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U.S. EPA Superfund Remedial Program’s Approach for Risk and Dose Assessment when
U.S. EPA Superfund Remedial
Program’s Approach for Risk
and Dose Assessment when
addressing Radioactive
Contamination
Stuart Walker
U.S. Environmental Protection Agency
Office of Superfund Remediation
and Technology Innovation (OSRTI)
Presented to U.S. NRC
Regulatory Information Conference
in Bethesda, MD on Tuesday March 10, 2015
EPA
Page-1
EPA Addresses Site Cleanup Under
Several Laws, Programs
This talk discusses only the Comprehensive
Environmental Response, Compensation &
Liability Act, CERCLA or “Superfund”
National Contingency Plan (NCP) is regulation
for CERCLA
National Priorities List (NPL) guides EPA’s
remedial program on which sites need further
attention
EPA
Page-2
Purpose
Provide brief description of CERCLA remedial
program process
Provide overview and comparison of key EPA
CERCLA remedial program guidance and tools
that specifically address radionuclides
»Radionuclides are also addressed with other
hazardous substances under general EPA
CERCLA guidelines
EPA
Page-3
1
Part 1.
Technical Guidance & Tools
for the Superfund Remedial
Program
Page-4
EPA
Nine CERCLA Remedy Selection
Criteria – Two Threshold
 Two threshold criteria (both must be met)
1. Protect human health and the environment
2. Comply (attain or waive) with other federal
and state laws: Applicable or Relevant and
Appropriate Requirements (ARARs)
— Protect current or future sources of
drinking water (e.g., attain MCLs or more
stringent state standards)
Page-5
EPA
CERCLA Cleanup Levels
 ARARs often determine cleanup levels
 Where ARARs are not available or protective, EPA sets
site-specific cleanup levels that
» For carcinogens, represent an increased cancer risk of
1 x 10-6 to 1 x 10-4
—10-6 used as “point of departure”
—PRGs are established at 1 x 10-6
» For non-carcinogens, will not result in adverse effects
to human health (hazard index (HI) <1)
 Address ecological concerns
 To-be-considered (TBC) material may help determine
cleanup level
EPA
Page-6
2
CERCLA Cleanup Levels Are NOT
Based On
NRC decommissioning requirements (e.g., 25,
100 mrem/yr mrem/yr [0.25, 1 mSv/yr] dose
limits) 10 CFR 20 Subpart E
» If used as an ARAR, 10-6 still used as point of
departure, and 10-4 to 10-6 risk range must be
met
Guidance outside risk range and/or if expressed
as a dose (# mrem/year). This includes:
» DOE orders, NRC guidance (e.g., NUREGs),
ICRP guidance, IAEA guidance, NCRP
guidance, ANSI/HPS guidance, EPA/DHS
Page-7
EPA PAGs, and Federal guidance
Risk-based Cleanup Levels for
Radioactive Contamination
Superfund uses radiation cleanup levels
expressed as risk levels, not mrem [mSv]
Superfund uses “slope factors” instead of dose
conversion tables to estimate cancer risk from
radioactive contaminants
» Slope factors have been updated with new
information from ICRP 107
EPA
Page-8
Site consistency
To help facilitate compliance with NCP and
cleanup sites, EPA Headquarters provides:
»Guidance documents
»Models (calculators)
»Training (developed with State led ITRC)
»13 Annual Meetings with EPA Regions
Guidance, models, training are available for free
on the internet
EPA
Page-9
3
Guidance: Risk Assessment Q&A
Old Superceded
Radiation Risk Assessment at CERCLA Sites: Q&A
(12/99) OSWER Directive 9200.4-31P
Provides overview of then current EPA guidance for
radiation risk assessment
Written for users familiar with Superfund but not
radiation
Adds some new guidance
» Dose assessment only for ARAR compliance
» No dose-based TBCs (including No 15 mrem/yr [0.15
mSv/yr])
» Direct exposure rate may supplement sampling
Page-10
EPA
New 2014 Risk Assessment Q&A
issued June 2014
Radiation Risk Assessment at CERCLA Sites:
Q&A (5/2014) OSWER Directive 9200.4-40
Provides overview of current EPA guidance for
radiation risk assessment
Written for users familiar with Superfund but not
radiation
Page-11
EPA
2014 Risk Q&A -- Reflect Superfund
guidance issued since 1999
1. Rad SSG User Guide 2000
7. BPRG calculator 2006
2. Rad SSG TBD 2000
8. SPRG calculator 2009
3. PRG calculator 2002
9. BDCC calculator 2010
4. Common Rads found at
Superfund sites 2002
10. SDCC calculator 2010
5. DCC calculator 2004
12. Eco calculator 2015?
11. CPM calculator 2015?
6. SF Rad Risk Assessment
& How You Can Help 2005
EPA
Page-12
4
2014 Risk Q&A -- Update Policies
Based on Newer Science
For an effective dose standard ARAR to be
considered protective, it should be 12 mrem/yr
[0.12 mSv/yr] or less.
»Change from 15 mrem/yr [0.15 mSv/yr] based
on risk to dose estimate in Federal Guidance
13
»Cleanup levels not based on an ARAR
continue to be based on cancer risk range
(10-4 to 10-6) not dose
EPA
Page-13
2014 Risk Q&A -- Update Policies
Based on Newer Science, cont.
To comply with UMTRCA indoor radon standard
as an ARAR, users may assume the following
concentrations correspond to 0.02 Working
Levels:
»5 pCi/l of Rn-222
»7.5 pCi/l of Rn-220
The methodology for making these conversions
is discussed in ICRP “Lung Cancer Risk from
Radon and Progeny”
EPA
Page-14
2014 Risk Q&A -- More consistency
on Risk Assessments (Rad & Chem)
Explain what type of circumstances these
Superfund guidance and tools are recommended
Reiterate more strongly that risk assessments
(e.g., models used) should be consistent with
chemicals at site and with other regional sites
Don’t use a steady state model for chemical and
a transfer/dynamic model for radionuclides
»Such as using RSL calculator for chemicals
then RESRAD for radionuclides
EPA
Page-15
5
2014 Risk Q&A -- More consistency
on Surveys (Rad & Chem)
Explain what type of circumstances these
Superfund guidance and tools are recommended
Reiterate more strongly that site surveys (e.g.,
characterization and confirmation) should be
consistent with chemicals at site and with other
regional sites
Don’t use not-to-exceed (NTE) for chemicals and
area averaging (AA) for radionuclides for
residential
»NTE for residential cleanup of chemicals but
AA approach like MARSIMM for the
radionuclides
EPA
Page-16
Guidance: Rad SSG
 Soil Screening Guidance for Radionuclides
[rad SSG] documents (10/00) OSWER Directives 9355.4-16A
and 9355.4-16
» User Guide
» Technical Background Document
 Guidance to screen out areas, pathways, and/or radionuclides
early in the process
 Consistent with 1996 chemical SSG
» 1 x 10-6 and MCLs (leaching from soil)
» Residential land use
» Survey procedures for site characterization
» Evaluates 5 soil to groundwater models
» Accounts for technical differences of radiation
EPA
Page-17
Guidance: Rad PRG Calculator
Calculator to establish PRGs, when:
» ARAR is either not available or sufficiently
protective (e.g., greater than 12 mrem/yr
[0.12 mSv/yr])
Electronic equations (risk and leaching to
groundwater) also are on Internet
» 1x10-6 and MCLs (leaching from soil)
» Accounts for technical differences of
radiation (e.g., gamma, plant uptake)
EPA
Page-18
6
Guidance: Rad PRG Calculator
(continued)
 Ten scenarios/land uses available
1.
2.
3.
4.
5.
Residential
Farmer
Recreator
Construction
Indoor workers
6. Outdoor workers
7. Fish ingestion
8. Tap water
9. Soil to groundwater
10. Air
 Chemical RSL Internet equations should be used
for chemical toxicity of uranium
 EPA developed Internet-based training with States
(ITRC) on calculator and radiation risk assessment
» http://www.clu-in.org/conf/itrc/rads_051507/
EPA
Page-19
Guidance: ARAR Dose Calculator
 Calculator to establish Dose Compliance Concentrations
(DCC) for single dose limit ARARs requiring a dose
assessment
 Eight scenarios/land uses available
1. Residential
5. Fish ingestion
2. Farmer
6. Tap water
3. Indoor workers
7. Soil to water
4. Outdoor workers 8. Air
 Equations similar to those used for PRG calculator,
except dose conversion factors
used instead of slope factors
EPA
Page-20
Guidance: Building PRG (BPRG)
Calculator
 Calculator to establish 1x10-6 risk based PRGs for
the reuse of radioactively contaminated buildings.
 Equations and parameters are derived from latest
EPA chemical methodology (e.g., assessment at
WTC which used 1x10-4 cleanup level)
» Adjusted to account for technical differences
posed by radiation
 EPA and ITRC Internet-based training on BPRG
calculator and D&D
» http://www.clu-in.org/conf/itrc/radsdd_040308/
EPA
Page-21
7
Guidance: Building PRG (BPRG)
Calculator (continued)
BPRG calculator includes 2 land use scenarios
»Residential
»Indoor worker
Both land uses include
3 exposure routes
»Settled dust
»Ambient air
»Direct external exposure
—5 Room sizes and 4 receptor locations, both
–Surface
Page-22
EPA –Volumetric
Building Dose Cleanup Concentrations
(BDCC) ARAR Dose Calculator
BDCC Purpose: to establish BCCs for Inside
Buildings for single dose limit ARARs (#
mrem/yr)
BDCC includes 2 land use scenarios
(Residential, Indoor Worker)
2 land uses include 3 exposure routes (Settled
dust, Fixed Direct External 3-D, Ambient Air)
Equations similar to those used for BPRG
calculator, except dose conversion factors
used instead of slope factors
EPA
Page-23
Surfaces PRG (SPRG) Calculator
 Establish 1 x 10-6 risk based PRGs for
radioactively contaminated outside hard surfaces
(e.g., slabs, pavement, sidewalks, sides of
buildings)
 Derived from rad PRG and BPRG calculators
EPA
Page-24
8
SPRG Exposure Scenarios
 SPRG includes 3 land use scenarios
» Residential
» Indoor Worker
» Outdoor Worker
 3 land uses include 3 exposure routes
» Settled dust (pave and unpaved street level)
» Fixed Direct External 3-D (street level)
—Surface and Volumetric
» Fixed Direct External 2-D (slabs)
—Surface and Volumetric
Page-25
EPA
Surface Dose Cleanup Concentrations
(SDCC) ARAR Dose Calculator
SDCC Purpose: to establish DCCs for Outside
Hard Surfaces for single dose limit ARARs (#
mrem/yr)
SDCC includes 3 land use scenarios
(Residential, Indoor Worker, Outdoor Worker)
3 land uses include 3 exposure routes (Settled
dust, Fixed Direct External 3-D, Fixed Direct
External 2-D (slabs))
Equations similar to those used for SPRG
calculator, except dose conversion factors
used instead of slope factors
Page-26
EPA
Part 2.
Involving Stakeholders at
Superfund Remedial Program
Sites
EPA
Page-27
9
Community Involvement
EPA has many tools to facilitate meaningful
involvement by communities near sites
EPA hosts a community involvement national
conference
EPA has 2 tools designed specifically for use at
radiation sites
 EPA works with stakeholders
to develop site-specific tools
for local communities
EPA
Page-28
Toolkit: Radiation Risk Assessment
New – issued June 2014
Superfund Radiation Risk Assessment: A
Community Toolkit
Collection of 22 fact sheets for the general
public. It contains fact sheets on
» Superfund and Radiation
» Superfund risk assessment
process at radiation sites
» Each of the 6 PRG and DCC
calculators
EPA
Page-29
Video: Radiation Risk Assessment
Superfund Radiation Risk Assessment and How
you can Help, an Overview (3/05) OSWER
Directive 9200.4-37
Video for the general public. It contains
information on:
» The Superfund risk assessment process when
addressing radioactive contamination
» How the public is involved
site-specifically
EPA
Page-30
10
Part 3.
Radiation Risk Assessment
Guidance under Development for
the Superfund Remedial Program
EPA
Page-31
Radionuclide Ecological Benchmark
(REB) Calculator
 Establish risk-based Biota Concentration guides
(BCGs), or ecological benchmarks, for
radioactively contaminated sites
 Fits with Superfund framework for
developing eco benchmarks
 Derived from DOE Graded Approach
guidance
» Includes same dose levels for tissue death
» Strong recommendation to look at chemical
eco effects
EPA
Page-32
REB Exposure Scenarios
Includes 12 animal or plant benchmark scenarios
»6 generic composite only
»6 species-specific/site-specific
EPA
Page-33
11
CPM Calculator Scenarios
 The CPM calculator has three major sub
calculators based on the field survey scenario:
1. Ground based scanning of surface contamination
2. Ground based scanning of volumetric
contamination
3. Air based scanning of contamination (under
consideration)
EPA
Page-34
CPM tool caveats
 The CPM tool is intended to facilitate use of RealTime measurement techniques to supplement
sampling NOT replace sampling
 The CPM tool only addresses gamma emitters
 The CPM tool assumes uniform contamination
EPA
Page-35
For More Copies or Information
 Guidance documents are on Superfund Radiation Webpage:
» http://www.epa.gov/superfund/health/contaminants/radiation/index.htm
EPA/ITRC training on EPA Superfund radiation approach
» http://www.clu-in.org/conf/itrc/radscleanup_060507/
 Guidance documents for overall cleanup level issues are on
Superfund Remedy Decisions Webpage:
» http://www.epa.gov/superfund/policy/remedy/sfremedy/index.htm
 For further information or questions, Stuart Walker
» Phone: (703) 603-8748
» Fax: (703) 603-9133
» Email: [email protected]
EPA
Page-36
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EPA
Page-37
13
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