Detailed Information on the
EPA Radiation Protection Program Assessment

The Radiation Protection Program will continue work to improve the sharing of information and monitoring resources with DHS, DOE, other federal agencies, and the states. By June 30, 2008, the Program will provide a progress report and analysis of options for future efforts in this area that improve EPA's ability to contribute to interagency emergency response and environmental characterization during radiological emergencies.

By the end of September, the program will present an analysis of major radiological monitoring activity at EPA and other Federal agencies, exploring complementary efficiencies and potential redundancies.

Measure: Percentage of U.S. population in proximity to an ambient radiation monitoring system that provides scientifically sound data for assessing public exposure resulting from radiological emergencies.

Explanation:Measures improvement in U.S. population coverage by radiation monitors. Measures the percentage of U.S. population within 25 miles (40 km) of a radiation air monitor.

Measure: Level of readiness of radiation program personnel and assets to support Federal radiological emergency response and recovery operations (measured as percentage of radiation response team members and assets that meet scenario-based response criteria).

Explanation:Indicates level of readiness to support radiological monitoring and assessment during radiological emergency response and recovery operations. The level of readiness is assessed through criteria based on EPA's functional requirements under the National Response Framework and the National Contingency Plan.

Measure: Percentage of most populous U.S. cities with a RadNet ambient radiation air monitoring system, which will provide data to assist in protective action determinations.

Explanation:Indicates the coverage of the 100 larges U.S. cities in close proximity to a RadNet ambient radiation air monitor

Measure: Level of readiness of radiation program personnel and assets to support Federal radiological emergency response and recovery operations (measured as percentage of radiation response team members and assets that meet scenario-based response criteria).

Explanation:Indicates level of readiness to support radiological monitoring and assessment during radiological emergency response and recovery operations. The level of readiness is assessed through criteria based on EPA's functional requirements under the National Response Framework and the National Contingency Plan.

Measure: Level of readiness of national environmental radiological laboratory capacity (measured as percentage of laboratories adhering to EPA quality criteria for emergency response and recovery decisions).

Explanation:Indicates progress in identifying and developing radiological laboratory capacity and ensuring quality of the analytical data for emergency response and recovery decisions. The measure compares the number of Federal, state and commercial laboratories with assessed and verified capabilities to the projected need for laboratory capabilities modeled under the Homeland Security Council's Radiological Dispersion Device scenario.

Measure: Average time of availability of quality assured ambient radiation air monitoring data during an emergency.

Explanation:Indicates time in days between data collection and availability of data for release by EPA during emergency operations.

Measure: Time to approve site changes affecting waste characterization at DOE waste generator sites to ensure safe disposal of transuranic radioactive waste at WIPP (measured as percentage reduction from a 2004 baseline).

Explanation:Indicates the time to approve waste characterization program modifications at DOE waste generator sites.

Measure: Population covered by Radiation Protection Program monitors per million dollars invested.

Explanation:Indicates the annual level of population coverage and the cost of providing that coverage in terms of people per million dollars.

Is the program purpose clear?

Explanation: The purpose of EPA's Radiation Protection Program is to minimize unnecessary releases of radiation and to help mitigate impacts to human health and the environment should unwanted releases occur. The program includes three primary elements: 1) radiation monitoring and emergency response in the event of accidents or incidents involving nuclear or radiological material; 2) proper disposal of transuranic material releases from the Waste Isolation Pilot Plant, spent nuclear fuel, and high level waste, including establishing standards to protect the public from releases from radioactive materials stored or disposed of at the Yucca Mountain site; 3) establishing generally applicable standards and guidance to all Federal agencies for protection of the general environment from radioactive material.

Evidence: The most significant authorities for EPA's Radiation Protection Program are: ??The National Response Plan, Nuclear/Radiological Incident Annex, which defines radiation program monitoring and emergency response responsibilities for accidents or incidents involving nuclear or radiological material. See the National Response Plan, Nuclear/Radiological Incident Annex, page 27, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).]; ??The Waste Isolation Pilot Plant Land Withdrawal Act, which describes EPA's role in protecting the environment from radioactive (transuranic material) releases from a particular radiation waste site. See The Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA), S1671, Summary, http://thomas.loc.gov/cgi-bin/bdquery/z?d102:SN01671:@@@D&summ2=m&.; ??The Nuclear Waste Policy Act which provides the basis for the national program for the disposal of spent nuclear fuel and high level waste. See 4. 1982 Nuclear Waste Policy Act (42 USC 10101) Title 42, Chapter 108, Subchapter I, Part A, http://www4.law.cornell.edu/uscode/html/uscode42/usc_sec_42_00010141----000-.html; ??Reorganization Plan No. 3 (5) which defines the mission and functions of the EPA Radiation Program to include establishing generally applicable standards and guidance to all Federal agencies for protection of the general environment from radioactive material. See Reorganization Plan No.3, 1970, Section 2(a)(6), http://www.epa.gov/history/org/origins/reorg.htm; ??EPA Order 1110.2 (6) which defines the overall responsibilities of the EPA's Radiation Program. See EPA Order 1110.2, 12/1970, Number 11, http://www.epa.gov/history/org/origins/1110_2.htm; and ??The 1992 Energy Policy Act (7) directs EPA to develop standards to protect the public from releases from radioactive materials stored or disposed of at the Yucca Mountain site. See The 1992 Energy Policy Act, Section 801(a)(1), http://www.epa.gov/radiation/yucca/enpa92.htm.

Does the program address a specific and existing problem, interest, or need?

Explanation: The program addresses the need to minimize exposure to radiation through the monitoring and potential cleanup, disposal, and provision of guidance for the safe use of radioactive materials. Although many Americans are unlikely to be exposed to excessive radiation, the National Academy of Science (NAS) has endorsed a linear, no-threshold dose response relationship between radiation exposure and human cancer (1). Among the low-probability, high-consequence scenarios that EPA's Radiation Protection Program considers are foreign and domestic reactor releases, radioactive material releases from spacecraft, imported radioactively contaminated material, radiological dispersal device scenarios, and improvised nuclear device scenarios. Because of the potential high consequence of radiation release scenarios, the program includes RadNet, a national environmental radiation monitoring program as well as an environmental radiation response and recovery program (3,4,5). The program also oversees the safe disposal of radioactive waste to ensure that human health and the environment are protected (6,7,8). Additionally, understanding how to properly respond to a radiation release requires expertise in analyzing the potential environmental and human health risks. This analytical expertise provides a technical foundation to guide preparedness and response actions at the Federal, state, and local level -- including data analysis and support, laboratory standards, standards for waste disposal, emergency response protective action guides, and Federal guidance and technical reports.

Evidence: 1. "The committee concludes that current scientific evidence is consistent with the hypothesis that there is a linear, no-threshold dose-response relationship between exposure to ionizing radiation and the development of cancer in humans." Health Risks from Exposure to Low Levels of Ionizing Radiation: BIER VII - Phase 2 (2006), Executive Summary, page 15, http://www.nap.edu/openbook.php?record_id=11340&page=15. 2. 1982 Nuclear Waste Policy Act (42 USC 10131) Title 42, Chapter 108, Subchapter I, Part A, http://www4.law.cornell.edu/uscode/html/uscode42/usc_sec_42_00010131----000-.html. 3. The National Response Plan, Nuclear/Radiological Incident Annex, page 9, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 4. Foreign reactor release example, Chernobyl, http://www.epa.gov/radiation/rert/chernobyl.html. 5. Homeland Security Council Planning Scenarios: Executive Summaries, 2004, available locally as Scenarios_ExecSum_FINAL.pdf (196k pdf). 6. Implementation of the Waste Isolation Pilot Plant Land Withdrawal Act, FY 2004 Report to Congress, http://www.epa.gov/radiation/docs/wipp/402-r-06-001.pdf. 7. Radioactive Waste Disposal: An Environmental Perspective (EPA402-K-94-001) http://www.epa.gov/radiation/docs/radwaste/index.html. 8. Technical Basis for Yucca Mountain Standards (1995), National Academy of Sciences, http://books.nap.edu/catalog/4943.html#toc.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: EPA's Radiation Program is the only radiation program designed to provide national environmental radiation monitoring data, radiation standards for waste disposal, radiological emergency response cleanup support (short and long-term), and national consensus-based radiation risk guidance for use by Federal, state, and local agencies (1). The program provides information and standards to protect the public and the environment from potential disease causing radiation releases. Other Federal agencies have important yet different radiation roles, including DHS, DOE, DOD, NASA, and NRC, all of which are coordinating agencies under the National Response Plan for radiation incidents involving nuclear or radioactive material (2). EPA maintains a unique role as the coordinating agency for incidents involving foreign, unknown, or unlicensed radiological sources that may have an actual or perceived radiological consequence on the United States (3). EPA also has a unique role in overseeing DOE's radioactive waste disposal at the Waste Isolation Pilot Plant (4), and in setting standards for a high level nuclear waste repository.

Evidence: 1. See authorities cited under Question 1.1. 2. The National Response Plan, Nuclear/Radiological Incident Annex, Page 1, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 3. The National Response Plan, Nuclear/Radiological Incident Annex, Page 9, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 4. The Waste Isolation Pilot Plant (WIPP) Land Withdrawal Act, Summary, http://www.epa.gov/radiation/laws/laws_sum.htm#wipplwa.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The Radiation Program is free of major flaws that would limit its effectiveness or efficiency. The program works closely with the radiation scientific community, public and private stakeholders, as well as the general public. EPA utilizes scientific data and analysis from the National Academy of Sciences for developing guidance for risk analysis. This ensures that EPA's guidance is effective and based on sound science (1). In addition, the program requests public comments on significant changes in DOE's operation of radioactive waste disposal at the Waste Isolation Pilot Plant and on establishing criteria for certification and recertification of Waste Isolation Pilot Plant compliance with the disposal regulations (2). EPA uses the Science Advisory Board to evaluate aspects of the national radiation monitoring system (3). EPA also leads and participates in emergency response exercises to increase program effectiveness (4). EPA, along with other agencies with radiation responsibilities, uses the Interagency Steering Committee on Radiation Standards (ISCORS) to foster consensus and improve consistency in Federal radiation protection programs (5). EPA's Radiation Protection Program also has specific assignments under the Federal Radiological Protection Coordinating Committee to ensure proper coordination of emergency preparedness plans and activities (6). EPA also works with the National Response Team to ensure coordination of Federal radiological emergency response preparedness efforts across the National Response Plan and the National Oil and Hazardous Substances Pollution Contingency Plan (7).

Evidence: 1. EPA publications including: EPA Federal Guidance and Estimating Radiogenic Cancer Risks, http://www.epa.gov/radiation/assessment/pubs.html. 2. EPA 40 CFR PART 194 Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant's Compliance with the Disposal Regulations; Alternative Provisions, page 51930, http://www.epa.gov/radiation/docs/wipp/194_final-802_fr_wipp.pdf (170k pdf). 3. EPA SAB Report, Review of 2005 Agency Draft entitled "Expansion and Upgrade of the RadNet Air Monitoring Network, Vol. 1 & 2, Concept and Plan," Quality Review Draft, 8/17/06, http://epa.gov/sab/pdf/radnet_final_qual_rev_draft_08-17-06.pdf (504k pdf). 4. ER After Action reports: EPA Internal After Action Report - Exercise Southern Crossing 2006, available locally as southern-xing_aar.pdf (100k pdf). Radiological Response Deployables Demonstration (R2D2) After Action Report 2006, available locally as r2d2_aar.pdf (408k pdf). Dingo King After Action Report, 2005, available locally as dingo-king_aar.pdf (509k pdf). The 2004 Exercise Ruby Slippers After Action Report is available locally as ruby-slippers_aar.pdf (2.3M pdf). Top Officials (TOPOFF) Exercise Series: TOPOFF 2 After Action Summary Report For Public Release, 2003, http://www.dhs.gov/xlibrary/assets/T2_Report_Final_Public.doc. Joint Venture, SRS F-Tank Farm/FRMAC/Ingestion Pathway Exercise, 2005, page 32-33, EPA objectives, available locally as joint-venture.pdf (5.0M pdf). Operation River City Tabletop Exercise Workshop Notebook, 2003, Page 3-3 to 3-8, EPA Responsibilities, available locally as op-river-city.pdf (2.9M pdf). Kennedy Space Center, KSC-PLN-1903, Revision A, pages B 9-10, EPA Responsibilities. A file containing the report cover, the preface, and pages B 9-10 is available locally as KSC_1903_p9-10.pdf (41k pdf). EPA Full Scale WMD Exercise, EPA Region III, 2003, page ii, Introduction with participants. A file containing the report cover and the relevant pages is available locally as EPA_WMD-ex_03.pdf (305k pdf). 5. Interagency Steering Committee on Radiation Standards (ISCORS) Overview, http://www.iscors.org/about/overview.htm. 6. Federal Radiological Preparedness Coordinating Committee (FRPCC): Federal Emergency Management Agency (FEMA), Radiological Emergency Planning and Preparedness, 44 CFR Part 351, Sections 20 and 22, http://www.gpo.gov/nara/cfr/waisidx_03/44cfr351_03.html. 7. National Response Team, http://www.nrt.org/.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The Radiation Protection Program is designed to minimize unnecessary releases of radiation and be prepared to minimize impacts to human health and the environment should unwanted releases occur. The program is enhancing its radiation monitoring network by increasing the number of monitors and using specific siting criteria to characterize ambient radiation for more U.S. population centers and geographic areas (1). The program also has deployed monitors with real-time transmission capabilities, gamma spectrometry technology, as well as filter technology. This enhancement strengthens the response capabilities in the existing monitoring system and its ability to provide near real-time data directly to the states, local officials, and the Department of Homeland Security. In addition these enhancements facilitate rapid decision making in response to needs identified after "9/11" (2). With the information that the radiation monitoring program provides, health officials can guide the public to take essential actions to reduce exposures to radiation. In the event of a radiological release, the program is prepared to directly lead or support Federal, state, tribal, and local emergency responders, and continues to increase its readiness and capability in this area. The radiation waste program is targeted to fulfill EPA regulatory responsibilities and to respond to the Department of Energy requests for radioactive waste characterization approvals. The EPA waste characterization program is focused on inspecting DOE radioactive waste generator sites. The EPA program supports the DOE long-term/annual goals for disposal of transuranic waste at the Waste Isolation Pilot Plant (3). EPA recently revised its approval process for WIPP waste generator sites. The new process allows EPA and DOE more flexibility in obtaining EPA approval for disposal at WIPP without diminishing EPA's oversight responsibilities and without modifying EPA's technical approach (4). In addition, the program maintains strong analytical capabilities and expertise to support the efforts described above and to provide the Federal, state, and local radiological community with Federal Guidance and Technical Reports that characterize radiological risks to human health and the environment, outline cleanup levels, and provide emergency response protective action recommendations.

Evidence: 1. Expansion and Upgrade of RadNet air Monitoring Network Concept and Plan, 2005, Sections 3.6 and 5.5, http://www.epa.gov/radiation/docs/er/draft_radnet_plan-vol1.pdf (1.1M). 2. The National Response Plan, Nuclear/Radiological Incident Annex, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 3. DOE EM PART, transuranic waste measure, http://www.whitehouse.gov/omb/expectmore/detail.10001176.2005.html. 4. Criteria for the Certification & Recertification of the Waste Isolation Pilot Plant's Compliance with the Disposal Regulations; Alternative Provisions (69 FR 42571), http://www.epa.gov/radiation/docs/wipp/194finalrule.pdf (115k pdf).

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The Radiation Protection Program has long-term performance measures for its key program areas identified in EPA's Strategic Plan. These program areas include the U.S. ambient radiation monitoring program (RadNet) and the radiation emergency response program (1). EPA continues to use the Strategic Plan long-term measures for program assessment and improvement. The radiation monitoring measure supports the program's purpose by providing information that can be used to protect the public in the event of a release of radiation (2). With the information that the radiation monitoring program provides, health officials can guide the public to take essential actions to reduce exposure to radiation. The long-term measure, "Percentage of U.S. population in proximity to an ambient radiation monitoring system that provides scientifically sound data for assessing public exposure resulting from radiological emergencies," accounts for radiation monitors in both rural and urban areas including the most populous U.S. cities (3). The long-term readiness measure for emergency response is meaningful because it provides a comprehensive assessment of EPA's personnel and asset readiness in the event of a radiation emergency (4). The initial response and long-term support that the Radiation Protection Program provides will assist state and local agencies to take informed actions to reduce exposure from radiation (5). These measures are classified as level 2 intermediate outcomes based on the GAO Hierarchy of Indicators since collection of data and personnel readiness are actions being taken to protect human health and welfare. (6)

Evidence: 1. 2006-2011 EPA Strategic Plan, Goal 1.4: Radiation, pages 21-22, http://www.epa.gov/ocfopage/plan/plan.htm. 2. RadNet Monitoring System Measurement Implementation Plan, Long-term Outcome, System Coverage, available locally as MIP-RN_lt-outcome.pdf (26k pdf). 3. Expansion and Upgrade of RadNet air Monitoring Network Concept and Plan, 2005, Section 5.5, http://www.epa.gov/radiation/docs/er/draft_radnet_plan-vol1.pdf (1.1M). 4. Emergency Response Preparedness Evaluation Criteria and 2006 Evaluation, both available locally as ER_eval-criteria.pdf (53k pdf) and ER_2006_evaluation.pdf (20k pdf). 5. Radiological Emergency Response Measurement Implementation Plan, Long-term Outcome, Readiness, available locally as MIP-ER_lt-outcome.pdf (40k pdf). 6. GAO "Managing for Results: EPA Faces Challenges in Developing Results-Oriented Performance Goals and Measures." April 2000. GAO/RCED-00-77

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The baseline for the long-term RadNet radiation monitoring goal in 2001 has 22% of the U.S. population in proximity to a RadNet ambient radiation monitoring system (1). EPA has baseline ambient radiation monitoring data that dates back to the 1970s and provides a reliable history about background ambient radiation. This history of radiation data is used for determining whether ambient radiation levels have increased and provides a basis for taking essential actions to reduce radiation exposure. The 2011 goal of 55% coverage is based on tripling the total number of radiation air monitors while replacing some legacy monitors with near real-time monitors. This goal is ambitious given the complexity of siting the monitors but should be achievable by working closely with state and local partners. The baseline for the emergency response program level of readiness in 2005 is 50% (2). This level of readiness indicates EPA's ability to provide response and support to the public in a radiation emergency (3). Reaching and maintaining the 2011 goal of 90% readiness will require significantly increasing radiation personnel readiness while upgrading and maintaining fixed and mobile assets within a fixed budget. This goal is also supported by our efforts to increase laboratory capacity and ensure quality of analytical data for emergency response decisions (4).

Evidence: 1. RadNet Monitoring System Measurement Implementation Plan, Long-term Outcome, System Coverage, available locally as MIP-RN_lt-outcome.pdf (26k pdf). 2. Radiological Emergency Response Measurement Implementation Plan, Long-term Outcome, Readiness, available locally as MIP-ER_lt-outcome.pdf (40k pdf). 3. Emergency Response Preparedness Evaluation Criteria and 2006 Evaluation, both available locally as ER_eval-criteria.pdf (53k pdf) and ER_2006_evaluation.pdf (20k pdf). 4. Memorandum of Agreement for an Integrated Consortium of Laboratory Networks (ICLN), 2005, http://www.epa.gov/sab/pdf/signed_icln_memo_of_agreement_june-6-2005.pdf (3.5M pdf).

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The Radiation Protection Program has established annual measures which support each of the key radiation program elements. To track its implementation of a new inspection and approval process for the Waste Isolation Pilot Plant (1), the program is measuring the annual percent reduction in time to make decisions about on-site changes at DOE waste generator sites for safe disposal of radioactive waste. To track progress in deploying radiation monitoring stations in a way that front-loads risk reduction benefits, the ambient radiation air monitoring system has established annual targets for the percent of the 100 most populous U.S. cities with environmental radiation monitoring systems (2). This measures the program's progress in implementing the long-term outcome goal's strategy of deploying radiation monitoring stations in a way that focuses early on the most populous U.S. cities. The program also has annual goals for the average time between data collection and data availability during an emergency (3). This measure tracks both the roll-out of new monitors and the new system's efficiency gains in terms of data turnaround and ensures ambient air monitoring data is available to Federal and state agencies and the public in a timely manner. The Radiation Program also tracks the level of readiness of radiation program personnel and assets to support Federal radiological emergency response and recovery under the National Response Plan (4) on an annual basis. Annual systematic increases in readiness provide direct contribution to the long-term outcome of program readiness. The program is also tracking on an annual basis the percent of the national environmental laboratory capacity that can provide quality radiation analyses for emergency response and recovery decisions (5). Last, the program measures efficiency by tracking population covered by Radiation Protection Program monitors per million dollars invested (6). The annual measures assess program progress toward providing surge response capability and laboratory data during a radiation incident. These measures are classified as level 2 intermediate outcomes based on the GAO Hierarchy of Indicators since collection of data and personnel readiness are actions being taken to protect human health and welfare (7).

Evidence: 1. Waste Isolation Pilot Plant (WIPP) Measurement Implementation Plan, Annual Output, available locally as MIP-WIPP_ann-eff.pdf (25k pdf). 2. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome, Most Populous Cites, available locally as MIP-RN_ann-outcome.pdf (26k pdf). 3. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome/Efficiency, Data Availability, available locally as MIP-RN_ann-eff.pdf (27k pdf). 4. Radiological Emergency Response Measurement Implementation Plan, Annual Outcome, Readiness, available locally as MIP-ER_ann-outcome.pdf (40k pdf). 5. Radiological Emergency Response Measurement Implementation Plan, Annual Output, Laboratory Capacity, available locally as MIP-ER_ann-output.pdf (27k pdf). 6. Radiation Protection Program Measurement Implementation Plan, Annual Efficiency, Population Covered/$M, available locally as MIP-RPP_ann-eff.pdf (23k pdf). 7. GAO "Managing for Results: EPA Faces Challenges in Developing Results-Oriented Performance Goals and Measures." April 2000. GAO/RCED-00-77

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The Radiation Protection Program has baselines and ambitious targets for each of its annual measures. The baseline for EPA's ambient radiation air monitoring program for the 100 most populous cities with radiation monitors is 55% in 2005. In 2007 the percentage of the most populous cities with radiation air quality information is targeted to increase to 80% (1). This is an ambitious target because the program is not only increasing the percentage of cities with radiation monitors, but the program is also replacing legacy monitors with near real-time monitors. The annual measure of data availability quantifies both the increased percent of near real-time monitors in the system and the effect of that increase on the availability of data during an emergency (2); the targets in this area are ambitious because they directly impact ability to protect human health and the environment in a timely way. Maintaining the current radiation monitoring system and adding additional near real-time monitors also relies on increasing state and local government support. The baseline for the radiological emergency response program level of readiness was 50% in 2005. In 2009, program readiness is targeted to be at 90% (3). This is ambitious because it represents the simultaneous improvement of laboratory capability assets including radiation monitoring equipment as well as increased personnel readiness. The Radiation Protection Program has also developed annual goals for increasing the national laboratory capacity that can provide quality radiation data for emergency response environmental samples (4); starting from a 2005 0% baseline, the program is targeting highly ambitious improvements in this area, achieving 20% in 2007 and ultimately reaching 60% in 2010. The baseline for the Waste Isolation Pilot Plant's waste generator site inspection and approval process is 0% in 2004 (when the revised requirements took effect). In 2007, the percent reduction in approval time is targeted to reach 40% (5). This is an ambitious target because it uses the Agency's ability to build upon already established methodologies and lessons learned to more efficiently manage the continued regulation of an ever-increasing amount of properly disposed waste. This decrease in approval time shows that the program is facilitating clean up of radioactive material at DOE waste generator sites more rapidly. Last, the program's annual efficiency measure tracks population covered by Radiation Protection Program monitors per million dollars invested; the program aims to reduce the equivalent of a 33 cents per person covered 2001 baseline to 17 cents per person in 2010 (6).

Evidence: 1. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome, Most Populous Cites, available locally as MIP-RN_ann-outcome.pdf (26k pdf). 2. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome/Efficiency, Data Availability, available locally as MIP-RN_ann-eff.pdf (27k pdf). 3. Radiological Emergency Response Measurement Implementation Plan, Annual Outcome, Readiness, available locally as MIP-ER_ann-outcome.pdf (40k pdf). 4. Radiological Emergency Response Measurement Implementation Plan, Annual Output, Laboratory Capacity, available locally as MIP-ER_ann-output.pdf (27k pdf). 5. Waste Isolation Pilot Plant (WIPP) Measurement Implementation Plan, Annual Output, available locally as MIP-WIPP_ann-eff.pdf (25k pdf). 6. Radiation Protection Program Measurement Implementation Plan, Annual Efficiency, Population Covered/$M, available locally as MIP-RPP_ann-eff.pdf (23k pdf).

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The Radiation Protection Program works very closely with its Federal and state partners and provides funding to the Conference of Radiation Control Program Directors (CRCPD), a non-profit body that furthers EPA's long-term radiation protection goals (1). For the radiation monitoring program, state and local counterparts work directly with EPA to operate and maintain the RadNet system. State and local governments are providing assistance operating the monitoring stations at over 75 percent of the stations (58% state, 21% local). EPA is also a coordinating agency under the National Response Plan for incidents involving nuclear or radioactive material. DHS, DOE and other Federal coordinating agencies under the National Response Plan coordinate with EPA. Federal (e.g. DHS, DOE, DOD), state and local agencies all participate along with EPA in radiological emergency response training exercises. Additional examples of coordination (2) include increasing the radiological incident response laboratory capacity by working with DHS and nine other Federal agencies through the Integrated Consortium of Laboratory Networks (3). DOE also works closely with EPA on radioactive waste disposal to meet the long-term goal of safe radioactive waste disposal at the Waste Isolation Pilot Plant. EPA coordinates compliance inspections with DOE audits and works together with DOE to resolve deficiencies by pursuing corrective measures (4).

Evidence: 1. Conference of Radiation Control Program Directors, http://www.crcpd.org/. 2. The National Response Plan, Nuclear/Radiological Incident Annex, Page 1, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 3. Memorandum of Agreement for an Integrated Consortium of Laboratory Networks (ICLN), 2005, http://www.epa.gov/sab/pdf/signed_icln_memo_of_agreement_june-6-2005.pdf (3.5M pdf). 4. Implementation of the Waste Isolation Pilot Plant Land Withdrawal Act, FY 2004 Report to Congress, http://www.epa.gov/radiation/docs/wipp/402-r-06-001.pdf.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Program-wide independent surveys are not conducted on a regular basis. However, the Radiation Protection Program does conduct project-specific evaluations. The Radiation Protection Program has collaborated with EPA's Science Advisory Board and the CRCPD to conduct independent evaluations of RadNet, the ambient radiation air monitoring program. The SAB evaluated the expansion and upgrade of the RadNet system in 2006 (1). The CRCPD evaluation included an assessment of monitor location selection, use of the system, and recommendations for system enhancement (2). [The CRCPD is a nonprofit non-governmental professional organization dedicated to radiation protection. CRCPD's membership is made up of radiation professionals in state and local government who regulate the use of radiation sources (3).] For the radioactive waste disposal program, independent evaluations are completed formally through public discussions with stakeholders and public comment on important EPA actions such as the oversight of waste disposal at the Waste Isolation Pilot Plant. Public input is also sought officially on important EPA actions such as WIPP recertification and waste approvals, and EPA holds discussions with stakeholders (e.g., States, local governments, interest groups) concerning major agency actions affecting New Mexico residents (4). For EPA's emergency response program, EPA participates in at least one formally evaluated interagency exercise that tests our radiological readiness capabilities each year. At the completion of each exercise an After Action report is completed (5).

Evidence: 1. EPA SAB Report, Review of 2005 Agency Draft entitled "Expansion and Upgrade of the RadNet Air Monitoring Network, Vol. 1 & 2, Concept and Plan," Quality Review Draft, 8/17/06, http://epa.gov/sab/pdf/radnet_final_qual_rev_draft_08-17-06.pdf (504k pdf). 2. Conference of Radiation Control Program Directors, 2005 Survey: Summary of Survey Results, available locally as CRCPD_05survey-sum.pdf (164k pdf). 3. Conference of Radiation Control Program Directors, http://www.crcpd.org/. 4. Recertification Application Notice of Availability & Opening of Public Comment Period (69 FR 29646), http://www.epa.gov/EPA-AIR/2004/May/Day-24/a11765.htm. Proposed Approval of Central Characterization Project's TRU Waste Characterization Program at the Savannah River Site Notice of Availability & Opening of Public Comment Period (71 FR 13592), http://www.epa.gov/fedrgstr/EPA-AIR/2006/March/Day-16/a3813.htm. 5. ER After Action reports: EPA Internal After Action Report - Exercise Southern Crossing 2006, available locally as southern-xing_aar.pdf (100k pdf). Radiological Response Deployables Demonstration (R2D2) After Action Report 2006, available locally as r2d2_aar.pdf (408k pdf). Dingo King After Action Report, 2005, available locally as dingo-king_aar.pdf (509k pdf). The 2004 Exercise Ruby Slippers After Action Report is available locally as ruby-slippers_aar.pdf (2.3M pdf). Top Officials (TOPOFF) Exercise Series: TOPOFF 2 After Action Summary Report For Public Release, 2003, http://www.dhs.gov/xlibrary/assets/T2_Report_Final_Public.doc. Joint Venture, SRS F-Tank Farm/FRMAC/Ingestion Pathway Exercise, 2005, page 32-33, EPA objectives, available locally as joint-venture.pdf (5.0M pdf). Operation River City Tabletop Exercise Workshop Notebook, 2003, Page 3-3 to 3-8, EPA Responsibilities, available locally as op-river-city.pdf (2.9M pdf). EPA Full Scale WMD Exercise, EPA Region III, 2003, page ii, Introduction with participants. A file containing the report cover and the relevant pages is available locally as EPA_WMD-ex_03.pdf (305k pdf).

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: EPA's Radiation Protection Program budget request is tied to the accomplishment of annual and long-term performance goals set within the framework of the program and projects, and in accordance with EPA's Strategic Plan. The Radiation Protection Program estimates and budgets for the full annual costs of operating its programs, taking into consideration any changes in funding, policy, or legislation. All spending categories, the resource levels and activities associated with them, are included in the annual Congressional Justification (1). EPA's Congressional Justification is structured around the strategic planning framework to link environmental goals to resources. The program/projects structure provides a more specific level of detail for program resources and performance information. EPA removed all reference to GPRA performance goals and measures per OMB passback to EPA in FY 2006. EPA will include measures once they have been negotiated with OMB.

Evidence: 1. EPA's FY 2008 Annual Performance Plan and Congressional Justification, http://epa.gov/ocfo/budget/2008/2008cj.htm. See Environmental Program and Management, Radiation: Protection, page 21 and Radiation: Response Preparedness, page 23, http://epa.gov/ocfo/budget/2008/epm.pdf (1.6M pdf). Also see Science and Technology, Radiation Protection (page 18), Radiation Response Preparedness (page 20), and Homeland Security Preparedness, Response, Recovery (page 33), http://epa.gov/ocfo/budget/2008/sciencetech.pdf (663k pdf).

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: After September 11, 2001, the Radiation program identified strategic planning deficiencies in the ambient radiation monitoring program and the national radiological laboratory capability program. The program is correcting these deficiencies. Post 9/11, it became apparent that the ambient radiation monitoring program needed to provide decision makers with data more quickly and improve its ability to assess the widespread impacts of a radiation incident. The program is correcting this deficiency by replacing and supplementing legacy monitors with near real-time monitors and deploying additional monitors to increase population and geographic coverage (1, 2). Deficiencies in the national laboratory capability program were identified in EPA's Aftermath of September 11, 2001 Lessons Learned Report (3). The program is correcting this deficiency by providing guidance and training to increase environmental radiological laboratory capacity adhering to quality criteria for emergency response and recovery decisions (4). In order to make the Radiation Program's planning more strategic, the program is identifying and considering emerging challenges and opportunities related to radiation protection. In developing the Future of Radiation Protection: 2025 report, the Institute for Alternative Futures, with EPA support, studied the most important radiation protection-related challenges and opportunities that may emerge through 2025. The project relied on input from state, local, Tribal, and public sector organizations to define upcoming challenges (5). The program has made steady progress over the past few years to encourage the use of futures analysis in the planning process. By early identification of issues that could impact on radiation protection, the program can better respond to and take advantage of new trends, circumstances and technologies. The Future of Radiation Protection: 2025 report identifies over 100 emerging radiation issues between now and 2025 (6).

Evidence: 1. Expansion and Upgrade of RadNet air Monitoring Network Concept and Plan, 2005, Section 1.4, pages 5-6, http://www.epa.gov/radiation/docs/er/draft_radnet_plan-vol1.pdf (1.1M). 2. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome, Most Populous Cites, available locally as MIP-RN_ann-outcome.pdf (26k pdf). 3. EPA Lessons Learned in the Aftermath of September 11, 2001, 2002, page ES-6, is available locally as ll_chapters.pdf (234k pdf). 4. Radiological Emergency Response Measurement Implementation Plan, Annual Output, Laboratory Capacity, available locally as MIP-ER_ann-output.pdf (27k pdf). 5. Future of Radiation Protection: 2025, Appendix A, Participants and Contributors, http://www.epa.gov/radiation/docs/futures/future_2025.pdf (806k pdf). 6. Future of Radiation Protection: 2025, http://www.epa.gov/radiation/docs/futures/future_2025.pdf (806k pdf).

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The Radiation Protection Program regularly collects performance information through customer and partner reviews. The program co-chairs quarterly meetings through ISCORS (1-5) and its subcommittees to review program needs and products. Feedback from Federal partners and customers is incorporated into program plans and products including radiation risk guidance in Federal Guidance Reports (6), radiation sampling guidance in the Multi-Agency Radiation Survey and Site Investigation Manual, (MARSSIM) (7-10), and radiation laboratory guidance Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP) (11) and the Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (MARSAME) (12). Program reviews through ISCORS promote consistent guidance for use in emergency response, radiation monitoring, and ongoing radiation site cleanup. The development of consensus based documents such as Federal Guidance Reports, MARSSIM, MARLAP, and MARSAME with key program partners including DOE, NRC, DOD, and DHS improve program performance and consistency across Federal programs and allow EPA to provide response support during a radiation incident. The Waste Isolation Pilot Plant, WIPP, project undergoes independent evaluations and reviews of the design, construction and operations of WIPP, as they relate to the protection of public health and safety and the environment (Public Law 100-456, 102 Stat. 1918, 2073, National Defense Authorization Act , Fiscal Year 1989). In addition, the National Research Council has provided scientific and technical evaluations of WIPP since 1978. The Radiation Program uses findings from these evaluations to assess our regulatory actions and processes (13). The Radiation Program also receives performance data from all participants at the conclusion of emergency response exercises. Effectiveness of communications, incident mitigation, team structure and roles and responsibilities are critically assessed and adjustments to the Emergency Response Plan are made based on this performance data. As a result of the TOPOFF Exercise, the Consequence Management Subgroup (CMS) was formed to address the development of a unified cleanup approach and consistent plume modeling procedures. Evaluations of the performance data from the Tokimura, Japan radiation accident and the Los Alamos and Hanford area wildfires responses have been incorporated into planning efforts to enhance future emergency response capabilities.

Evidence: 1. ISCORS, Interagency Steering Committee on Radiation Standards, http://www.iscors.org/index.htm. 2. ISCORS Overview, http://www.iscors.org/about/overview.htm. 3. ISCORS Committees, http://www.iscors.org/subcommittee/. 4. ISCORS September 2005 Public Meeting Agenda, Topics include: MARSSIM, BEIR VII, http://www.iscors.org/about/news.htm. 5. ISCORS meeting minutes from 2003, http://www.iscors.org/about/meetings.htm. 6. EPA Federal Guidance, http://www.epa.gov/radiation/federal/about.htm#what_is. 7. Multi-Agency Radiation Survey and Site Investigation Manual, MARSSIM, http://www.epa.gov/radiation/marssim/. 8. MARSSIM Meetings, http://www.epa.gov/radiation/marssim/meetings.htm. 9. MARSSIM Frequently General Questions, http://www.epa.gov/radiation/marssim/faqs.htm. 10. Agencies which developed MARSSIM, http://www.epa.gov/radiation/marssim/faqs.htm#faq1_2. 11. Multi-Agency Radiological Laboratory Analytical Protocols Manual, MARLAP, http://www.epa.gov/radiation/marlap/about_marlap.htm#marlap_necessary. 12. Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (MARSAME), 2006, Cover page, Abstract, and page 1 of Table of Contents, is available locally as marsame3.pdf (1.4m pdf). 13. Committee on the Waste Isolation Pilot Plant, Board on Radioactive Waste Management, National Research Council, http://fermat.nap.edu/openbook/0309069289/html/index.html.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: EPA managers and staff with fiduciary responsibilities have performance standards which specifically hold them accountable for cost, schedule, and performance results (1). The Radiation Program currently has no active grants. The program does have several Interagency Agreements. For example, an agreement with DOE shows that EPA will provide cost effective, timely, and high quality performance results (2). Contractual statements of work and individual work assignments include cost schedules, specified deliverables and due dates, and clearly articulated outcomes (3). Contractors are held accountable for costs, schedule, and performance results through the written terms of the contracts, work assignments, and technical directives. The program tracks contractor progress through required monthly status/cost reports for each project. EPA conducts an annual performance evaluation which addresses the quality of products and services, cost controls, timeliness of performance, and business relations. The program also conducts on-site visits of contractor facilities to ensure that the facility is maintained and managed according to the terms and clauses written in the contract (4).

Evidence: 1. Sample Performance Standards, Radiation Program Managers and Staff with Fiduciary Responsibilities: a) Budget Operations Officer, pages 3-5, available locally as budget_ops.pdf (6.6M pdf); b) Associate Radiation Protection Division Director, pages 3, 6, 7, available locally as assocdir.pdf (13.2M pdf); c) Administrative Officer, pages 6, 10, available locally as adminoff.pdf (8.5M pdf). 2. Sample WIPP IAG Statement of Work, available locally as wippiag.pdf (4.0M pdf). 3. Sample Contract Work Assignments. a) Work Assignment 2-02, Concept of Operations for the Radiological Emergency Response Team, available locally as conops_wa.pdf (1.6M pdf). b) Work Assignment No. 2-08, RadNet Deployables Tabletop and Field Exercises, available locally as deployables-fx_wa.pdf (2.4M pdf). 4. Sample Progress Reports. a) Work Assignment No. 2-02, Concept of Operations for the Radiological Emergency Response Team, available locally as conops_prog.pdf (110k pdf). b) Work Assignment No. 2-08, RadNet Deployables Tabletop and Field Exercises, available locally as deployables-fx_prog.pdf (97k pdf).

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: The Radiation Program routinely obligates approximately 95% of its financial resources each fiscal year, typically reserving a nominal amount as carryover. For example, in FY 2006, the end of year status of funds report reflected that the program had committed and obligated 94.9% of its financial resources. That percentage was also confirmed in the Agency's end of fiscal year report provided mid-October (1). Prior to the beginning of each fiscal year, the program develops an operating plan that reflects how it plans to spend its budget allocation as requested in the President's Budget, and allocates resources by strategic plan goal, objective, program/project, and budget object class. The program then adjusts the operating plan to reflect appropriated levels of funding (2,3). The program regularly tracks spending through tracking spreadsheets, and EPA's budget and annual Operating Plan are aligned with the Agency's Strategic Plan, approved by OMB, and sent to Congressional Appropriations Committees. EPA tracks its obligations and expenditures in the Agency's Integrated Financial Management System (IFMS) through the Financial Data Warehouse (FDW) against the Operating Plan allocations (4).

Evidence: 1. FY 2006 13th Month Status of Funds, 10/10/06, available locally as 06_13th-month.pdf (55k pdf). 2. Radiation Protection Program FY 2006 Operating Proposal, available locally as 06_prog_op-prop.pdf (234k pdf). 3. FY06 Radiation Program Budget Summary, available locally as 06_bud_summary.pdf (23k pdf). 4. The Agency's Integrated Financial Management System (IFMS) provides complete data on expenditures of funds.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: EPA's Radiation Protection Program tracks efforts to increase program efficiency and cost effectiveness. For the program as a whole, we compare the increase in percentage of U.S. population covered by the RadNet monitoring system in relation to any changes in the full program budget. As an annual efficiency measure, we calculate the population covered by Radiation Protection Program monitors per million dollars invested (1). This measure reflects the annual level of population coverage and the cost of providing that coverage in terms of people per million dollars. In addition, the program tracks process and time oriented measures for two of its program elements, as part of an effort to streamline processing and make sure that the program can provide data quickly when required.(2, 3). The first of these annual efficiency measures tracks the time taken by EPA to approve site changes that affect waste characterization at DOE waste generator sites, as a means of ensuring safe disposal of transuranic radioactive waste at WIPP (measured as percentage reduction from a 2004 baseline). Another annual efficiency measure tracks the average time EPA takes to provide ambient radiation monitoring data during an emergency. This is measured as days between data collection and availability of data for release by EPA during emergency operations.

Evidence: 1. Radiation Protection Program Measurement Implementation Plan, Annual Efficiency, Population Covered/$M, available locally as MIP-RPP_ann-eff.pdf (23k pdf). 2. Waste Isolation Pilot Plant (WIPP) Measurement Implementation Plan, Annual Output, available locally as MIP-WIPP_ann-eff.pdf (25k pdf). 3. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome/Efficiency, Data Availability, available locally as MIP-RN_ann-eff.pdf (27k pdf).

Does the program collaborate and coordinate effectively with related programs?

Explanation: The Radiation Program collaborates and coordinates with Federal and state Partners through the use of the Interagency Steering Committee on Radiation Standards (ISCORS) (1). The group meets quarterly and its goal is to improve consistency in Federal radiation protection programs. EPA co-Chairs ISCORS and members include: EPA, NRC, DOE, DOD, HHS, DOL, DOT, and DHS. Two collaborative efforts which demonstrate effective coordination include the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (2) and the Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP) (3). To effectively coordinate an emergency response activity, close coordination with DHS, DOE, NRC, and DOT is critical to the response, mitigation, and recovery phases of an incident. Radiological planning and preparedness goals have been established by the Federal Radiological Preparedness Coordinating Committee (FRPCC) (4). Collaborative emergency response efforts include the Federal Radiological Monitoring and Assessment Center (FRMAC), the National Response Plan Nuclear/Radiological Incident Annex, and the National Response Team (NRT). The WIPP approval process for radioactive waste requires effective coordination between the Radiation Program and the Department of Energy; the reduction in time for approvals is facilitated by active communication between the two agencies (5). In addition, the national environmental radiation monitoring program, RadNet, collaborates with state and local officials to maintain and operate the national network of air monitors (6).

Evidence: 1. ISCORS, Interagency Steering Committee on Radiation Standards, http://www.iscors.org/index.htm; ISCORS Overview, http://www.iscors.org/about/overview.htm; ISCORS Committees, http://www.iscors.org/subcommittee/. 2. Multi-Agency Radiation Survey and Site Investigation Manual, MARSSIM, http://www.epa.gov/radiation/marssim/. 3. Multi-Agency Radiological Laboratory Analytical Protocols Manual, MARLAP, http://www.epa.gov/radiation/marlap/about_marlap.htm#marlap_necessary. 4. FRPCC, EPA roles defined in 351.22, http://www.epa.gov/rpdweb00/rert/more_authorities.htm#regulations. 5. WIPP Docket A98-49, especially II-B2 and II-B3, http://www.epa.gov/radiation/wipp/a9849_index.htm. 6. RadNet Siting Plans, Agreements. Site evaluation for Memphis, TN, available locally as memphis_site-eval.pdf (1.5M pdf). Site evaluation for Harrisburg, PA, available locally as harrisburg_site-eval.pdf (169k pdf). Site evaluation for Fresno CA, available locally as fresno_site-eval.pdf (266k pdf).

Does the program use strong financial management practices?

Explanation: The Radiation Protection Program establishes an annual operating plan for each fiscal year that ties in with our strategic goals and measures and is linked to the comprehensive EPA Operating Plan approved by OMB and sent to Congress annually. In addition to routine, regular tracking and monthly review of expenditures (1), the program conducts a thorough mid-year review to assess progress against the operating plan, reconcile deviations, and establish mid-course corrections if needed (2). At the end of the fiscal year, the program's financial performance is rolled into Agency-wide financial statements. The Radiation Protection Program follows EPA's financial management guidance for committing, obligating, reprogramming, and reconciling appropriated funds. Managers and staff with fiduciary responsibilities take all required training and have fiduciary responsibilities written into their performance standards (3). The program ensures that all staff responsible for approving purchases, committing funds, and reviewing invoices are properly trained and certified (4, 5). EPA received an unqualified audit opinion on its FY 2006 and FY 2005 financial statements and had no material weaknesses associated with the audit (6).

Evidence: 1. FY 2006 Allocation and Year End Status of Funds Report, available locally as 06_13th-month.pdf (55k pdf). 2. FY 2006 Radiation Program Mid-Year Review and Resource Status, summarized locally in the following files: 06_Rad-MidYear.pdf (220k pdf), 06_ER-Midyear.pdf (219k pdf), 06_RadNet-MidYear.pdf (162, pdf), and 06_Rad-Prog-Midyear_xls.pdf (22k pdf). 3. Sample Performance Standards, Radiation Program Managers and Staff with Fiduciary Responsibilities. a) Budget Operations Officer, pages 3-5, available locally as budget_ops.pdf (6.6M pdf), b) Associate Radiation Protection Division Director, pages 3, 6, 7, available locally as assocdir.pdf (13.2M pdf). 4. Sample of critical element for bankcard holder and COR certification, Administrative Officer, pages 6, 10, available locally as adminoff.pdf (8.5M pdf). 5. Sample of Contracting Officer's Representative appointment, available locally as wacor.pdf (854k pdf). 6. Audit of EPA's Fiscal 2006 and 2005 consolidated Financial Statements, Audit Report 2007-1-00019, http://www.epa.gov/oig/reports/2007/20061115-2007-1-00019.pdf (1.3M pdf).

Has the program taken meaningful steps to address its management deficiencies?

Explanation: No material weaknesses have been identified for the Radiation Protection Program under the Federal Managers Financial Integrity Act of 1982 (FMFIA) (1). In addition to FMFIA, the program annually reviews practices and processes to identify program areas, management practices, and policies that would benefit from an Inspector General audit or evaluation (2). While the Radiation Protection Program has not recently identified any program areas for an IG audit, the "Critical Infrastructure and Key Resource Protection Plan" (CIPP) report to the Office of Management and Budget prompted the IG to conduct an audit to determine EPA status in implementing initiatives and meeting milestones listed in the CIPP. In addition, the IG evaluated issues identified in the report, "EPA Needs to Better Manage Counter Terrorism/Emergency Response Equipment" (3). EPA has already addressed many of the issues identified in the draft report. Specifically, EPA is updating its monitoring network to identify radioactive contaminants so that early public health decisions can be made in the event of a radiological incident. EPA is also making facility and equipment updates to its analytical laboratories in Montgomery and Las Vegas to support emergency response. The program also annually performs two formal program reviews and briefings for the Office Director that include discussion of management practices and policies (4).

Evidence: 1. FY 2006 FMFIA letters, available locally as fy06fmfia.pdf (1.7M pdf). 2. ORIA summary of FMFIA Assurance Processes, available locally as fmfia_summary.pdf (55k pdf). 3. Draft Audit Report, Assignment No. 2005-001262, 2/24/06, "EPA Needs to Better Implement Plan for Protecting Critical Infrastructure and Key Resources Used to Respond to Terrorist Attacks and Disasters" (Draft - not to be released outside of EPA - Homeland Security Information, sensitive but unclassified). 4. Radiation Protection Program FY 2006 Operating Proposal, available locally as 06_prog_op-prop.pdf (234k pdf). FY 2006 Radiation Protection Program Mid-Year Review and Resource Status, summarized locally in the following files: 06_Rad-MidYear.pdf (220k pdf), 06_ER-Midyear.pdf (219k pdf), 06_RadNet-MidYear.pdf (162, pdf), and 06_Rad-Prog-Midyear_xls.pdf (22k pdf).

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The Radiation Program has developed and is using long-term goals for measuring the population coverage of the radiation national monitoring program and the emergency response readiness program. In 2001 approximately 22% of the U.S. population was covered by the RadNet ambient radiation air monitoring system. EPA's long-term performance goal is 55% of the population (1). The program was on target in 2006, with approximately 32% of the U.S. population covered by the RadNet system. The program has established site plans and agreements with state and local officials for installing new radiation monitoring systems scheduled for 2007 which will continue progress toward the long-term performance goal. The long-term emergency response measure, level of readiness of radiation program personnel and assets was 50 percent in 2005 (2,3). In 2006, the level of readiness was raised to 78% as a result of the high priority placed on emergency response readiness by the Radiation Protection Program. In order to continue progress toward increasing the long-term level of readiness, the program purchased 40 radiation monitoring deployable units for the Radiological Emergency Response Team. The addition of these radiation monitoring deployable units for area-specific use during an emergency has significantly upgraded the environmental radiation monitoring network currently in place and allows more focused data to be collected during an emergency.

Evidence: 1. RadNet Monitoring System Measurement Implementation Plan, Long-term Outcome, System Coverage, available locally as MIP-RN_lt-outcome.pdf (26k pdf). 2. Radiological Emergency Response Measurement Implementation Plan, Long-term Outcome, Readiness, available locally as MIP-ER_lt-outcome.pdf (40k pdf). 3. The current criteria used for the readiness assessments are available locally as ER_eval-criteria.pdf (53k pdf).

Does the program (including program partners) achieve its annual performance goals?

Explanation: The Radiation Program has achieved its annual performance goals for increasing the percent of the most populous cities with ambient radiation air monitoring systems and placing systems in the most populous cities with the highest risks. In 2005, 55% of the most populous 100 cities were covered by the radiation ambient air monitoring system, as measured by a 100-mile radius of the monitor location (1). In addition, EPA exceeded its annual performance goal for 2006 by covering 67% of the 100 most populous cities with radiation monitoring systems. Accomplishing this required establishing new site plans for the ambient radiation monitors and evaluating new potential monitor locations with our state and local partners (2). The program has also established contracts for monitor deployment (3). The radiological emergency response program anticipates a 30% increase in the level of readiness over a three year period; this entails increasing laboratory capability assets (fixed and mobile), including monitoring equipment and personnel readiness (4). Starting with a 2005 baseline of 50% readiness, the program has exceeded its 2006 75% target by 4%. The Radiation Protection Program also is achieving its goals for improving national environmental radiological laboratory capacity readiness (5). Laboratory readiness under the new program went from a 0% baseline in 2005 to its target of 7% in 2006. The Radiation Protection Program also has established and is implementing a new DOE radioactive waste generator site approval process and has reduced the approval time for this process. The decrease in the approval time directly affects the cleanup of radioactive material at DOE sites. The program has established an annual performance goal for the percent reduction in time to make decisions about on site changes at DOE waste generator sites for safe disposal of radioactive waste. In 2006 the program achieved a 33% reduction in the inspection/approval time (6). Last, the program measures population covered by Radiation Protection Program monitors per million dollars invested. The program covered 3.5 people per dollar in 2006 against a target of 3.2 people per dollar; this reflects a 14 percent reduction in cost per person covered since 2001 (7).

Evidence: 1. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome, Most Populous Cites, available locally as MIP-RN_ann-outcome.pdf (26k pdf). 2. Radiation Monitoring Site Agreement/Evaluation Reports, example from Bridgeport site available locally as Bridgeport_RadNet_Eval.pdf (107k pdf). 3. Radiation Monitor Deployment Contract. The contract is available locally as EP-W-05-012.pdf (3M pdf). 4. Radiological Emergency Response Measurement Implementation Plan, Annual Outcome, Readiness, available locally as MIP-ER_ann-outcome.pdf (40k pdf). 5. Radiological Emergency Response Measurement Implementation Plan, Annual Output, Laboratory Capacity, available locally as MIP-ER_ann-output.pdf (27k pdf). 6. Waste Isolation Pilot Plant (WIPP) Measurement Implementation Plan, Annual Output, available locally as MIP-WIPP_ann-eff.pdf (25k pdf). 7. Radiation Protection Program Measurement Implementation Plan, Annual Efficiency, Population Covered/$M, available locally as MIP-RPP_ann-eff.pdf (23k pdf).

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The Radiation Protection Program has demonstrated improved efficiency and cost effectiveness by expanding the population covered by Radiation Protection Program monitors per million dollars invested. On this basis, program results indicate that efficiency and cost effectiveness have increased each year. Through 2006, the program has achieved a 14 percent reduction in cost per person covered. The program also has demonstrated improved efficiencies in other activities. For example, the radiation program is tracking the time to approve site changes at Department of Energy (DOE) waste generator sites for safe disposal of transuranic radioactive waste. Through 2006, the program achieved a 33% reduction in approval time (2) from the 2004 baseline. The Radiation Protection Program can also show reductions in average time between radiation ambient air monitoring data collection and data availability during an emergency; the data availability measure tracks both the roll-out of new monitors and the system's efficiency gains in terms of data turnaround (3).

Evidence: 1. Radiation Protection Program Measurement Implementation Plan, Annual Efficiency, Population Covered/$M, available locally as MIP-RPP_ann-eff.pdf (23k pdf). 2. Waste Isolation Pilot Plant (WIPP) Measurement Implementation Plan, Annual Output, available locally as MIP-WIPP_ann-eff.pdf (25k pdf). 3. RadNet Monitoring System Measurement Implementation Plan, Annual Outcome/Efficiency, Data Availability, available locally as MIP-RN_ann-eff.pdf (27k pdf).

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The EPA Radiation Protection Program is unique within the United States given its authority in the National Response Plan, Nuclear/Radiological Incident Annex (1), the Waste Isolation Pilot Plant (WIPP) Land Withdrawal Act (2), and in Reorganization Plan No. 3 (3). The RadNet National Radiation Monitoring System is the only national ambient radiation monitoring system. There is no Federal, state, local government, or private sector program that is comparable to EPA's Radiation Protection Program.

Evidence: 1. The National Response Plan, Nuclear/Radiological Incident Annex, page 27, http://www.dhs.gov/xlibrary/assets/NRP_FullText.pdf (4M pdf). [A file containing the NUC annex, the NRP cover page, and the NRP Forward is available locally as NRP_NUCannex.pdf (318k pdf).] 2. The Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA), S1671, Summary, http://thomas.loc.gov/cgi-bin/bdquery/z?d102:SN01671:@@@D&summ2=m&. 3. Reorganization Plan No.3, 1970, Section 2(a)(6), http://www.epa.gov/history/org/origins/reorg.htm.

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: EPA's radiation monitoring program relies on independent evaluations by the EPA Science Advisory Board (1), the CRCPD, and state program managers to provide an evaluation of the program goals and effectiveness. Based on the 2005 state CRCPD survey, all 16 states with radiation monitoring systems indicated that the program was effective and should be expanded in their respective states (2). For EPA's radioactive waste disposal program, EPA seeks public input officially on important EPA actions such as WIPP recertification and waste approvals of DOE waste generator sites. EPA has discussions with stakeholders (states, local governments and interest groups) concerning major Agency actions affecting New Mexico residents. EPA has made regulatory changes after the evaluation of public comments pertaining to waste recertification decisions (3, 4). For EPA's emergency response program, EPA participates in at least one formally evaluated interagency exercise that tests our radiological readiness capabilities each year. At the end of each exercise an After Action report is completed (see evidence for Question 2.6, citation 5).

Evidence: 1. EPA SAB Report, Review of 2005 Agency Draft entitled "Expansion and Upgrade of the RadNet Air Monitoring Network, Vol. 1 & 2, Concept and Plan," Quality Review Draft, 8/17/06, http://epa.gov/sab/pdf/radnet_final_qual_rev_draft_08-17-06.pdf (504k pdf). 2. CRCPD 2005 Survey: Summary of Survey Results, available locally as CRCPD_05survey-sum.pdf (164k pdf). 3. Recertification Application Notice of Availability & Opening of Public Comment Period (69 FR 29646), http://www.epa.gov/EPA-AIR/2004/May/Day-24/a11765.htm. Proposed Approval of Central Characterization Project's TRU Waste Characterization Program at the Savannah River Site Notice of Availability; Opening of Public Comment Period (71 FR 13592), http://www.epa.gov/fedrgstr/EPA-AIR/2006/March/Day-16/a3813.htm. 4. Criteria for the Certification & Recertification of the Waste Isolation Pilot Plant's Compliance with the Disposal Regulations; Alternative Provisions (69 FR 42571), http://www.epa.gov/radiation/docs/wipp/194finalrule.pdf (115k pdf).