuclear Security Administration within DOE), management of low and high-level
radioactive wastes generated by past nuclear weapons and research programs, and for
constructing and maintaining a repository for civilian radioactive wastes generated by
commercial nuclear reactors. DOE develops its own standards under the authority of the
AEA by issuing DOE orders, and is responsible for enforcing their standards as well as EPA
regulations at DOE facilities.
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(a) DOE provides for the framework for DOE environmental management in DOE
Order 450.1 by establishing environmental protection requirements, authorities, and
responsibilities for their operations. DOE complies with applicable Federal, state and local
environmental protection laws and regulations, executive orders, and DOE policy and
guidance.
(b) DOE restricts off-site management of radioactive mixed waste through DOE Order
5400.5. All radioactive wastes and mixed waste must be disposed of at a DOE facility,
unless DOE grants a specific exemption for that waste. If granted an exemption, mixed
waste can be treated off-site at a licensed commercial TSD facility that has the required
RCRA permit and a NRC or state license for the radionuclides being shipped.
(c) Specific requirements on the management of radioactive waste material are
contained in DOE Order 435.1. The DOE order is meant to ensure that all DOE radioactive
waste is managed in a manner that is protective of work and public health and safety, and the
environment.
(d) Much of the DOE 5400 series orders have been codified at 10 CFR 835.
b. State Involvement. Under CERCLA, EPA does not authorize states to administer
the program. However, states may promulgate their own “mini” CERCLA-type laws. It
should be recognized that these are strictly state laws and do not preempt the authorities of
EPA or other Federal agencies under CERCLA. CERCLA does include many provisions for
consulting with and comment by state officials regarding response actions. In particular,
Section 121(f) provides a list of CERCLA response phases in which the state is required to
be given an opportunity for meaningful involvement. Section 120(a)(4) provides that, for
current Federal facilities not listed on the NPL, state laws regarding removal and remedial
actions are applicable to response actions conducted at such facilities. There are provisions
in Section 121 regarding state ARARs, and relief from state laws that exceed ARARs or are
not applied consistently to Federal and other facilities. Section 121(e) provides that Federal,
state, and local permits are not required for response actions conducted on the CERCLA site,
but that the substantive requirements that would otherwise be applicable shall be met in
providing for removal or remedial actions. The NCP provides that this permit waiver applies
to NPL sites, and also to other response actions led by Federal agencies. The authority to
select the lead agency remedy is not subject to state concurrence or non-concurrence under
any law, regulation, or executive order. The precise determination of state authority will
depend on a particular factual circumstance and must be reviewed by agency counsel on a
fact-specific basis. The state is expected to have a meaningful opportunity for consultation
with the lead agency throughout the response process, and state laws must be identified and
considered and their substantive standards and requirements complied with, but their
approval or permits that might otherwise be required are not necessary before a lead Federal
agency proceeds with necessary response actions.
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c. LLRW Compacts. In 1980, Congress passed the Low-Level Radioactive Waste
Policy Act to encourage states to develop low-level radioactive waste disposal facilities or to
enter into regional compacts among several states to develop facilities to serve the member
states. There are currently ten regional compacts, and additional states that remain
unaffiliated. Each compact assigns a host state the first tenure, typically 20 years, for
disposing of LLRW. Compacts may also enter into agreements with other compacts to
dispose of their waste. At the time the Act was passed, there were three operational LLRW
disposal sites in the country, Richland, Washington, Beatty, Nevada, and Barnwell, South
Carolina. Since that time, the Beatty facility has closed and one new facility was opened in
Utah. The Utah facility, which is not affiliated with the Compact system, accepts Class A
LLRW nationwide, subject to the waste meeting its waste acceptance criteria under its
operating licenses. The Richland facility accepts waste only from its own compact (the
Northwest compact) and the Rocky Mountain compact. The Barnwell facility is the only
facility accepting Class A, B, and C waste from outside the compact to which it belongs.
However, under state law, the Barnwell facility is in a 6-year process to ramp down the
amount of waste that may be accepted from outside the Atlantic Compact states. After 30
June 2008, the Barnwell facility may only accept LLRW from the Atlantic Compact states.
This is a significant concern for future disposal of higher activity LLRW (Class A, B, or C)
from decommissioning or CERCLA response actions.
(1) Compacts may prohibit the disposal of LLRW from outside the member states in
certain circumstances, or charge increasing surcharges from states that have neither
developed their own disposal facility nor entered into a compact that develops a disposal
facility, subject to emergency authority in the NRC to grant access to a licensed compact
facility if necessary to eliminate an immediate and serious threat to the public health and
safety or the common defense and security [42 USC 2021e and 2021f.] The statute
specifically allows a compact facility to refuse to accept for disposal material identified
under the FUSRAP or may accept the material for disposal subject to meeting their waste
acceptance criteria under their NRC/Agreement State license. The Act does state that the
Federal government is responsible for disposal of LLRW generated by DOE,
decommissioning Navy vessels, or waste generated by atomic weapons research, testing, or
production.
(2) Compacts may state that, for waste to be sent out of their compact, the DOD must
have permission. This issue must be coordinated with the District and HTRW-CX Office of
Counsel to determine if there is a statutory requirement to obtain permission for the LLRW
to be sent to a disposal facility outside the Compact where the LLRW is generated. The
customer may request that USACE obtain this permission, even though it is determined to
not be applicable.
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d. Significant Memorandums of Understanding (MOUs).
(1) The NRC and USACE signed an agreement on 5 July 2001 to temporarily suspend
NRC licenses on FUSRAP sites that were to be remediated to unrestricted levels, and to
minimize dual regulation and duplication of regulatory requirements at NRC-licensed
facilities. At the written request of USACE, NRC will initiate action for the suspension of
the NRC license or portions of the license for a FUSRAP site to be remediated by USACE
under CERCLA authority. USACE takes temporary control and responsibility for radiation
control and for ensuring public health and safety during the CERCLA response action. Upon
completion of the response action, NRC will reinstate the license for the facility. For
activities where a potential dual regulation could exist, the two agencies agree to cooperate,
share information, and coordinate activities in their respective programs. USACE, as
provided for in section 121(e) of CERCLA and 40 CFR 300.400(3), is not required to obtain
an NRC license for its on-site remediation activities conducted under its CERCLA authority.
The NRC may observe, as it deems warranted, remediation activities being conducted by
USACE and may issue comments or questions arising from their observations of the USACE
response action. USACE agrees to remediate the licensed site to meet at least the
requirements of CERCLA and of 10 CFR 20.1402. The ARARs in the final executed ROD
will include 10 CFR 20.1402 or a more stringent requirement.
(2) The NRC and EPA signed an agreement on 9 October 2002 on the radiological
decommissioning and decontamination of NRC-licensed sites. The MOU will defer EPA’s
authority under CERCLA for most of the NRC licensed sites that are being decommissioned
under NRC authority. The MOU includes provisions for NRC and EPA to consult about
certain sites when, at the time of license termination 1) ground water contamination exceeds
EPA-permitted levels (MCLs), 2) NRC contemplates restricted release or use of alternate
criteria at the site, and 3) residual radioactive soil concentrations exceed levels defined in
Table 1 of the MOU for residential or industrial and commercial future land use.
9-4. Other Major Environmental Statutes and Regulations.
a. Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) [42 USC 7911 et
seq.]. In the 1940’s, the U.S. government began to purchase uranium for the atomic weapons
program. Large quantities of uranium milling tailings, the waste byproduct of the extraction
of uranium from ore (“yellowcake production”), were generated in the processing of the ore
to obtain the uranium metal. The mill tailings (sand-like material) were stored in surface
impoundments (piles) predominantly in the western United States where the ore was mined.
Historically, uranium mill tailings were not covered under the AEA since they were not
considered to be hazardous. Testing of the mill tailings indicated they were highly
contaminated with radionuclides (Ra-226) and inorganics (arsenic, molybdenum, and
selenium). The mill tailings were not regulated until the passage of the Uranium Mill
Tailings Radiation Control Act (UMTRCA) in 1978. Section 275 of the AEA, as amended
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by Section 206 of UMTRCA, directed EPA to set generally applicable health and
environmental standards to govern the stabilization, restoration, disposal, and control of
effluents and emissions at both active and inactive mill tailings sites. Title I of the Act
covers inactive uranium mill tailing sites, depository sites, and vicinity properties. It directs
EPA, DOE, and NRC to do the following:
• EPA must set standards that provide protection that is as consistent with the
requirements of RCRA as possible. The standards must include ground water protection
limits.
• DOE must implement EPA’s standards for the tailings piles and nearby properties
and provide perpetual care for some properties.
• NRC must review completed site cleanups for compliance with EPA standards and
licenses issued for the site to the state or DOE for perpetual care.
• Title II of the Act covers the operating uranium processing sites licensed by the
NRC. EPA was directed to promulgate disposal standards in compliance with Subtitle C of
the Solid Waste Disposal Act, as amended, to be implemented by NRC or the Agreement
States.
• UMTRCA applies to residual radioactivity at NRC-licensed uranium mill sites and
at specifically listed inactive mill sites (22 sites designated by Congress and 2 sites by DOE).
Though not “applicable” to FUSRAP sites that are undergoing a CERCLA response action,
these regulations may be considered “relevant and appropriate” to on-site actions involving
uranium or thorium mill tailings at some of the FUSRAP sites.
(1) 40 CFR 192. EPA promulgated these regulations in January 1983 to address the
inactive tailing sites that qualified for remedial action under Title I of UMTRCA. The
regulations were written to control the risks from four principal environmental pathways:
•
Diffusion of radon-222, the decay product of radium-226, from tailings into indoor
air.
• Direct exposure to gamma radiation that results from many of the decay products in
tailings (lead-214, bismuth-214, thallium-210).
• Dispersal of small radioactive particles into the air by wind erosion of un-stabilized
tailing piles.
• Waterborne transport of radioactive and toxic (heavy metals) material by erosion,
wind or leaching to the surface and ground water.
(a) Subpart A of 40 CFR 192 contains design requirements for the control of disposal
areas for tailings, resulting from processing or extraction of uranium, that are located at the
processing site or adjacent properties. The control mechanism must be effective for a
minimum of 200 years and up to 1000 years to the extent reasonably achievable. Releases
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from radon-222 to the atmosphere must not exceed 20 pCi/m2. This regulation also contains
ground water protection requirements for disposal sites.
(b) Subpart B of §192 contains cleanup standards for land and buildings and adjacent
properties contaminated with residual radioactivity from processing ore for uranium. The
soil cleanup levels are for residual radioactive materials from a processing site not to exceed
a concentration of radium-226, averaged over any area of 100 square meters, of 5 pCi/g
above background averaged over the first 15 centimeters of soil below the surface, and 15
pCi/g above background over 15 centimeter layers of soil below the first 15 centimeters of
soil. This regulation does not apply to sites owned or controlled by a Federal agency after
1978 or to a site that is currently NRC licensed or had a NRC license in 1978 or thereafter.
The standard includes requirements for occupied or habitable buildings and requires that the
remedial action achieve an annual average (or equivalent) radon decay product concentration
(including background) not to exceed 0.02 Working Level (WL), which is defined in the
regulations. In addition, the gamma radiation level shall not exceed background by more
than 20 microroentgens per hour. Ground water below the processing site and nearby areas
with residual radioactive materials shall be monitored to ensure that the levels of constituents
specified in Subpart A are not exceeded.
(c) Subpart C of §192 addresses the implementation of Subparts A and B and contains
requirements for applying site-specific supplemental standards in lieu of strict compliance
with Subparts A and B in limited circumstances. Any general standard may be changed if
there is a clear and present risk of injury to workers or the public, despite reasonable
protective measures, from compliance with the general standards. The standards for land,
ground water, or surface control may be changed if remedial actions taken to meet standards
would produce health and environmental harm that is long-term and grossly disproportionate
to health and environmental benefits that may reasonably be anticipated. The standards may
be changed if the estimated cost of remedial action to satisfy soil cleanup levels at a
“vicinity” site is unreasonably high relative to the long-term benefits, and the residual
radioactive materials do not pose a clear present or future hazard. In situations where
radionuclides, other than radium-226 and its decay products, are present in sufficient quantity
and concentration to constitute a significant radiation hazard, the remedial action shall reduce
other residual radioactivity to levels that are as low as is reasonably achievable and conform
to the standards of subparts A and B to the maximum extent possible. Supplemental
standards for ground water must preserve all current and reasonably projected future uses of
the water. UMTRCA requires that both the general standards and the implementation of
them be developed on the basis of an analysis of the reasonableness of the benefits compared
to the economic and environmental costs.
(d) Subpart D to §192 contains criteria for restoration of licensed uranium byproduct
processing and disposal areas. Standards for closure of byproduct disposal areas are
provided. The disposal area shall include a radon barrier to limit releases of radon-222 to 20
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pCi/m2 per second averaged over the entire impoundment for a design life of 1000 years, to
the extent reasonably achievable, but no less than 200 years. This standard does not apply
areas that require cleanup to the land standard (5/15 pCi/g) for radium-226.
(e) Subpart E to §192 contains criteria for restoration of licensed thorium byproduct
processing and disposal areas. The standards govern facilities licensed for thorium
processing and their byproduct disposal sites, and generally use the same standards as
uranium processing and disposal areas, which require a permanent radon barrier to limit
release of radon-220 and radium-228.
(2) 10 CFR 40, Appendix A.
(a) The NRC has established criteria in 10 CFR 40, Appendix A, for the operation of
active licensed uranium and thorium mills and the disposition of tailings or wastes produced
by the extraction or concentration of source material (uranium and thorium) from ores
processed primarily for their source material content. This regulation is of interest primarily
for situations where USACE would be performing a CERCLA remediation and it was
determined to be “relevant and appropriate” for a milling site or mill tailings site that was
inactive prior to the enactment of UMTRCA where byproduct materials were managed and
radionuclides other than radium in soil are present, and where building surfaces are
contaminated. This criterion uses a benchmark dose derived using site conditions and the
assumption that 5 pCi/g radium above background is present in the top 15 centimeters and is
present at 15 pCi/g above background in the subsurface. The benchmark dose is then back
calculated to derive concentrations of the radionuclides to which the criterion is being
applied. Normally, radionuclides that this criterion will be relevant and appropriate for will
be total uranium and thorium-230.
(b) This regulation covers more activities than the EPA UMTRCA standards, but they
conform to the EPA UMTRCA standards for comparable activities. It is important to note
that the NRC considers milling wastes to include equipment and piping that was used for
processing the ore. Byproduct material is disposed of in uranium mill tailings
impoundments, subject to meeting NRC regulations. The NRC regulation provides more
radiological criteria on the decommissioning of licensed uranium and thorium mills. The
NRC regulation uses the existing 5/15 pCi/g soil radium standard to derive a dose criterion
(benchmark approach) for the cleanup of byproduct material other than radium in soil for
surface activity on structures and land. The NRC standard provides a regulatory basis for
determining the extent to which lands and structures at uranium and thorium mills must be
remediated before decommissioning of a site can be considered complete and the license
terminated.
b. Clean Air Act (CAA) [42 USC 7401 et seq.]. The CAA standards called “National
Emissions Standards for Hazardous Air Pollutants” (NESHAPs) limit the allowable level of
air emissions of radionuclides, other than radon-222 and radon-220, from facilities owned or
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operated by DOE and from Federal facilities not owned or operated by DOE or licensed by
the NRC. EPA has promulgated implementing regulations for the control of hazardous air
pollutants (HAP) from major and area sources in 40 CFR 61. CERCLA response actions
often times identify NESHAPs as a potential ARAR when close examination of the
applicability of the regulation reveals that it does not pertain to the activity. It is important to
note that EPA has proposed a NESHAP regulation for the category entitled “Site
Remediation” (67 FR 49398) on 30 July 2002 for the control of HAP emissions to the
ambient air. However, a final rule would still have to be promulgated before NESHAPS are
established for remediation activities. The potential NESHAP subparts that may apply under
limited scenarios are as follows:
• Subpart H - National Emission Standards for Emissions of Radionuclides Other
Than Radon From DOE Facilities (does not apply to §§191 or 192 facilities).
• Subpart I - National Emission Standards for Radionuclide Emissions From Federal
Facilities Other Than NRC Licensees and Not Covered by Subpart H (does not apply to
§191, Subpart B or §192 mill tailing piles).
• Subpart Q - National Emission Standards for Radon Emissions From Department of
Energy Facilities (does not apply to Title I facilities of UMTRCA but does apply to a specific
list of DOE facilities).
• Subpart T - National Emission Standards for Radon Emissions From the Disposal
of Uranium Mill Tailings.
(1) These regulations require that emissions of radionuclides to the ambient air shall
not exceed those amounts that would cause any member of the public to receive in any year
an effective dose equivalent of 10 mrem. Also, for non-DOE Federal facilities, emissions of
iodine shall not exceed those amounts that would cause any member of the public to receive
in any year an effective dose equivalent of 3 mrem/year. The owner or operator of facilities
covered by these regulations must submit an annual report regarding emissions to EPA by 31
March of the following year.
(2) Title V of the CAA requires operating permits for all major sources (40 CFR 70).
Some decommissioning activities, such as hazardous and mixed waste treatment, storage, and
disposal units, may require Title V permits because of radionuclide emissions. Additionally,
some activities (including treatment of mixed waste) may emit enough other regulated
pollutants (e.g., volatile organic compounds and lead) to qualify as a major source. A Title V
permit would not be required on a CERCLA response action because of the permit waiver
[CERCLA, Section 121(e)]. Because Title V is a procedural requirement (administrative)
and not a substantive requirement, the CERCLA response action would not need to comply
for on-site activities.
c. Safe Drinking Water Act (SDWA) [42 USC 300f et seq.]. The SDWA requires EPA
to promulgate and enforce primary standards for contaminants in public water systems,
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including radionuclides. The 1986 amendments required EPA to develop maximum
contaminant level goals (MCLGs) and maximum contaminant levels (MCLs). In 1991, EPA
proposed a revision to raise the MCLs for combined radium-226 and radium-228 from 5
pCi/L to individual MCLS of 20 pCi/L for each isotope. After further evaluation, EPA
decided to retain the current combined radium-226/228 level of 5 pCi/L based on risk to
humans (65 FR 76708). Under the 1996 amendments to the SDWA, EPA is required to
ensure that any revision to a drinking water regulation maintains or provides for greater
protection of the health of persons. The EPA rule (promulgated 7 December 2000) becomes
effective in December 2003 and establishes the uranium MCL at 30 µg/L. The gross alpha
(excluding uranium and radon but including radium-226) remained at the current level of 15
pCi/L. The beta particle and photon radioactivity MCL was also retained at the level of less
than or equal to 4 mrem/year to the total body or any given internal organ.
(1) When determining cleanup criteria for contaminated ground water, MCLs
established under the SDWA may be considered ARARs that must be attained by the
selected remedy, if the affected ground water is a current or potential drinking water source.
CERCLA, Section 121(d)(2)(A) and (B), provides that standards developed under the SDWA
and the Clean Water Act may be relevant and appropriate, depending on the designated or
potential use of the water, the purposes for the criteria, and the latest information.
Radioactive substances’ MCLs are applicable to community water systems, which are
defined by EPA as 15 service connections used by year round residents or regularly serves at
least 25 year-round residents. For non-community water systems, the radioactive substances’
MCLs may still be considered relevant and appropriate if the water is an actual or potential
source of drinking water.
(2) In addition to MCLs, maximum contaminant level goals (MCLGs) established
under the SDWA are sometimes designated as ARARs for the response action. Because the
SDWA has a MCLG of zero for all radionuclides, it is important to note the NCP states
MCLGs can only be considered ARARs when non-zero concentrations are established.
(3) Some states have laws or regulations that establish a universal non-degradation
standard for ground water. This has the effect of establishing background as the standard to
be achieved if the law or regulation is considered an ARAR for the ground water remedy. In
practice, satisfying a non-degradation standard is frequently not technically practicable or
achievable. If information is developed that demonstrates technical impracticability, then a
waiver of the ARAR under the NCP provisions would be possible.
(4) For radioactive or mixed waste remediation, where the NRC decommissioning
standard is an ARAR, then ground water must also be considered in the all-pathways analysis
of dose. The ground water exposure could lead to more restrictive cleanup levels than the
MCLs, or additional restrictions may be necessary to control exposure. On some sites there
may be no ground water pathway, so the exposure from ground water would not be included.
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If there are no ARARs for contaminated ground water at a site, then the risk assessment
process should be used to develop cleanup levels.
d. Clean Water Act (CWA) [33 USC 1251 et seq.]. The Federal Water Pollution
Control Act commonly known as the Clean Water Act (CWA) is the principal law governing
the restoration and protection of the nation’s streams, lakes, and estuaries. The CWA’s
principal objectives are to prohibit discharges of pollutants into U.S. navigable waters, except
in compliance with a permit, and achieve an interim goal of protecting water quality for fish,
wildlife, and recreational uses. The CWA established several regulatory programs,
standards, and plans for the prevention, reduction, and elimination of pollution in the nation’s
water, which include the following:
• National Pollutant Discharge Elimination System (NPDES) Program that
establishes an effluent permit system for point source discharges into navigable waters. The
NPDES storm water program is designed to prevent discharge of contaminated stormwater
into navigable waters. The NRC regulates discharges of materials subject to the AEA.
• National and Local Pretreatment Standards that require new and existing industrial
users to users to pre-treat their wastewater prior to discharging to a Publicly Owned
Treatment Works (POTW) to prevent pollutants from overloading a POTW or interfering
with the operation of the treatment facility.
• Dredge or Fill Discharge Permit Program that establishes a permit system
administered by USACE to control the placement of dredge or fill material in waters of the
United States, including wetlands.
• Sewage Sludge Use and Disposal Program that protects human health and the
environment when POTW sludge is managed or disposed of.
(1) The NPDES requires all discharges to the waters of the United States to comply
with certain pollutant discharge criteria. The term “pollutant” includes “radioactive
materials, except those regulated by the AEA.” Radioactive material that is covered by the
AEA includes source, byproduct, and special nuclear material. The NPDES regulations
specifically prohibit radiological discharges: “No permit may be issued for the discharge of
any radiological, chemical, or biological warfare agent or high-level radioactive waste.”
(2) EPA has the authority under the CWA to regulate radioactive materials not
specifically addressed under the Atomic Energy Act. In particular, the CWA provided EPA
the authority to limit liquid discharges of TENORM into surface waters from mines or mills
used for the production of uranium, radium, and vanadium.
e. National Environmental Policy Act (NEPA) [42 USC 4321 et seq.]. NEPA was
enacted on 1 January 1970 to ensure that Federal agency decision-making takes
environmental factors into consideration. NEPA is generally only applicable to Federal
agencies and Federal actions unless a state, local, or private entity is involved with Federal
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funding or actions. Close coordination with the District Office of Counsel is essential when
determining whether NEPA is a requirement for the response action planned to address a
radioactively contaminated site. Unlike other environmental laws, NEPA is a procedural
requirement and does not contain specific enforcement provisions; EPA does not have
enforcement authority under NEPA. NEPA requires the preparation of Environmental
Assessments (EA) or Environmental Impact Statements (EIS), or both, for any project that
will have a major impact on the environment. This would potentially include
decommissioning activities under the jurisdiction of DOE, NRC, and DOD (e.g., Army
Reactor Program).
(1) Individual actions, such as decommissioning facilities, are to be evaluated to
determine the level of NEPA review needed. The NEPA process begins with a determination
of whether the “proposed action” is subject to NEPA compliance. If the determination is
made that the action cannot be categorically excluded from the EA, or EIS, the first step is to
prepare the EA. The EA helps to determine if an agency needs to prepare an EIS or if the
agency can make a finding of no significant impact (FONSI).
(2) It is important to note that on 23 January 1995, the Department of Justice (DOJ)
made a decision that a Federal agency is not required to independently implement NEPA at
CERCLA cleanup sites. The DOJ decision stated that the CERCLA process incorporates
many of the NEPA values of public participation and collection of environmental and human
health impacts that result from proposed Federal action. It is Army policy that response
actions implemented in accordance with CERCLA or RCRA are not legally subject to NEPA
and do not require separate NEPA analysis [32 CFR 651.5]. However, the CERCLA and
RCRA response actions should incorporate the procedural requirements of NEPA, which
include full and open public participation, analysis of all reasonable alternative remedies,
evaluation of the significant impacts of the studied alternatives, and consideration of public
comments when selecting the remedy.
f. Toxic Substances Control Act (TSCA) [15 USC 2601 et seq.].
(1) Contaminated sites that have polychlorinated biphenyls (PCBs) commingled with
radionuclides can create a situation of dual regulation. TSCA does not preempt other more
stringent Federal statutes and regulations (e.g., AEA), but it still needs to be considered.
EPA has established regulations for the cleanup of PCB contamination that must be
considered in conjunction with the applicable radioactive standards. Cleanup criteria for
PCB remediation waste are found in 40 CFR 761.61. The concentrations of PCBs must be
within a limited range and the appropriate controls must be in place to protect the public and
environment from exposure or release. However, a CERCLA response action must meet the
threshold criteria of being protective of human health and the environment and comply with
ARARs, and the radioactive waste may not be appropriate for on-site disposal. PCBs
commingled with radioactive material will typically require the off-site disposal at a facility
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that is licensed and permitted to accept the remediation waste. For example, EPA has
promulgated an exemption for low-level mixed waste for storage and treatment (40 CFR
266). The waste is not considered RCRA hazardous waste, if it meets the conditions of the
exemption. The low-level mixed waste must be disposed of into a licensed low-level
radioactive waste disposal facility, but it must meet the LDRs because it is being placed in a
land disposal facility.
(2) Mixed waste can further complicate the regulatory requirements for the disposal of
material having low concentrations of PCBs that may not even be regulated under TSCA.
PCBs are not a RCRA hazardous waste; however, mixed waste must meet the Land Disposal
Restrictions (LDRs) before it can be land disposed. For certain types of RCRA hazardous
wastes, there is a requirement to comply with the universal treatment standards for the
underlying hazardous constituents, which does include a treatment standard for PCBs. There
may be a RCRA treatment standard for PCBs, even though waste is not a RCRA hazardous
waste and complies with TSCA. EPA recognized the disparity between TSCA and RCRA
and has put into practice a temporary deferral for specific RCRA hazardous wastes (metals:
arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) that contain less
than 1000 ppm of PCBs. As this requirement is less stringent than previous promulgated
RCRA regulation, this must be adopted in the RCRA authorized states to be effective.
9-5. Summary of Radiation Standards. In the development of cleanup criteria, it is important
to understand the regulations that govern the response action. The regulatory authority must
be established to determine what the potential standard or numerical limit is for the media of
concern. Table 9-1 provides a summary of the regulations that might apply to an
environmental restoration, processing, or disposal operation.
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Table 9-1
Major Radiation Standards Summary Table
Regulation
Agency
Standard/Numerical Limit
General Public
(10 CFR 20.1301)
Uranium mill tailings
(40 CFR 192 & 10 CFR 40 App. A)
NRC
High-level waste operations
(10 CFR 60)
Low-level waste disposal
(10 CFR 61)
NRC
Total Effective Dose Equivalent
(TEDE):
100 mrem/year
Ra-226/228: 5 pCi/g (surface)
15 pCi/g(subsurface)
Rn-222
20 pCi/m2-sec
NRC standard includes benchmark dose
for other radionuclides
100 mrem/year
Effluent emissions 10 CFR 20
NRC
Drinking water (40 CFR 141)
EPA
Uranium fuel cycle (40 CFR 190)
Air emissions (National Emission
Standards for Hazardous Air
Pollutants) (40 CFR 61, H)
Superfund (CERCLA) cleanup
(40 CFR 300)
EPA
EPA
Decommissioning
(10 CFR 20, Subpart E)
NRC
Occupational standards
OSHA
29 CFR 1910.1096;
10 CFR 20;
NRC
DOE
10 CFR 835
OSHA,
NRC,
DOE
EPA &
NRC
NRC
Annual effective dose to public
25 mrem to the whole body
75 mrem to the thyroid, and
25 mrem to any other organ
Radionuclide specific activities, in
Appendix B => 50 mrem/year
Radium:
5 pCi/L
Gross Alpha 15 pCi/L (excludes Rn &
U)
Beta/photon: 4 mrem/year
Uranium:
30 µg/L
25/75/25 mrem/year
10 mrem/year to nearest off-site receptor
EPA
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Protective of human health &
environment,
Complies with ARARs
Unrestricted Use: 25 mrem/yr TEDE
plus ALARA
Restricted Use: Up to 100 mrem/yr or
500 mrem/yr if institutional controls
fail.
5,000 mrem/year & ALARA
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9-6. Miscellaneous Criteria.
a. Building Cleanup Criteria. The cleanup criteria for building surfaces and structural
materials that are contaminated with residual radioactivity is contingent on the regulatory
authority that governs the response action. Decommissioning and decontamination of NRC
licensed facilities is done in accordance with 10 CFR 20 Subpart E and the appropriate
regulation for the type of licensed activity (e.g., Part 30 - Byproduct material, Part 40 Source material, Part 70 - Special nuclear material). It is important to note that, under a
CERCLA response action, the decommissioning and decontamination standards may not be
applicable if the facility is not currently or never had an NRC license. However, the
standards may still be relevant and appropriate. CERCLA response actions (e.g., FUSRAP)
need to assess any actual or potential release or migration of contamination from the building
to the environment. When soil or groundwater, outside of or underneath the building
structure, become contaminated, cleanup criteria for these environmental media should also
be developed in accordance with the CERCLA process.
(1) The NRC has developed generic screening models for building release. This
guidance is being compiled and will be issued in one volume of NUREG-1757. When the
use of generic screening is appropriate, a computer code developed by NRC, known as
DandD, Version 1.0, may be used to generate concentration based cleanup levels for each
contaminant of concern. NRC also acknowledges that D and D may not be the only
appropriate computer model and has recognized that the RESRAD-BUILD, by Argonne
National Laboratory, may be a better model for certain applications. NRC does recommend
an uncertainty analysis be done if other models are used. The actual cleanup level derived
from dose modeling is not altered when an ALARA analysis is conducted. However, if a
remedial action required by the ALARA analysis is not performed, the final status survey
must demonstrate that the level of residual contamination is less than the cleanup level by the
percentage that would have been reduced if the action were taken. For example, it is almost
always ALARA to scrub and wash the walls and floor of a building to remove loose
radioactive contamination. If this action is taken, then the final status survey need only
document that the cleanup level was met.
(2) At inactive uranium or thorium milling sites, where 40 CFR 192 is an ARAR, and
where any occupied or habitable building is currently present, a reasonable attempt must be
made to control the annual average radon decay concentration (including background) to not
exceed 0.02 Working Level, and the gamma radiation shall not exceed the background by
more than 20 microroentgens per hour. It is important to fully characterize a building site to
ensure all the sources of radon (e.g., soil underneath floor) are understood. The decision
document should address the actions that will be taken if the cleanup criteria for the building
are not met after removal of the contaminated soil. Supplemental standards may need to be
considered if the contamination is under the floor of the building.
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b. Below Regulatory Concern (BRC). The NRC, in June 1990, attempted to establish
regulations and procedures by which small quantities of low-level radioactive materials could
be largely exempted from regulatory controls. The agency proposed that if radioactive
materials did not expose individuals to more than 1 millirem per year or a population group
to more than 1000 person-rem per year, they could be eligible for the exemption from fullscale regulation. It was intended that the BRC policy would apply to consumer products,
landfills, and other sources of very low levels of radiation. However, the public and
Congress objected to this proposed rulemaking and the NRC decided to defer any action on
the BRC issue. Currently, there is no regulatory level (dose or activity concentration) for
radionuclides that exempts them from regulatory control. There are promulgated NRC
regulations that allow certain exemptions from licensing for byproduct material (10 CFR
30.14) that doesn’t exceed the listed concentrations found in §30.70 - Schedule A. Source
material (uranium or thorium) also has exemptions from licensing for persons or activities
that are under the control of DOE or NRC contracts (§ 40.11); for material being transported
by a contract carrier (§40.12); for material that is considered an unimportant quantity of
source material (<0.05%) as described in §40.13; or by special request to the NRC (§40.14).
Special nuclear material (enriched uranium, plutonium) are exempt from licensing if the
material is under the control of the DOE or is under the control of DOD in accordance with
Section 91 of the AEA for national defense (§70.14).
c. State Regulations for the Control of NORM. The status of state regulations for the
control of NORM/TENORM contamination, as of 2000, can be summarized as follows
(Reference: The NORM Report, Volume II, Number 2):
States with NORM regulations
States with radiation regulations that
regulators believe address NORM
States with no NORM regulations
Arkansas, Georgia, Louisiana,
Mississippi, New Mexico, Ohio, Oregon,
South Carolina, Texas, Washington,
Arizona, Delaware, Idaho, Kansas, Maine,
Maryland, Massachusetts, Michigan,
Minnesota, Nebraska, New Hampshire,
New Jersey, New York, Pennsylvania,
Tennessee, Utah, Virginia, Wisconsin
Alabama, Alaska, California, Colorado,
Connecticut, Florida, Hawaii, Illinois*,
Indiana, Iowa, Kentucky, Missouri,
Montana, Nevada, North Carolina, North
Dakota, Oklahoma, Rhode Island, South
Dakota, Vermont, West Virginia,
Wyoming
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CHAPTER 10
Remedies and Innovative Technologies
10-1. Introduction. This chapter addresses remedies and innovative technologies that may
be used at radioactive remediation sites. There are only a few remedies available at sites
contaminated with radioactive materials: attenuation through decay, decontamination of
soils, buildings, and equipment, and disposal of the contaminant, or disposal of the
contaminated soils, buildings or equipment. There are a number of potential disposal sites
addressed in Chapter 12. In this chapter we will limit our discussion to disposal on-site and
disposal off-site.
10-2. Attenuation through Decay. This can only prove feasible when the half-lives of all the
radioactive contaminants are short enough for the attenuation to occur within a specified
time. For example, if a site is contaminated with I-125, which has a 60-day half-life,
attenuation could be considered as a means of accomplishing remediation. Within 2 years,
99.9% of the I-125 will have decayed away. However, attenuation would not be feasible at a
site contaminated with uranium, which has a 4 billion year half-life.
10-3. Decontamination. This is the process of removing some or all of a radioactive
contaminant from an object. For a procedure to be feasible, it must be able to remove
enough of the radioactive material so that the object can pass a final status survey.
Decontamination has been attempted on soils using soil-washing techniques. Results have
been mixed because of varying soil parameters that may bind the contaminants to the soil, or
make the soil handling difficult.
10-4. Soil Volume Reduction. This has been attempted using a number of processes.
Segmented gate systems operate using an array of detectors positioned over a conveyor belt.
The soils are loaded onto the conveyor belt in a thin layer, and passed under the detectors.
When a detector senses some radioactive material in the soil, that particular portion of soil is
diverted out of the waste stream into a contaminated material pile. The rest of the soil goes
on to the ‘clean’ pile. A USACE pilot study results can be found at
http://www.fusrapmaywood.com/Docs/MISS-106.pdf.
10-5. Soil Washing. The soil-washing process is a treatment method where dispersed, lowlevel radioactive contaminated particles are washed from the soil fraction. Low to
intermediate levels of contamination are removed from the soil. The process can reduce the
volume of a contaminated soil that would otherwise require special handling and packaging
for off-site disposal by 98%. Soil can be washed in situ or ex situ and is done using a dilute
solvent that is selective for the contaminants to be treated. Soil washing may be effective
when there is an inverse relationship between particle size and contaminant concentration.
Soil washing is effective for the remediation of soils with a high content of material with
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large particle sizes (more than 90% sand and gravel). After size separation, a large portion of
the radioactive material may be concentrated in the fine material, leaving a minor portion in
the coarse material. The coarse material may then contain low enough amounts of
radioactive material for replacement on-site. Soil washing has been successfully
demonstrated (pilot scale) on soils contaminated with strontium, cesium, technetium, radium,
uranium, thorium, barium, and lead. Soil washing can also be used for mixed wastes
contaminated with organics or heavy metals. One problem with soil washing has been
stakeholder acceptance of using the washed soil as fill at the site. Some pilot studies for
chemical extraction methods can be found at:
http://www.frtr.gov/matrix2/section3/table3_8.html.
10-6. In-situ Phytoremediation. This is a method of using plants to bioaccumulate
contaminants. It has been able to remove approximately 95% of the cesium and strontium
contamination from a pond near Chernobyl, where sunflowers were grown hydroponically,
and to remove uranium from water. Indian mustard and poplar trees have also been used.
The plants take up certain contaminants and store them within their biomass. Most
accumulation is in the root system, which may make it less amenable to soil remediation.
Similarly, DOE research has shown promise in using bioaccumulation of uranium from soil
matrices by certain bacteria.
10-7. Ex-situ Soil Treatment. The ex-situ soil treatment process combines dissolution with
dilute selective solvents, contaminant recovery, and solvent regeneration to provide a
continuous recirculating treatment process. The solvent chemistry combines well-established
carbonate recovery chemistry with a chelant and an oxidant. Countercurrent extraction is
used to dissolve and recover the contaminant in the ex-situ treatment process. The number of
extraction stages and the contact time in the extractors are determined based on the
contamination level in the soil, the physical and chemical characteristics of the soil, and the
level to which the soil must be treated. Removal factors (the ratio of the contaminant level in
the feed material divided by the contaminant level in the treated material) of 10 to 20 are
typically achievable.
10-8. Equipment and Debris. Waste may be compacted to reduce its volume. First, one
should determine whether compaction is beneficial to the treatment and disposal scheme of
each waste. Compaction may be an appropriate technology to reduce disposal costs if the
disposal facility charges on a volume basis. If debris will be sent off-site for disposal, it is
important to determine if the disposal facility has any dimensional limitations on debris.
Land disposal facilities sometimes limit dimensions to ensure proper compaction during
placement in the disposal cell.
10-9. Cutting and Sawing. These operations may be appropriate on large metal or plastic
items. This type of waste typically has to be reduced to make it fit into packaging containers
or to prepare it for further treatment, such as incineration. The cutting may be carried out
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either in the dry state in cells, and with conventional tools, or underwater. The cutting may
also be done with plasma-jets, laser torches, or explosive fuses. Crushing techniques may be
used for size reduction of friable solids (e.g., glass, concrete, and ceramics). Crushing
increases the apparent density of the waste. In principle, all types of mill, grinder, and
crushing machines of conventional technology can be used. Shredding reduces void space
and is particularly effective when plastics are compacted. Air, trapped between the folds of
bulk plastic and in plastic bags, takes up container and disposal space.
10-10. Incineration. Incineration as a hazardous waste treatment technology is discussed in
EM 1110-1-502. Major considerations in using incinerator technology for radioactive waste
treatment involve shielding requirements, use of HEPA filters, and methods of ash disposal.
Incineration is primarily a volume reduction technique. It has a secondary benefit of
destroying hazardous organic chemicals often present in mixed waste. In all instances,
incineration will create a final product, which is ash, with a higher radionuclide
concentration. This ash may require treatment before disposal.
10-11. Building Demolition.
a. Demolition is the total destruction of a building, structure, or piece of equipment.
Demolition usually occurs in conjunction with dismantling. Specific demolition techniques
include complete burn-down, controlled blasting, wrecking with balls or backhoe-mounted
rams, rock splitting, awing, drilling, and crushing. The debris may be treated (possibly by
incineration) and is then disposed of. The building is usually pretreated for the majority of
the radioactive material before demolition, and some structures within the building may have
to be dismantled and removed before demolition.
b. Hazardous substances, such as PCBs and asbestos, may also be present in the
building and typically warrant prior remediation or removal so as to avoid generating large
quantities of commingled waste (TSCA or NESHAP regulated) during the building
demolition. Contaminated structures and equipment can be physically separated from the
environment by a barrier. These barriers may be plaster, epoxy resins, or concrete. Control
effectiveness depends primarily on the correct choice of encapsulant.
10-12. Hydroblasting. This technique uses a high-pressure (3500- to 350,000-kPa), low
volume water jet to remove contaminated debris from surfaces. The debris and water are
collected, and the water is decontaminated. Hydroblasting may not effectively remove
contaminants that have penetrated the surface layer. On the average, this technique removes
0.5 to 1.0 centimeters of concrete surface at the rate of 35 m2/hr. The method can be used on
contaminated concrete, brick, metal, and other materials. Hydroblasting can easily
incorporate variations such as hot or cold water, abrasives, solvents, surfactants, and varied
pressures.
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10-13. Paint Removal. This might be needed in a building found to contain radioactive
contamination on the wall surface or trapped between layers of paint. A combination of
commercial paint removers, hand scraping, water washing, and detergent scrubbing may be
necessary to remove the paint and radioactive contamination. Fixative/stabilizer coatings can
be used on contaminated residues to fix or stabilize the contaminant in place and decrease or
eliminate exposure hazards. These agents include molten and solid waxes, carbowaxes,
organic dyes, epoxy paint films, gels, foams, and polyester resins. To create strippable
coatings, compounds that bind with contaminants are mixed with a polymer, applied to a
contaminated surface, and removed to achieve decontamination.
10-14. Scarification. This is capable of removing up to 2.5 centimeters of surface layer from
concrete (not block) and cement. The scarifier tool consists of pneumatically operated piston
heads that strike the surface, causing concrete to chip off. The piston heads consist of
multipoint tungsten carbide bits. An almost identical or similar process to scarifying is
scabbling, in which a super-high-pressure water system can be used. This water system is
more easily operated remotely. Wall, floor, and hand-held scarifiers are available.
10-15. Steam. Steam cleaning physically extracts contaminants from building materials and
equipment surfaces. Currently, steam cleaning is used mainly to remove contaminated
particulate. This technique is known to be effective only for surface decontamination. Steam
cleaning requires steam generators, spray systems, collection sumps, and waste treatment
systems. Commercial-scale steam cleaners are available from many manufacturers. Several
manufacturers make portable steam cleaning equipment.
10-16. Drilling and Spalling. This operation consists of drilling holes 2.5 to 4 centimeters in
diameter and 7.5 centimeters deep into concrete. The spalling tool bit is inserted into the
hole and hydraulically spreads to spall off the contaminated concrete. This technique can
remove up to 5 centimeters of surface from concrete or similar materials. Vacuum filter
systems and water sprayers can be used to control dust during drilling and spalling
operations. Remotely operated drill and span rigs are available.
10-17. Disposal. Disposal may be accomplished through a number of methods. Burial and
capping on-site, disposal at waste disposal facilities, and allowed effluent releases are the
most common methods of disposal. AR 11-9 prohibits on-site burial at DA facilities, and onsite burial rarely will be allowed without site restrictions or institutional controls of some
type.
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CHAPTER 11
Transportation
11-1. Introduction. Transportation of hazardous materials is regulated by the US
Department of Transportation (DOT). The regulations applicable to transportation of Class 7
(radioactive) materials can be found in Subpart I of 49 CFR 173. Under the AEA of 1954,
the NRC has responsibility for safety in the possession, use, and transfer (including transport)
of byproduct, source, and special nuclear material. Because of this overlap in statutory
authorities of NRC and DOT, the two Federal agencies signed a MOU in 1979 with regard to
regulation of the transport of radioactive material (44 FR 38690). DOT (in consultation with
the NRC) is responsible for developing safety standards for the classification of radioactive
materials; for design specifications and performance requirements of packages for quantities
of radioactive materials (other than fissile) not exceeding Type A limits and for low specific
activity materials; and for other transportation requirements. The NRC is responsible for
greater than Type A quantities of radioactive materials and fissile materials. DOT acts as the
US representative to the IAEA (International Atomic Energy Agency) and other internal
governmental matters and the NRC provides DOT technical support and advice.
a. The NRC has promulgated in 10 CFR 71 requirements that must be met by licensees
for packaging used to deliver certain types of licensed material to a carrier for transport if
fissile material or quantities exceeding Type A quantities are involved. NRC also assists and
advises DOT in establishing both national and international safety standards and in reviewing
and evaluating packaging designs. Persons offering radioactive materials for transportation
are responsible for ensuring that the package is in good physical condition and meets DOT
specifications, the package is appropriate to the contents, all closures are in working order,
all radiation and contamination levels are checked, and all labeling, marking, manifesting,
and placarding requirements are met.
b. Only personnel trained in transporting hazardous materials will prepare, package
mark, label, manifest, or offer for shipment any radioactive materials for USACE. Only
USACE members formally designated and authorized by a MSC or District Commander or
Deputy Commander shall be allowed to execute hazardous waste manifests and related
documents for a site. The authorization letter should recognize that the individual is within
his or her scope of employment when executing manifests and related documents. To
document appropriate training and the scope of an individual’s signature authority, a
nomination and authorization procedure must be put into practice. All persons nominated to
be manifest certifying officials must have completed the required training and obtained
certification. The nomination package should contain a one-page summary of the person’s
training and experience in HTRW and manifesting. The nomination package should also
have the authorization letter (to be coordinated with the local counsel) ready for signature.
The authorization letter must clearly state that the execution of manifests and related
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documents are within the scope of the individual’s official duties. (See EP 415-1-266,
Resident Engineer Management Guide for HTRW Projects.)
c. It is USACE policy, if requested by its customers, to execute hazardous waste
manifests and related documents on behalf of those customers when it is not precluded by
state statutes or regulations. Currently, USACE is signing manifest forms and related
documents on behalf of EPA, FEMA, and FSA. USACE personnel executing hazardous
waste manifests and related documents must ensure that the USACE is authorized by its
customers to execute hazardous waste manifests and related documents on their behalf prior
to such documents being executed.
11-2. Determining if Packages are Radioactive for Shipping.
a. Currently, a material is considered Class 7 (radioactive) for shipping purposes if the
material contents of the package have a specific activity greater than 70 becquerel per gram
(Bq/g, which is approximately 2000 pCi/g). If more than one radionuclide is present in the
package, such as when shipping radionuclides that decay to radioactive daughters, the sum of
all the specific activities must not exceed 70 Bq/g.
b. On 26 January 2003, DOT published a final rule that will change the regulatory
definition of Class 7 (radioactive) material by harmonizing the regulations with international
standards. Under the system that will become effective 1 October 2004, the exempt material
activity concentrations vary depending on the individual radionuclide. The exempt
concentrations are published in 40 CFR 173.436. There is also an activity limit for an
exempt consignment of material that, if exceeded, would require the consignment to be
shipped as Class 7 even though each individual package may be exempt.
c. Materials, soils, and debris containing radioactive materials greater than natural
background but exempt from DOT requirements, will be shipped and handled in such a way
as to be protective of worker health and safety, the public, and the environment. Most truck
and rail transporters require that these materials be packaged. Bulk shipments may use liners
(i.e. ‘burrito bags’) inside rail gondolas, or intermodal containers. Smaller shipments may be
made in strong, tight containers.
d. DOT radioactive materials are also classified by their containment, quantity, and
exceptions.
(1) Containment. Radioactive materials may be considered as normal form or special
form. Special form materials are those defined in accordance with DOT regulations (49 CFR
173.403). Special form materials must be a single, solid piece or be contained in a sealed
capsule with one dimension greater than 5 millimeters and must pass tests to demonstrate its
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resistance to breach or destruction. All other radioactive materials are considered normal
form. Most USACE radioactive wastes are normal form.
(2) Quantity. The A2 quantity (normal form) is the maximum activity of normal form
material allowed in one Type A package. An A1 quantity (special form) is the activity that
will produce an external radiation level of 1 R/hr at 3 meters, up to a maximum of 1080
curies, and it is the maximum activity of special form material allowed in a Type A package.
There are some radioisotopes currently assigned an unlimited A2 value. This value is used in
determining other quantity limits. The recently amended regulations also revised the A
values for many radionuclide, therefore each on-going transportation program should assess
the impact of the changes prior to 1 October 2004. A Type B quantity is one that exceeds the
Type A quantity. A highway-route-controlled quantity means a quantity within a single
package that exceeds:
• 3000 times the A1 or A2 quantity
• Any quantity exceeding 1000 TBq (27,000 Ci), whichever is the least
(3) Exceptions. Radioactive materials that qualify as exceptions may be shipped using
less stringent requirements for packaging, marking, labeling, and manifesting. These
exceptions are spelled out in 49 CFR 173.421 through 427: limited quantities of class 7
materials, instruments and articles, manufactured articles containing natural uranium or
thorium, low specific activity Class 7 materials, and objects with contaminated surfaces.
(a) A Limited Quantity is not greater than one one-thousandth of the Type A quantity
for solids, or not greater than one ten-thousandth of a Type A quantity for liquids.
(b) Instruments and articles are manufactured items containing radioactive material
that would require destruction of the item to remove the material. The activity cannot exceed
one one-hundredth of the type A quantity for solid material, one one-thousandth of a Type A
quantity for gases, or one ten-thousandth of a Type A quantity for liquids. The radiation
level at any point on the external surface of the package shall not exceed 0.005 mSv/hr (0.5
mrem/hr).
(c) Low Specific Activity material are uranium or thorium ores and their physical and
chemical concentrates, or un-irradiated natural or depleted uranium or thorium, or mill
tailings, contaminated earth, concrete, rubble, or other debris in which the Class 7 material is
uniformly distributed and the average specific activity meets specified concentration limits
determined by their A2 values.
(d) Depending upon their total activity, some remediation wastes may not meet the
definition of a Class 7 (radioactive) material but they are DOT hazardous material because
they contain a reportable quantity (RQ) of a hazardous substance in a single package or bulk
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container under 49 CFR 172.101 Appendix A Table 2. Should any of these radioactive
materials contain a hazardous substance, they may be subject to additional regulations on
transport, depending on the hazardous substance involved.
11-3. Packaging. Radioactive soils and debris from site remediation that are DOT regulated
normally contain low specific activities of radioactive contaminants and have a low external
dose rate. These packages may be shipped under 49 CFR 173.427 Transportation
Requirements For Low Specific Activity (LSA) Class 7 (radioactive) Materials and Surface
Contaminated Objects (SCO). LSA materials have several options for packaging but,
typically, strong, tight containers will suffice for domestic shipments of most soils and
debris. These packages must meet the DOT requirements for LSA and must be shipped as
exclusive use.
a. Small quantities, such as field samples may be shipped under 49 CFR 173.421
Excepted Packages, Limited Quantity of Class 7 Materials. Small quantities of higher
activities may be shipped in Type A containers. Radioactive materials with high activities
may require Type B packaging. Each successively greater packaging has additional
requirements and is proportionately more expensive A trained and certified hazardous
materials shipper must be consulted for packaging and shipping radioactive materials or
waste.
b. The outside of each container must meet DOT’s specified contamination control
limits. This is usually accomplished through smear or wipe testing the outside of the
package, and assaying the smear to assure there is no removable contamination from the
package.
11-4. Marking. Non-bulk packages will be marked with the proper shipping name, the UN
identification number, and the consigner or consignee’s name and address. The gross weight,
RQ, package type and weight, and orientation markings, if applicable, will also be included
on the package. Bulk packages must be marked with the UN identification number, and
conditions may require that it be displayed on an orange panel or white square-on-point if
certain conditions exist. Markings must be in English, meet specified size requirements,
must be durably marked with a contrasting color background, and be isolated on the package
and un-obscured.
11-5. Labeling.
a. Radioactive packages will be labeled with a White I, Yellow II or Yellow III
radioactive label unless excepted by DOT from labeling. The label will include the
Transport Index, the radionuclides in the shipment, and their activities. A subsidiary hazard
labels may be necessary if required by regulation. The labels will be placed on opposite
sides of the package. Empty packages may be shipped but must include the Empty label.
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b. All packages of radioactive waste will also be labeled with a non-DOT USACE
marking sticker adjacent to the specified DOT labels and placards to ensure the materials are
properly disposed. Containers (bulk and non-bulk) of wastes or materials that are not DOT,
EPA, or NRC regulated, but are being sent off-site for disposal shall also have the marking
sticker even though there are no specification markings, labels or placards required.
11-6. Manifesting. If the material to be disposed of is NRC licensed material, an NRC
Uniform Low-Level Radioactive Waste Manifest (forms 540 and 541) must be used. This
manifest will fulfill the DOT shipping paper requirements as well as the NRC requirements.
If the material to be disposed of is a hazardous waste, a state or uniform EPA Hazardous
Waste Manifest must be used. If the material is a RCRA regulated waste and is also NRC
regulated, the NRC manifest must accompany the EPA manifest. If the material is not a
hazardous waste or NRC licensed, but is still regulated by DOT (e.g., RQ of radionuclides)
then a DOT straight bill of lading may be used.
a. The manifest or shipping papers will be filled out completely. If the material is a
hazardous waste, the appropriate hazardous waste manifest (see 40 CFR 262.21 for
hierarchy) and land disposal notifications will be completed. The manifest must include the
name, address, and phone numbers for the consignor and the consignee. DOT regulations
require hazardous materials be listed first on the shipping paper or marked with a contrasting
color or marked with an “X” in the hazardous materials column.
b. The proper shipping name, UN number, and hazard class will be filled out for each
material. The physical and chemical form, the activity, the TI and Labeling applied to the
package will be listed, and Highway Route Controlled Quantity (HRCQ) or RQ, if
applicable, will be included in the description.
c. A 24-hour emergency telephone number must be listed on the manifest when
transporting DOT hazardous materials. The emergency phone must be monitored at all times
the hazardous material is in transportation (including storage incidental to transportation) by
personnel knowledgeable of the shipment, its hazards, and proper emergency response and
incident mitigation information in case of accident (49 CFR 172.604). Pagers and call backs
are unacceptable to meet this requirement.
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11-7. Placarding. Exclusive use shipments of LSA or SCO and packages labeled with
Radioactive Yellow III labels will require vehicle placarding. The consignor is responsible
for providing the shipper with the appropriate placards. Most commercial shippers will have
their own placards available but the shipper should have the necessary placards on hand.
HRCQ shipments of radioactive materials must have a radioactive placard placed on a square
white background in accordance with DOT regulations.
11-8. Mixed or Co-Mingled Waste.
a. Except for Class 7 limited quantity packages, as defined in 49 CFR 173.421,
radioactive materials that also meet the classification of more than one hazard class will be
classified primarily as Class 7. Limited quantity packages will be classed as the additional
hazard and prepared for transportation according to the other hazard class.
b. Mixed waste may have subsidiary hazard labeling, requirements under 49 CFR
172.402. Excepted packages under 49 CFR 173.421, 424 or 426 do not need to have a
subsidiary “Radioactive” label.
11-9. DOT Required Security Plans. Security of hazardous materials in the transportation
environment poses unique challenges. To address this DOT requires shippers and carriers to
have security plans in place and provide training for personnel involved in shipments of
certain hazardous materials. Radioactive materials and radioactive waste shipments of a
HRCQ, a shipment that requires a placard, or shipments of hazardous materials in bulk or
non-bulk packaging when specified limits (e.g., 468 cubic feet for solids for bulk, 5000
pounds gross weight or more of one hazard class in non-bulk packaging) are exceeded will
require a security plan. Most exclusive use shipments of radioactive materials will require
placards, and so will require a security plan. These new DOT security requirements are
imposed industry-wide on transporters. USACE contracts require the contractor to provide
site security, and contractors and transport companies are required to follow applicable
Federal regulations. USACE duties for compliance with the DOT security plan requirements
include the following:
• Ensuring that the contractor and transporter know that under their contracts they
must comply with all Federal laws, including this new DOT requirement.
• Ensuring that the contractor is aware of the security clauses in his or her basic
contract that requires they provide site security.
• Determine whether USACE needs to prepare a security plan to address the security
of the hazmat during pre-transportation phases when the hazmat is on-site.
To demonstrate compliance with these regulations, the following procedure will be followed
for all USACE shipments of DOT regulated hazmat by contractors when security plans are
required by 49 CFR 172, Subpart I. Guidance on the new DOT security planning and
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training requirements for hazardous material shipments is forthcoming from HQ USACE in
an Engineering Technical Letter. A fact sheet has been prepared by the HTRW-CX, which
addresses the new DOT security requirements.
a. The contract will clearly require full compliance with DOT regulations, 49 CFR,
Subchapter C.
b. The contract will clearly indicate, through the appropriate Federal Acquisition
Regulations clauses, that the prime contractor is responsible for on-site security.
c. With each shipment of hazmat required to have a security plan, the USACE
representative, responsible for signing the shipping documents, will require the initial
transporter to sign a certification statement. Subsequent shipments of the same hazard class
of materials transported by the same transporter need not provide additional certifications.
d. The certification will be typed on a separate page and read as follows:
I hereby certify that (name of transportation company) has a Security Plan in place
which meets the requirements of 49 CFR 172 Subpart I for the hazardous materials
described in the attached shipping papers.
This certification will be signed by the initial transporter and dated.
e. The certification will be placed in the project files with the shipping documents, and
retained for at least the period required for the shipping papers.
f. It is not USACE responsibility to review, accept, approve or even have copies of
shipper’s and transporters security plans.
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CHAPTER 12
Disposal
12-1. Introduction. USACE policy is that USACE will dispose of radioactively
contaminated materials only at facilities licensed by the Nuclear Regulatory Commission
(NRC) or an Agreement State, or at facilities permitted by a Federal or state regulator to
accept radioactive materials in accordance with their facility permit and all applicable laws
and regulations. Materials will be disposed of in a cost-effective manner, considering all
feasible options that achieve protectiveness and compliance with all applicable Federal and
state laws. To assure that this policy is implemented, the project manager will document a
disposal strategy containing the following elements in the Project Management Plan for each
project.
12-2. Characterization of Materials. USACE will characterize materials to determine the
laws and regulations that apply to off-site disposal of specific materials at each site. The use
of appropriate analytical testing to determine physical and chemical characteristics and a
determination of historical factors (generator knowledge) about the materials processed on
the site are necessary to properly characterize the materials as to category of radioactivity and
RCRA hazardous waste codes (if relevant), and determine who has regulatory authority.
More than one type of material may be identified for a particular site. Characterization will
be conducted in consultation with the appropriate technical and legal specialists. The
characterization process will be coordinated with the Hazardous, Toxic, and Radioactive
Waste Center of Expertise and the conclusion will be documented, and retained in the project
file.
12-3. Identify and Coordinate with Potential Disposal Facilities. Based on the
characterization of materials, USACE will identify potential disposal facilities and will
assure that such interested off-site disposal facilities are provided accurate characterization
information concerning material intended for off-site disposal.
12-4. Compare Transportation and Disposal Costs of Viable Facilities. USACE will
determine the most cost-effective option for disposal of material. Packaging, transportation
(including potential demurrage costs), and disposal fees will be included in the cost
effectiveness analysis.
12-5. The Off-site Rule. Only facilities meeting the NCP Off-site Rule’s (40 CFR 300.440)
acceptability criteria will be used for disposal of materials that are CERCLA waste, including
radionuclides. Under this rule, USACE will notify the EPA Regional Off-site Coordinator
(ROC), in the region where the selected facility is located, of the intent to send CERCLA
waste to that facility. USACE will transport CERCLA waste off-site only when the ROC has
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made a finding and notified USACE that the receiving facility meets the compliance and
release criteria in 40 CFR §300.440 (b) and is therefore acceptable under the Off-site Rule.
a. In the event of an emergency posing an immediate and significant threat to human
health or the environment, shipment may commence prior to the ROC’s determination. The
project manager may consider temporary measures, such as interim storage, to allow time to
locate an acceptable facility. The ROC must be notified and the response received prior to
final disposal of the CERCLA waste.
b. If shipments are not initiated within 60 days of the ROC’s determination of the
facility’s acceptability status, then USACE will recheck the status with the ROC. In the
event that the facility’s status under the Off-site Rule changes to unacceptable, and EPA
notifies the facility and the project manager, material will cease to be sent to that facility until
the status of the facility is officially changed to acceptable by EPA under the Off-site Rule.
c. The ROC determination does not supersede the facility regulator’s authority to
determine the acceptability of a material under the facility’s license or permit; however,
waste may not be shipped and disposed of at the facility without the EPA finding of
acceptability under the Off-site Rule.
12-6. Facility Regulators. USACE is responsible for ensuring that all appropriate contacts
(NRC, EPA, or state) are made with regulators before shipment of materials off-site for
disposal. Open and early communication with regulators is necessary for the successful
execution of this policy.
a. A written description of the materials to be disposed of will be provided to the
selected facility. The facility will seek to obtain written authorization from the appropriate
regulators, indicating that the proposed disposal is consistent with applicable regulations and
the permit or license of the disposal or treatment facility. USACE will ensure that:
(1) The nature of the material to be disposed of has been accurately represented.
(2) Acceptance is unqualified.
(3) The regulator indicates the proposed action would not violate applicable laws and
regulations or the facility permit or license.
b. There may be low-level radioactive waste (LLRW), as defined by the LLRW Policy
Amendments Act (reference 4.f.), on some sites. Disposal of such material may be affected
by regulations governing the regional LLRW compacts. The Atlantic, Rocky Mountain*, and
*
Rocky Mountain compact contracts with the Northwest compact for use of the Northwest disposal facility at Hanford in Washington state
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North West compacts have Low Level Radioactive Waste Disposal facilities that must be
used for disposal of waste generated within their compact. Some compacts allow for export
of waste but will charge an export fee. Since these vary among compacts, plans for disposal
of LLRW must be coordinated with District Office of Counsel to ensure compliance with all
applicable regulations.
c. All contacts will be documented and all records retained in the project file, as well
as copies of all written agreements and approvals.
d. The State of Utah has enacted a requirement for a generator’s site access permit to
allow generators to dispose of radioactive waste at sites within their state. Office of counsel
for USACE contends that application of this permit and the accompanying fees to the Federal
government is not permissible. The State of Utah has agreed that the fee does not apply to
the Federal government when disposing of AEA regulated material. However, the State of
Utah has not concurred with the USACE position pertaining to the disposal of non-AEA
regulated materials (e.g., NORM, radioactive residuals from ore processing prior to
UMTRCA). USACE has agreed not to ship these materials to Utah without a permit or a
resolution of the disagreement.
12-7. Transportation Requirements. Shipments of FUSRAP materials will comply with all
applicable NRC and Department of Transportation requirements. Materials that are an
RCRA hazardous waste must also comply with applicable EPA and state manifest and
transportation requirements. See LLRW Policy Amendments Act (references 4.h. and 4.i.)
for a discussion of these requirements. USACE will also follow the additional items below.
a. USACE personnel are responsible for signing shipping papers in accordance with
LLRW Policy Amendments Act (reference 4.i.).
b. A secondary non-DOT marking sticker will be added to all bulk containers of
material. The intent of this sticker is to ensure that all materials, no matter their hazardous
characteristics, are appropriately disposed of.
c. A Certificate of Disposal or Placement is required for all off-site disposal of
materials. This certificate will provide a complete record of the final disposition of the
material. The certificate should identify the individual quantities of material received at the
disposal facility and the location where the material is finally placed after disposal.
d. A Chain-of-Custody form will be required for the off-site disposal of all material,
including material that is not regulated by DOT, EPA, or NRC.
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12-8. Disposal Contracts. Kansas City District has a number of contracts in place for
disposal of radioactive materials. These contracts are available for use to all DOD
components and Federal agencies. These contracts offer very competitive disposal rates at a
variety of sites, depending on the nature of the waste materials.
12-9. Disposal Options Available as of January 2003.
a. Chem-Nuclear Systems, L.L.C., Barnwell, South Carolina. This is the Atlantic
Compact disposal site. It may accept waste from outside the Atlantic Compact. Acceptable
waste includes LLRW Class A, B, and C, NORM and NARM. Will accept biological waste.
No liquid waste accepted. Waste must be packaged. Requires annual allotment of space for
Out of Compact users with large volumes. Costs range from $4.50 to $8.04 per pound,
depending on density, plus $0.38 per millicurie, plus $1.00 to $1.50 per mR/hr, depending on
exposure rate, plus $4.00 per cubic foot Compact Commission surcharge.
b. US Ecology, Hanford Reservation, Washington. This is the Northwest and Rocky
Mountain Compacts disposal site. It accepts LLRW, Class A, B, and C, from within
Compacts. NORM and NARM may be accepted from outside the compact. Will accept
biological waste. No liquid waste accepted. Waste must be packaged.
c. Envirocare, Inc., Clive, Utah. Accepts LLRW Class A, NORM and NARM, 11e(2),
and Mixed Waste. Offers treatment services.
d. Waste Control Specialists, Andrews County, Texas. Provides Interim Storage for
LLRW Class A, B, C, and greater than Class C wastes. May dispose of non-NRC regulated
radioactive waste.
e. American Ecology, Grandview, Idaho. May dispose of non-NRC regulated
radioactive waste with activities less than 2000 pCi/g total activity.
f . American Ecology, Robstown, Texas. May dispose of non-NRC regulated
radioactive waste with activities less than 2000 pCi/g total activity.
g. International Uranium Corp., Utah. May accept uranium for recycling as source
material.
12-10. USACE and DA Coordination. The Department of Defense (DOD) has designated
the US Army as the Executive Agent for disposal of DOD radioactive waste. The
operational working of this has been delegated by the DOD Executive Agent to the Army
Field Support Command (AFSC), Radioactive Waste Disposal Division. All DOD-generated
radioactive waste must be disposed of in coordination with AFSC. Since USACE disposes
of waste from a large number of generators, all waste disposed of by USACE must be
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coordinated with the HTRW CX. The HTRW CX will determine which disposal actions
must be coordinated with AFSC and will provide case-by-case guidance and assistance on
accomplishing this.
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CHAPTER 13
Multi-Agency Radiation Site Survey and Investigation Manual (MARSSIM)
13-1. Introduction. The Multi-Agency Radiation Survey and Site Investigation Manual
(MARSSIM) provides detailed guidance for planning, implementing, and evaluating
environmental and facility radiological surveys conducted to demonstrate compliance with a
dose- or risk-based regulation. The MARSSIM guidance focuses on the demonstration of
compliance during the final status survey following scoping, characterization, and any
necessary remedial actions.
13-2. Data Life Cycle. The process of planning the survey, implementing the survey plan,
and assessing the survey results prior to making a decision is called the Data Life Cycle.
MARSSIM provides detailed guidance on developing appropriate survey designs using the
Data Quality Objectives (DQO) Process to ensure that the survey results are of sufficient
quality and quantity to support the final decision. The survey design process is described,
and guidance on selecting appropriate measurement methods (i.e., scan surveys, direct
measurements, samples) and measurement systems (i.e., detectors, instruments, analytical
methods) is provided. Data Quality Assessment (DQA) is the process of assessing the survey
results, determining that the quality of the data satisfies the objectives of the survey, and
interpreting the survey results as they apply to the decision being made. Quality Assurance
and Quality Control (QA/QC) procedures are developed and recorded in survey planning
documents, such as a Quality Assurance Project Plan (QAPP). MARSSIM does not provide
guidance for translating the release criterion into derived concentration guideline levels
(DCGLs). DCGLs must be coordinated with the stakeholders. DCGLs must include a
DCGLW, the average concentration of radionuclides in an area, the area over which the
DCGLW may be averaged, and a DCGLEMC, the maximum concentration acceptable in a
small localized area.
a. MARSSIM discusses contamination of surface soil and building surfaces in detail.
If other media (e.g., ground water, surface water, subsurface soil, equipment, vicinity
properties) are potentially contaminated at the time of the final status survey, modifications
to the MARSSIM survey design guidance and examples may be required. Figure 13-1
provides a diagram of the data life cycle within the MARSSIM process. Figure 13-2
provides a flow diagram for final status survey design.
b. MARSSIM defines the limits of a site, then classifies areas of the site as impacted or
non-impacted. Areas that have no reasonable potential for residual contamination are
classified as non-impacted. Areas with some potential for residual contamination are
classified as impacted. Impacted areas are further divided into one of three classifications:
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(1) Class 1 Areas. These are areas that have, or had prior to remediation, a potential
for radioactive contamination (based on site operating history) or known contamination
(based on previous radiation surveys) above the DCGLW. Examples of Class 1 areas include:
1) site areas previously subjected to remedial actions, 2) locations where leaks or spills are
known to have occurred, 3) former burial or disposal sites, 4) waste storage sites, and 5)
areas with contaminants in discrete solid pieces of material and high specific activity.
(2) Class 2 Areas. These are areas that have, or had prior to remediation, a potential
for radioactive contamination or known contamination, but are not expected to exceed the
DCGLW. To justify changing the classification from Class 1 to Class 2, there should be
measurement data that provide a high degree of confidence that no individual measurement
would exceed the DCGLW. Other justifications for reclassifying an area as Class 2 may be
appropriate, based on site-specific considerations. Examples of areas that might be classified
as Class 2 for the final status survey include: 1) locations where radioactive materials were
present in an unsealed form, 2) potentially contaminated transport routes, 3) areas downwind
from stack release points, 4) upper walls and ceilings of buildings or rooms subjected to
airborne radioactivity, 5) areas handling low concentrations of radioactive materials, and 6)
areas on the perimeter of former contamination control areas.
(3) Class 3 Areas. These are areas any impacted areas that are not expected to contain
any residual radioactivity, or are expected to contain levels of residual radioactivity at a small
fraction of the DCGLW, based on site operating history and previous radiation surveys.
Examples of areas that might be classified as Class 3 include buffer zones around Class 1 or
Class 2 areas, and areas with very low potential for residual contamination but insufficient
information to justify a non-impacted classification.
(4) Summary. Class 1 areas have the greatest potential for contamination and therefore
receive the highest degree of effort for the final status survey using a graded approach,
followed by Class 2, and then by Class 3. Non-impacted areas do not receive any level of
survey coverage because they have no potential for residual contamination. Non-impacted
areas are determined on a site-specific basis.
c. MARSSIM then assists in determining the number and quality requirements of data
collected, and provides statistical tests to ensure that sufficient data are collected so a
defensible decision to remediate further or determine no further action for the site can be
made. The statistics also take into account the stakeholder negotiated decision errors.
d. While MARSSIM is designed primarily to address the final status survey of a site,
the methodologies and statistical tests are applicable to scoping surveys, characterization
surveys, and remedial action surveys. Additional multi-agency guidance is in draft which
addresses sub-surface soils, equipment and debris release, and radiological laboratory
accreditation.
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Figure 13-1. Data Life Cycle Applied to a Final Status Survey.
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Figure 13-2. Flow Diagram for Designing a Final Status Survey.
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APPENDIX A
References and Bibliography of Regulatory Documents, Regulations and Laws
A-1. Code of Federal Regulations (CFR)*
a. NRC Standards.
10 CFR 20
Standards for protection against radiation
10 CFR 60
Disposal of high-level radioactive wastes in geologic repositories
10 CFR 61
Licensing requirements for land disposal of radioactive waste
10 CFR 71
Packaging and transportation of radioactive material
b. OSHA Standards.
29 CFR 1910
Occupational safety and health standards
29 CFR 1926
Safety and health regulations for construction
c. EPA Standards
40 CFR 61
National emission standards for hazardous air pollutants
40 CFR 122
EPA administered permit programs: The national pollutant discharge elimination system
40 CFR 125
Criteria and standards for the national pollutant discharge elimination system
*
Superintendent of Documents
Government Printing Office
Washington, DC 20402
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40 CFR 141
National primary drinking water regulations
40 CFR 142
National primary drinking water regulations implementation
40 CFR 191
Environmental radiation protection standards for management and disposal of spent nuclear
fuel, high-level and transuranic radioactive wastes
40 CFR 192
Health and environmental protection standards for uranium and thorium mill tailings
40 CFR 260
Hazardous waste management system: General
40 CFR 261
Identification and listing of hazardous waste
40 CFR 268
Land disposal restrictions
40 CFR 300
National Oil and Hazardous Substances Pollution Contingency Plan
d. General Standards.
41 CFR 101
Federal Property Management Regulations
48 CFR Chapter 2
Federal Acquisition Regulation Department of Defense
e. DOT Standards
49 CFR 171-178
Transportation of Hazardous Materials
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A-2. Congressional Acts.
Clean Air Act
Public Law 88-206
42 U. S. C. 1857
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA)
Public Law 96-510
42 U. S. C. 9601-et seq., as amended
Superfund Amendments and Reauthorization Act of 1986
(SARA, amending CERCLA)
Public Law 99-499
Federal Water Pollution Control Act (Clean Water Act)
Public Law 86-70 amended by PL 92-500
33 U. S. C. 1251 et seq.
National Environmental Policy Act (NEPA)
Public Law 91-190
42 U. S. C. 4321
Solid Waste Disposal Act as amended by the
Resource Conservation and Recovery Act of 1976 (RCRA)
Public Law 94-580
42 U. S. C. 6901et seq., as amended
Hazardous and Solid Waste Amendments of 1984(HSWA) amends the Solid Waste Disposal
Act as amended by RCRA
Public Law 98-616
Safe Drinking Water Act
Public Law 93-523
42 U. S. C. 300f et seq., as amended
Toxic Substances Control Act
Public Law 94-469
15 U. S. C. 2601 et seq., as amended
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National Low Level Radioactive
Waste Policy Act of 1980
Public Law 96-573
42 U. S. C. 2021-2121D
The following three acts are available in NUREG 0980:
Low Level Radioactive Waste Policy Act Amendments Act of 1985
Public Law 99-240
42 USC 2021b et seq.
NUREG 0980 Vol. 2
Atomic Energy Act of 1954 (and amendments)
42 U. S. C. 2011-2296
NUREG 0980 Vol. 1
Energy Reorganization Act of 1974
Public Law 93-438
NUREG 0980 Vol. 1
A-3. DOD Regulations.
DOD 4715.6-R
Low-Level Radioactive Waste Disposal Program
A-4. Army Regulations.
AR 11-9
The Army Radiation Safety Program
AR 50-7
Army Reactor Program.
AR 200-1
Environmental Protection and Enhancement
AR 200-2
Environmental Effects of Army Actions.
AR 385-10
Army Safety Program.
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AR 385-40
Accident Reporting and Records.
AR 750-43
Army Test, Measurement and Diagnostic Equipment Program.
A-5. USACE Publications.
a. Engineer Regulations.
ER 5-1-11
U.S. Army Corps of Engineers Business Process
ER 200-1-4
Environmental Quality - Formerly Utilized Sites Remedial Action Program (FUSRAP) - Site
Designation, Remediation Scope, and Recovering Costs
ER 385-1-80
Ionizing Radiation Protection.
ER 385-1-92
Safety and Occupational Health Requirements for Hazardous, Toxic and Radioactive Waste
(HTRW) Projects.
ER 1110-1-263
Chemical Data Quality Management For Hazardous, Toxic, Radioactive Waste Remedial
Activities
ER 1110-3-1301
Hazardous, Toxic And Radioactive Waste (HTRW) Cost Engineering
ER 1165-2-132
Hazardous, Toxic And Radioactive Waste (HTRW) Guidance For Civil Works Projects
b. Engineer Manuals.
EM 200-1-2
Technical Project Planning (TPP) Process
EM 200-1-3
Requirements for the Preparation of Sampling and Analysis Plans
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EM 200-1-6
Chemical Quality Assurance For Hazardous, Toxic And Radioactive Waste (HTRW)
Projects
EM 385-1-1
Safety And Health Requirements Manual
EM 385-1-80
Safety - Radiation Protection Manual
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APPENDIX B
Radiation Control Agency Points of Contact*
B-1. Federal Radiation Programs.
a. MARSSIM Appendix L.
MARSSIM Appendix L contains a directory list of Federal radiation program managers
and is updated on a regular basis.
MARSSIM Appendix L
NRC Headquarters and Regional Offices
b. USACE and Radioactive Waste Disposal Points of Contact.
Headquarters, US Army Corps of Engineers
Radiation Safety Staff Officer
441 G St NW
Washington, DC 20314-1000
(202) 761-1953
US Army Corps of Engineers
HTRW Center of Expertise
12565 W Center Rd
Omaha, NE 68144-3869
(402) 697-2478 fax (402) 697-2595
Headquarters, Army Field Support Command AMSFS-SF
Building 350, 32 Floor
1 Rock Island Arsenal
Rock Island Arsenal, IL 61299-6500
(309) 782-2033
fax (309) 782-2988
*
Because offices move and change, addresses and telephone numbers found at these hyperlinks cannot be
guaranteed, but they should provide an excellent starting point the majority of the time.
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B-2. State Agencies.
The Conference of Radiation Control Program Directors (CRCPD) maintains a
directory of State Program POCs.
CRCPD
NRC Agreement States
Alabama
Kansas
Arizona
Kentucky
California
Louisiana
Colorado
Maine
Florida
Maryland
Georgia
Massachusetts
Illinois
Mississippi
Iowa
Nebraska
Nevada
New Hampshire
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
B-2
Oregon
Rhode Island
South Carolina
Tennessee
Texas
Utah
Washington
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APPENDIX C
Technical Information on Radioactive Materials, Decay,
Measuring Techniques, and Instrumentation
C-1. Decay Chains.
a. Many radioactive materials decay to other radioactive materials, which may in turn,
also decay to other radioactive materials. When the parent radionuclide decays to a
radioactive progeny, it is said to be part of a radioactive decay chain. Two very common
decay chains are the uranium-238 decay chain, which includes, among other radionuclides,
thorium-230, radium-226, and radon-222, and the thorium-232 decay chain, which includes
radium-228 and radon-220.
b. Because of the existence of decay chains, a number of things important to
contaminant characterization can happen. First, if a parent radionuclide is found on-site, the
progeny radionuclide can be expected to be on-site, and inversely, if a progeny radionuclide
is present, the presence of its parent radionuclide may be inferred. For example, if you have
detected cesium-137 on a site, you will always find its progeny, barium-137m on the site, and
its activity will be in equilibrium with the activity of the cesium-137.
C-2. Identifying Radionuclides.
a. Radionuclides are identifiable by the radiation they emit, and by their atomic
properties. Most radionuclides found on USACE projects emit multiple types and energies
of radiation. The types and energies of the all the radiations emitted by a radionuclide are a
unique characteristic of that radionuclide.
b. Example: cesium-137 (137Cs) decays by two pathways. 94.6% of the time 137Cs will
emit a beta particle with a maximum energy of 511.6 keV. 5.4% of the time 137Cs will decay
by emitting a beta particle with a maximum energy of 1173.2 keV. In both cases it decays to
metastable barium-137m (137mBa), which is also radioactive. 137mBa decays to stable barium137, 89.98% of the time by emitting a 661.649 keV gamma ray.
c. So anytime we have Cs-137 contamination on-site, we will be able to measure a
spectrum of beta activity with a maximum beta energy of 1173 keV, and a 137mBa gamma
peak with an energy of 662 keV.
d. An unknown sample of a radioactive material can be analyzed by determining what
type of radiation it emits, determining at what energy the radiation is emitted, then looking
up in tables which particular radionuclides emit that type of radiation at that particular
energy. In the example above, 137Cs could be analyzed using a liquid scintillation counter to
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determine the beta spectrum, and the maximum beta energy. The area under the curve of the
beta spectrum is proportional to the activity of the 137Cs. Noting that 137Cs is part of a decay
chain, one could also use a gamma counter to count the gamma rays at an energy of 662 keV
from the 137mBa and divide the result by the gamma intensity of 89.98% to calculate the
activity of the 137Cs. Since gamma counting is much easier and cheaper to perform, this
method is more commonly used. Many of the radionuclides of concern at USACE sites are
parts of decay chains.
e. Surrogates can be used because, when a parent radionuclide has a half-life very
much larger than its progeny, the progeny decay at a rate faster than it is generated, so it
appears than the activity of the progeny is equal to the activity of the parent after sufficient
in-growth. As a rule of thumb, seven half-lives of the progeny is considered sufficient time
for this in-growth to be achieved.
f. This practice of measuring a surrogate radionuclide and calculating the activity of
another radionuclide in the same decay chain is common, but there are a number of pitfalls
that must be avoided. There are a number of actions that can invalidate this use of
surrogates. Many of these involve actions that chemically separate the radionuclide from its
progeny or not permit enough time for adequate in-growth of the surrogate. It is important to
discover at which point in the decay chain materials were brought to the site or removed from
the site.
g. A number of decay progeny may be gamma emitters but either the percent of time
the gammas are emitted or the percent of time the decay chain goes by their path may be too
small to make them useful at activities near remediation guidelines. All use of surrogates for
determination of the presence and activity of a radioactive contaminant must be thoroughly
investigated, documented and agreed to by the regulators.
h. Because the act of sampling soil or water can disrupt the concentrations of ingrown
progeny, samples must be held for a number of days or weeks to ensure that the surrogate
being measured has had sufficient time to approach equilibrium with the parent radionuclide
being analyzed.
i. As an example, Ra-226 is commonly analyzed using gamma spectroscopy and
measuring the activity of Bi-214. The decay chain is Ra-226 to Rn-222 to Po-218 to Pb-214
to Bi-214 to Po-214. The act of soil sampling often causes the Rn-222, which is a gas, to
escape. This disrupts the decay chain and the sample should be held undisturbed for seven
half-lives for each of the progeny to re-establish equilibrium. The half-lives of the progeny
are Rn-222-3.82 days, Po-218-3.05 min., Pb-214-26.8 min., and Bi-214-19.9 min. This totals
3.85 days. The sample should be held for seven half lives, 27 days, to ensure that the Bi-214
activity is the same as the Ra-226 activity. Note that under certain conditions, ratio charts
can be constructed to allow counting before the seven half-lives have passed. There are a
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number of factors that can influence the accuracy of the ratio chart. The project health
physicist should be consulted to check if the method may be accurately used on any
particular phase of a project.
j. Bi-214 emits a 0.609 MeV gamma 46.1% of the time when it decays. The gamma
spectrometer will count the number of these gamma emitted. The radiochemist will divide
the number of counts by the efficiency and the intensity to determine the number of
disintegrations during the counting period. This is then assumed to be the number of
disintegrations of the parent radionuclide over the same time period.
k. Since radionuclides can be measured by their atomic properties, some chemical
quantification methods may be used to quantify the radionuclides. One common example is
use of inductively coupled plasma-mass spectrometry to determine the isotopic abundance of
enriched or depleted uranium isotopes.
C-3. Background.
a. A large number of radionuclides are present in the environment at concentrations
that can interfere with the measurement of the contamination at a site. The radiation emitted
by these radionuclides - mostly naturally occurring but some man-made is collectively
referred to as background radiation. Primary radionuclides found in background include:
• The uranium (U) decay chain [U-238, thorium (Th)-234, protactinium (Pa)-234, U234, Th-230, radium (Ra)-226, radon (Rn)-222, polonium (Po)-218, lead (Pb)-214, bismuth
(Bi)-214, Po-214, Pb-210, Bi-210, and Po-210].
• The thorium decay chain [Th-232, Ra-228, actinium (Ac)-228, Th-228, Ra-224,
Rn-220, Po-216, Pb-212, Bi-212 and Po-212].
• Potassium-40 (K-40), tritium (H-3) and carbon-14 (C-14).
• Mixed fission products from above ground nuclear testing (Cs-137, Sr-90, etc.).
b. The concentrations of radionuclides in background are highly variable, depending
on types of soil throughout the entire soil column, precipitation, water table, temperature, and
latitude. Concentrations can vary by orders of magnitude. For example, uranium found in
igneous rock averages about 0.6 ppm, but uranium found in Florida phosphate rock averages
about 120 ppm.
c. Because of this variability, it is important to select an area from which to take
background survey readings and samples that has the same soil and water characteristics, and
as near the physical location, of the contaminant as is possible. Additionally, when
determining background concentrations, enough background samples must be obtained to
determine the variability and standard deviation of the concentration at an acceptable
confidence limit. MARSSIM, Sec. 4.5, provides guidance on selection of a background
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reference area, and a health physicist must be consulted to determine the proper number of
background samples to take. This number may be as high as the total number of samples
taken at the site, i.e., one background sample per contaminant sample.
C-4. Regulated Contaminants. Because of the nature of the regulatory process, radioactive
contamination is regulated under a number of statutes. A more detailed description of the
regulations and their interaction can be found in Chapter 9. Ongoing legislative changes
have followed changes in the philosophy of radiation safety, but a number of older statutes
are still applicable, and have led to a few confusing remediation goals at some sites. The
Uranium Mill Tailings Control Act was one of the first acts specifically addressing
radioactive contamination in the soil. This act set the remediation goal for uranium mill sites
at 5 pCi/g of radium in the top 6 inches of soil and 15 pCi/g radium in each subsequent 15
inches of soil. Because there were no other promulgated standards on soil contamination,
this prescriptive remediation goal was cited as relevant and appropriate and applied to other
sites where the contaminants were not uranium mill tailings.
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APPENDIX D
Typical Remediation Site Characteristics
D-1. Uranium and Thorium Mines and Mills.
a. Facility Operation Description. Uranium is mined using both open pits and
underground shafts. Some facilities are now using a subsurface pumping and leaching
process. Uranium mills are often co-located with the mines. A majority of the mines in the
US are located in the states of Arizona, New Mexico, Utah, and Colorado, but active
leaching also occurs in Nebraska and Texas. The majority of the contaminants are located in
tailings from the mills and the mines. Co-mingled hazardous components such as Arsenic,
and acids are commonly found at these sites.
b. Types of Radiation Expected. Alpha, beta, gamma and neutron radiation can be
expected from these sites.
c. Types of Sources Present. Uranium 238, 235, and 234 and all their decay progeny
can be found at these sites. Thorium-232 and 230 and their decay progeny may also be
present at some sites. Since the mills selectively extracted uranium, the decay progeny at
these sites can be expected to not be in equilibrium. There will still be residual uranium or
thorium in the mill tailings, and can be expected to contain greater levels of decay progeny.
d. Radioactive Contamination Potential. There is nearly always contamination from
mining and milling operations. Great piles of mine-and-mill tailings are left on-site. Often
consolidation points from nearby mines exist, where ores were consolidated for transport to
the mills. Surface and ground water contamination is common from rain percolating through
the waste piles, and running off sites. Establishment of background can be troublesome
because the naturally elevated background radiation is primarily attributable to the elevated
Uranium in the local and subsurface soils.
e. Radioactive Waste Generated. Large quantities of source material, 11e.(2)
byproduct material or residuals of ore processing prior to 1978, may be encountered.
f. Potentially Contaminated Areas. Mines, mills access roads, wide surrounding areas,
associated heavy equipment, hand tools, transport vehicles, PPE, ground water, creeks and
rivers, and workers’ houses can be expected to be contaminated. Cross contamination is a
common problem.
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D-2. Nuclear Weapons Facilities.
a. Facility Operation Description. The nuclear weapons facilities considered here are
those where nuclear weapons are inspected, stored, and maintained. TRU materials and
wastes may be present. Both radioactive wastes and co-mingled wastes may be present as
byproducts of the processes and operations in the facilities. The weapons were disassembled,
inspected, repaired, reassembled, and stored until shipped from these facilities.
b. Types of Radiation Expected. Alpha, beta, gamma and neutron radiation can be
expected.
c. Types of Sources Present. The radioactive material can be considered a sealed
source when a weapon is assembled. During inspection and maintenance, the radioactive
material is an unsealed source. Examples of radionuclides present in nuclear weapons are
uranium-233, and -235, plutonium-239 and -241, americium-241, and hydrogen-3. Depleted
uranium is also used in testing and training for weapons maintenance.
d. Radioactive Contamination Potential. There is little potential for radioactive
contamination when a weapon is assembled unless it is subjected to severe physical damage
such as a fire. When a weapon is disassembled, there is a slight potential for contamination.
This potential increases if the radioactive material is damaged in any way during inspection
and maintenance.
e. Radioactive Waste Generated. Very small volumes of slightly contaminated solid
waste can be generated during inspection and maintenance. No significant amount of liquid
radioactive waste is generated.
f. Potentially Contaminated Areas. Areas of potential contamination include
disassembly, inspection, maintenance, and reassembly areas; radioactive waste handling and
packaging areas; and decontamination facilities. Sinks, drains, trash receptacles, and
formerly used radioactive waste disposal cells are probable contaminated areas.
D-3. Research Laboratories.
a. Facility Operation Description. Depending on its mission, a research laboratory may
be involved in a wide variety of activities, including the analysis of materials activated by
neutron radiation, the effects of radiation exposure on animals, and the use of radioactive
tracers in chemistry experiments. Various radionuclides may be used in a typical laboratory
environment or may be used in closed, shielded cells, or glove boxes to protect personnel
from radioactive hazards. A reactor or accelerator may also be used at the facility.
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b. Types of Radiation Expected. Depending on the facility mission, a number of
different radionuclides may be used, and alpha, beta, X, gamma, or neutron radiation can be
expected.
c. Types of Sources Present. Sealed, partially sealed, and unsealed sources can be
expected to be used.
d. Radioactive Contamination Potential. There is a high potential for contamination in
any area of a laboratory where unsealed sources are used.
e. Radioactive Waste Generated. Moderate to large volumes of solid radioactive waste
can be expected. Small to moderate volumes of liquid radioactive waste can also be
generated. Research labs characteristically produce larger quantities of mixed or co-mingled
wastes compared to radioactive wastes.
f. Potentially Contaminated Areas. Areas of potential contamination include:
• Laboratory areas (bench tops, fume hoods, glassware, centrifuges, scintillation
counters, hot cells, glove boxes, and refrigerators used for radioactive material storage)
• Animal cage areas
• Solid radioactive waste-handling and packaging areas
• Liquid radioactive waste system (tanks, pumps, valves, piping)
• Ventilation system (ducting, filters, filter housings)
D-4. Medical Facilities.
a. Facility Operation Description. Medical facilities perform a variety of diagnostic
and therapeutic procedures using radioactive materials and radiation-producing machines.
For diagnostic procedures, radioactive material may be injected into a patient in liquid form
or taken orally. Radiation-producing machines such as X-ray units and computerized
tomography scanners may be used. For therapeutic procedures, radioactive material may be
injected into a patient in liquid form, taken orally, or implanted in solid form. These
implanted sources may remain in the patient or can be removed later. Accelerators and
highly radioactive cobalt-60 source capsules are also used for radiation therapy.
b. Types of Radiation Expected. Beta, X, gamma, neutron and charged particle
radiation sources could occur.
c. Types of Sources Present. Sealed, partially sealed, and unsealed sources can be
expected to be used.
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d. Radioactive Contamination Potential. There is a high potential for contamination
where unsealed sources are used for diagnosis or therapy. Most unsealed radionuclides used
in medicine have short half-lives and, therefore, may not present major decontamination
problems for decommissioning. There is a minimum potential for contamination when
sources are implanted if the sources are mishandled. There is a slight potential for
contamination from sealed sources such as high radioactivity cobalt-60 sources that are used
in radiation therapy units. Contamination may occur from activation products created by
high-energy accelerators (> 10 million electron volts) used in research-oriented medical
facilities.
e. Radioactive Waste Generated. Small to moderate volumes of solid radioactive
waste can be expected. Small to moderate volumes of liquid radioactive waste will be
generated.
f. Potentially Contaminated Areas. Areas of potential contamination may include the
following:
• Radio-pharmacies that are producing, storing, or dispensing radioactive drugs
• Laboratories where liquid sources are prepared for use
• Operating rooms where sources are implanted
• Patients’ rooms and examination rooms where patients who have been administered
radioactive materials are located
• Nuclear medicine hot labs
• Solid radioactive waste-handling, packaging, and storage areas
• Liquid radioactive waste system (tanks, pumps, valves, piping)
• Areas where liquid radioactive sources are stored prior to preparation for
administration
D-5. Pool Reactors and Neutron Radiography Reactors.
a. Facility Operation Description. These reactors are atmospheric-pressure, watercooled assemblies generally used to produce long-term, steady-state fluxes of thermal
neutron radiation. Some reactors can also produce a high flux of thermal neutron radiation
for a very short period of time. The neutron radiation is made available for use outside the
reactor by beam ports which penetrate the reactor structure. Items to be irradiated are placed
in front of the beam ports.
b. Types of Radiation Expected. Primarily gamma and neutron radiation are expected
from the reactor. Beta and gamma radiation are expected from the irradiated test items,
reactor structures, or impurities in the cooling water.
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c. Types of Sources Present. The reactor fuel elements can be considered a sealed
source because the uranium fuel and fission products are contained in cladding. Impurities in
the cooling water that become activated can be considered an unsealed source. Any
radioactive material resulting from neutron activation of test items or reactor structures could
be classified as sealed or unsealed sources based upon the types of materials being activated.
Sealed and partially sealed sources will be used for instrument checks and calibrations.
d. Radioactive Contamination Potential. The potential for contamination in a poolreactor facility can be characterized as moderate. The radioactive material in the cooling
water, which results from neutron activation of impurities, may be pumped through the
cooling system and deposited in pipes, valves, pumps, and other system components. When
these components are opened for maintenance or repair, or if leaks occur, contamination is
likely. The inventory for the coolant radioactive material will be increased if the fuel
cladding leaks or is damaged in some manner, releasing fission products into the cooling
water. If neutron activation of test items or the structures surrounding a reactor occurs, the
radioactive material will be fixed.
e. Radioactive Waste Generated. Moderate volumes of solid and liquid radioactive
wastes will be produced at this type of facility.
f. Potentially Contaminated Areas. Areas and other sources of potential contamination
include:
•
•
•
•
•
•
•
•
•
Area housing the reactor
Areas housing the reactor auxiliary system
Test items
Beam ports and equipment used to handle activated test items
Maintenance areas
Solid radioactive waste-handling and packaging areas
Liquid radioactive waste system (tanks, pumps, valves, piping)
Ventilation system (ducting, filters, filter housings)
Decontamination areas
D-6. Power Reactors.
a. Facility Operation Description. The majority of the power reactors in the United
States are pressurized water reactors (PWR) or boiling water reactors (BWR). Other types of
reactors include gas-cooled, liquid metal, and heavy water. The reactor fuel produces large
amounts of heat as a result of the fission process. This heat is used to generate steam directly
in a BWR or is carried by the coolant in the primary system to the steam generator in a PWR
or other indirect-cycle reactors. The heat is transferred through the walls of the tubes in the
steam generator to the water in the secondary side of the steam generator. The temperature is
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sufficiently high to change the secondary water into steam. In most plants, the steam travels
to a turbine that drives an electric generator to produce electrical power.
b. Types of Radiation Expected. Primarily, gamma and neutron radiation are expected
from the reactor. Beta and gamma radiation are expected from the irradiated reactor
structures or impurities in the coolant. Alpha, beta, and gamma radiation may arise from the
spent fuel rods stored at the facility.
c. Types of Sources Present. The fuel rods inside the reactor itself are designed to
contain the uranium fuel and fission products within the cladding. The fuel rods are the main
source of gamma and neutron radiation in the reactor. However, cladding failure, or the
presence of tramp uranium on reactor surfaces, may result in the release of radioactive fission
products to the surrounding coolant. Activated impurities and corroded activated metals in
the reactor coolant can be considered an unsealed source. Activated materials in the reactor
structure can also be the source of gamma and beta radiation.
d. Radioactive Contamination Potential. The potential for contamination in a power
reactor facility is greater than that in other facilities primarily because of repair and
maintenance activities. The radioactive material in the reactor coolant, which results from
neutron activation of corrosion products and fission products from fuel-cladding failures or
tramp uranium, is carried through the system and deposited in pipes, valves, pumps, the
steam generator, and other components. When these components are opened for
maintenance or repair, or if leaks occur, contamination is likely. The radioactive material
inventory will be greatly increased if a substantial number of fuel-cladding leaks occur or the
fuel is damaged in some manner, releasing fission products into the primary coolant. When
neutron activation of the structures surrounding a reactor occurs as the system ages, the
radioactive material is fixed but may become removable if the material is dislodged through
corrosion and erosion.
e. Radioactive Waste Generated. Great volumes of solid and liquid radioactive waste
can be produced at this type of facility.
f. Potentially Contaminated Areas. Areas of potential contamination include:
•
•
•
•
•
•
•
•
Area housing the reactor
Areas housing reactor auxiliary systems
Maintenance areas
Equipment decontamination areas
Personnel decontamination areas
Protective clothing laundry area
Respiratory protective equipment decontamination area
Solid radioactive waste-handling and packaging area
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•
•
Liquid radioactive waste-system (tanks, pumps, valves, piping)
Ventilation systems (ducting, filters, filter housings)
D-7. Accelerator Facilities.
a. Facility Operation Description.
(1) Particle accelerators are radiation-producing machines used for medical, industrial,
and research purposes.
(2) Electron linear accelerators (linacs) are used to produce a primary beam of electron
radiation (similar to beta radiation though highly directive and of much greater energy) or a
secondary beam of X-radiation (similar to gamma radiation) for use in therapy. The patient
is positioned relative to the output beam port of an electron linacs and the machine is
energized for the time required to produce the amount of radiation desired for the therapy.
(3) Electron linacs are used in industrial applications to produce a secondary beam of
X-radiation. The radiation is used for the radiography of such items as welds, castings, and
munitions. Electron linacs are used in research to determine the effects of irradiation on
various materials under study.
(4) Other types of particle accelerators are used for engineering physics research.
b. Types of Radiation Expected. Electrons make up the primary beam of electron
linacs. If the output energy of electron linacs exceeds about 10 million electron volts,
neutrons may be produced. Other types of particle accelerators emit, protons, alpha particles
or other nuclear particles, resulting in secondary radiations and activation of materials. The
activated material normally decays by beta- (positive or negative) and gamma-radiation
emission.
c. Types of Sources Present. Linacs incorporate radioisotopes of various species in
their sources and in some of their targets. If the output energy of an electron linac exceeds
about 10 million electron volts, neutron radiation may be produced. This neutron radiation
and output from other types of particle accelerators may activate areas of the device around
the output beam port and the structure surrounding the device. If this occurs in solid objects,
the radioactive material is considered a sealed source; activated liquids or gases will usually
be in unsealed form and more mobile.
d. Radioactive Contamination Potential. There are several different types of particle
accelerators. Each type and its specific operation must be reviewed to determine the
potential contamination.
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e. Radioactive Waste Generated. No liquid or solid radioactive waste is expected
unless the electron linac exceeds 10 million electron volts, in which case small volumes of
solid, liquid, or gaseous waste resulting from neutron activation may be produced. Small
volumes of radioactive waste may be generated by other types of particle accelerators.
f. Potentially Contaminated Areas. If the output energy of electron linacs is less than
10 million electron volts, none of the surrounding structure will be contaminated. Energies
greater than 10 million electron volts from electron linacs or other particle accelerators may
activate components, targets, and surrounding structures, which may result in contamination
from loose or disturbed material, during maintenance of the devices, and during
decommissioning of the devices.
D-8. Radiographic Facilities.
a. Radiographic Facilities using Electromagnetic Radiation. The primary purpose of
radiographic facilities is to nondestructively test items for defects. For example, welds are
radiographed to reveal any hidden porosity or cracks, castings are radiographed to reveal any
hidden voids, and munitions are radiographed to check for proper assembly. Electromagnetic
radiation penetrates a test item and exposes a sheet of film or array of detectors in the same
manner that light exposes film or video systems to produce an image. Radiographic films are
processed and checked for defects in the item radiographed. The electromagnetic radiation
needed for radiography may be produced by a sealed source of radioactive material such as
cobalt-60 or iridium-192, or by X-ray machines or election linacs. Sealed radioactive
sources must be housed in shielded containers when not in use. The containers may be fixed
or portable. X-ray machines require no shielding when not in use because radiation is
produced only when a machine is electrically energized. Shielding is required when a
machine is energized. X-ray machines may be installed in a fixed configuration or may be
portable.
(1) Types of Radiation Expected. Gamma radiation is expected from sealed
radioactive sources. Linacs may be used to generate the radiographic beam and their
characteristic radiation and waste potential should be expected.
(2) Types of Sources Present. When radioactive material is used, the sources will be
sealed.
(3) Radioactive Contamination Potential. There is no potential for contamination from
an X-ray machine or from a sealed source unless the source is damaged in a manner that
breaches the integrity of the material used to encapsulate the radioactive material, or unless
the sealed source leaks for any other reason.
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(4) Radioactive Waste Generated. None is expected from most radiographic systems.
However, if linacs are used to generate the radiographic beam, the sources and targets are
probable waste sources.
(5) Potentially Contaminated Areas. There are none, except in the case of linacgeneration radiographic systems.
b. Radiographic Facilities using Neutron Radiography. Neutron radiography is used to
detect moisture and corrosion in bonded honeycombed structures and to test other materials.
The secondary radiations created by the neutrons reacting with the material are detected and
displayed on monitors that have the capability of digital and imaging enhancement. Most
frequently, sources such as radium, americium, or plutonium can be used as sources of alpha
radiation impinging on beryllium. The beryllium is activated by alpha radiation to emit
neutrons. The radiography occurs in a shielded and interlocked bay, which is accessible only
when the source is withdrawn into a shield.
(1) Types of Radiation Expected. Neutrons from the source are to be expected. Due to
neutron activation, alpha, beta, neutron, and gamma radiation may result from irradiated test
items and structural materials.
(2) Types of Sources Present. The source is typically sealed hermetically. Source
encapsulation may fail, causing the direct release of alpha and neutron radiation. Any
radioactive material resulting from activation of test items or structural material can be
classified as sealed or unsealed, based on the types of material being activated.
(3) Radioactive Contamination Potential. The potential for contamination is low for
properly used and maintained sources. Abandoned or lost source capsules present a serious
hazard. It must be noted that the beryllium used to produce the secondary neutron radiation
is a very toxic heavy metal. Neutron activation of test items or the structure surrounding the
source of neutrons could result in contamination if the material were dislodged and became
loose and spreadable.
(4) Radioactive Waste Generated. Very little waste will be generated that is
radioactive so long as proper operational, maintenance, and storage practices are followed.
Decommissioning of radiographic equipment will generate the largest portion of LLRW of
the entire use cycle. The potential for uncontrolled radioactive waste is greater in the event
of equipment abandonment, fire, or other catastrophic event.
(5) Potentially Contaminated Areas. Areas of potential low-level contamination are
restricted to the radiography bay and test-material-handling areas.
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D-9. Radioluminous-device Storage Facilities.
a. Facility Operation Description. These facilities store new and used radioluminous
devices such as clocks, instruments, gunsights, night-vision testers, exit signs, and
radioluminescent airfield lighting systems.
b. Types of Radiation Expected. Radioluminescent devices use radioactive sources to
energize phosphorescent elements or chemicals. The radioactive materials primarily used to
generate luminosity are tritium, promethium-147, krypton-85, and radium-226. Tritium and
promethium-147 emit beta radiation only, krypton-85 emits beta and gamma radiation, and
radium-226 emits alpha and gamma radiation. Decay products of radium-226, which are
radioactive, will also emit beta radiation. Radon-222 is a gaseous decay product and poses
the risk of inhalation.
c. Types of Sources Present. Radioluminous devices may consist of instrument faces
with the radiation source painted on or may incorporate vials or capsules of radioluminous
materials. Because the devices frequently rely on tritium or radium as primary radiation
sources, they have great potential to be effectively unsealed. This is because tritium may be
a gaseous radioisotope, and because one of the daughters of the decay of radium is radon,
which is a gaseous radioisotope. Guaranteed seals, even of encapsulated radioluminous
materials, are difficult to achieve and should not be expected.
d. Radioactive Contamination Potential. Radioluminous paint is a probable surface
and water contaminant when scraped or dissolved off its substrate. The most serious and
difficult contamination arising from radioluminous devices is from radium-doped paint.
e. Radioactive Waste Generated. Damaged equipment components that are painted
with radioluminous materials may be radioactive waste. Maintenance of radioluminous
systems will generate contaminated cleanup materials. Radioluminous materials
characteristically produce gaseous radioactive contaminants. Tritium and radon are readily
soluble in water, are easily spread, and can contaminate biological organisms, soil, and
ground water. The great mobility of radioluminescent-generated waste makes it difficult to
clean up. Fortunately, the low energy levels and the small volumes of the original sources
commonly encountered will lessen the environmental impact.
f. Potentially Contaminated Areas. There are none, provided the device containing the
radioactive material remains intact. Devices with tritium or radium-226 should be treated as
suspect to having leakage because of the gaseous radioisotopes involved.
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D-10. Depleted Uranium Usage and Storage Facilities.
a. Facility Operation Description. Depleted uranium is used to manufacture various
types of munitions. These munitions are stored in various facilities and are used in test and
practice firings as well as actual warfare. Depleted uranium has been used as armor in some
military vehicles and as counterweights in aircraft. Depleted uranium is also used for
shielding radiography and teletherapy sources.
b. Types of Radiation Expected. Alpha, beta, gamma and neutron radiation can all be
expected. Additionally, the radioactive decay of the Uranium will produce a sequence of
daughter radioisotopes, each of which generates its own characteristic suite of ionizing
radiation. Uranium is also a kidney toxin and in some cases the chemical toxicity may be
more of a hazard than the radiation exposure. Controls should be based on the more limiting
of the chemical or radiological exposures.
c. Types of Sources Present. The depleted uranium in the stored munitions is encased
in aluminum or painted, so this source is considered sealed if the case or paint is intact. After
the munitions are fired, the sources would be unsealed because the depleted uranium shatters
and is dispersed. Depleted uranium used for shields is usually encased in steel and is
considered a sealed source.
d. Radioactive Contamination Potential. Airborne dust, machine shavings, cutting
lubricants, etc., will arise from the fabrication of components from depleted uranium. Waste
disposal areas, water drains, and ventilation ducts will be contaminated by the depleted
uranium. Once assembled, there is no potential while the munitions are in storage. After the
munitions are fired, there will be contamination of target areas and target materials.
e. Radioactive Waste Generated. There is little from storage except for radon-222
(inhalable alpha radiation source) produced as a decay daughter. Large fragments of the
depleted uranium dispersed after firing and the contaminated targets may be collected and
disposed of as waste. Small fragments and uranium oxide dust are not collected and are
generally dispersed around the target site. The volumes and dispersal of this contamination
are substantial.
f. Potentially Contaminated Areas. Firing ranges and targets are areas of
contamination.
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D-11. Maintenance Shops Repairing Components Containing Magnesium-Thorium Alloys
and Depleted Uranium.
a. Facility Operation Description. Machine shops at Air Force Logistics Command
Bases repair aircraft parts consisting of depleted uranium and magnesium-thorium alloys by
machining, cutting, drilling, welding, and grinding.
b. Types of Radiation Expected. Alpha, beta, gamma, and X-ray from thorium-232
and uranium-238, and radionuclides resulting from their decay are expected. Uranium is also
a kidney toxin and in some cases the chemical toxicity may be more of a hazard than the
radiation exposure. Controls should be based on the more limiting of the chemical or
radiological exposures.
c. Types of Sources Present. Depleted uranium as aircraft counterweights and aircraft
components manufactured from magnesium-thorium alloys are considered sealed sources
except during repair operations which remove metal.
d. Radioactive Contamination Potential. There is no potential while the parts are in
service or storage. Contamination results from machining, cutting, drilling, welding, and
grinding operations.
e. Radioactive Waste Generated. Grindings, filings, grinding oils, and broken parts are
disposed of as radioactive waste. During grinding of magnesium-thorium alloys, water is
used to prevent fires. This water is collected in the hood sump and the water is filtered prior
to release to the environment. Both liquid filters and high-efficiency particulate air filters for
the hoods are disposed of as radioactive waste. The waste volume generated is not large
enough to require a specific on-site storage facility.
f. Potentially Contaminated Area. This is limited to the hoods, exhaust ductwork, and
immediate area in which repair operations are conducted.
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GLOSSARY
Terms, Abbreviations, and Acronyms
µ
AFSC
ALARA
ARAR
Bq
CERCLA
CFR
CHP
Ci
cpm
Cs
CX
CY
DA
D&D
DCGL
DERP
DOD
DOE
DOT
dpm
DQO
EC
EM
EPA
EM
ER
FUSRAP
FSS
G
g
Gy
HLW
HP
HPGe
HQ
hr
microArmy Field Support Command
As Low As is Reasonably Achievable
Applicable, Relevant and Appropriate Regulations
becquerel
Comprehensive Environmental Response, Compensation, and Liability
Act
Code of Federal Regulations
Certified Health Physicist
curie
counts per minute
cesium
Center of Expertise
cubic yard
Department of the Army
Decontamination and Decommissioning
Derived Concentration Guideline
Defense Environmental Restoration Program
Department of Defense
Department of Energy
Department of Transportation
disintegrations (decays) per minute
Data Quality Objective
Engineering Circular
Engineer Manual
Environmental Protection Agency
Engineering Manual
Engineering Regulation
Formerly Used Sites Remedial Action Program
Final Status Survey
gigagram
gray
High-Level Radioactive Waste
Health Physic(s)(ist)
High Purity Germanium
Headquarters
hour
Glossary-1
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HSWA
HTRW
k
keV
L
LLRW
LUC
µR
m
X
M
m
MARSSIM
MDC
mR
mrem
MSC
n
NaI
NORM
NRC
OSHA
PA/SI
p
pCi
PM
POC
ppm
PRG
QA
QC
R
Ra
RCRA
ROD
SARA
SHP
SI
Sr
SSL
Sv
SWMU
T
Hazardous and Solid Waste Amendments
Hazardous, Toxic and Radioactive Waste
kilokilo-electron volts
liter
Low-Level Radioactive Waste
Land Use Control
microroentgen
metastable
megameter or milliMulti-Agency Radiation Site Survey and Investigation Manual
Minimum Detectable Concentration
milliroentgen
millirem
Major Subordinate Commands
nanosodium iodide
Naturally Occurring Radioactive Materials
Nuclear Regulatory Commission
Occupational Safety and Health Administration
Preliminary Assessment/Site Investigation
picopicocurie
Project Manager
Point of Contact
parts per million
Preliminary Remediation Guideline
Quality Assurance
Quality Control
roentgen
radium
Resource Conservation and Recovery Act
Record of Decision
Superfund Amendments and Reauthorization Act
Safety and Health Program
Systeme Internationale
strontium
Soil Screening Level
sievert
Solid Waste Management Unit
teraGlossary-2
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TEDE
Th
TPP
TRU
TSDF
U
US
USACE
Total Effective Dose Equivalent
Thorium
Technical Project Planning
Transuranic Waste
Treatment, Storage or Disposal Facility
uranium
United States
US Army Corps of Engineers
Glossary-3
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