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EPA Radiation Guidance for CERCLA: Cleanup Levels and ARARs
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Guidance: Radiation Site Cleanup Requirements and Guidance Training
"Radiation Site Cleanup - CERCLA Requirements and Guidance" archived Internet-based training course, held June 5, 2007. Note that this training is not a guidance.
This Internet-based training was developed collaboratively by EPA with the Radionuclides Team of the Interstate Technology and Regulatory Council (ITRC), a state-led coalition working together with industry and stakeholders to achieve regulatory acceptance of environmental technologies. The focus of Modules 2 and 3 of the training is on CERCLA requirements and EPA's guidance for remediating radioactively contaminated sites, which can facilitate cleanups that are consistent with how chemical contaminants are addressed, except where technical differences posed by radiation are addressed.
"Headquarters Consultation for Radioactively Contaminated Sites" July 26, 2000.
OSWER Directive 9200.1-33P, NTIS Order Number (PB2000 963304), 4p.
Available on-line from OSWER (4 pp, 420K).
This memorandum requests that EPA Regional Offices consult with Headquarters on CERCLA response decisions involving (1) onsite management (e.g., capping of material in place, building disposal cells) of radioactive materials, or (2) when there is a potential national precedent setting issue related to a radioactive substance, pollutant or contaminant.
"Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination" August 22, 1997.
OSWER Directive 9200.4-18, NTIS Order Number (PB97 963210), 20p.
Available on-line from OSWER (20 pp, 1M).
This memorandum provides clarifying guidance for establishing protective cleanup levels for radioactive contamination at CERCLA sites. In particular, this memo clarifies that cleanups of radionuclides are governed by the risk range (generally 10-4 to 10-6) for all carcinogens established in the NCP when ARARs are not available or are not sufficiently protective. Includes determination that dose limits in NRC decommissioning rule (e.g., 25/100 mrem/yr) should generally not be used to establish cleanup levels under CERCLA.
"Clarification of the Role of Applicable, or Relevant and Appropriate Requirements in Establishing Preliminary Remediation Goals Under CERCLA" August 22, 1997.
OSWER Directive 9200.4-23, NTIS Order Number (PB97 963246), 4p.
Available on-line from OSWER (4 pp, 412K).
This memorandum clarifies that, EPA may establish preliminary remediation goals (PRGs) at levels more protective than required by ARARs, even at sites that do not involve multiple contaminants or pathways of exposure. Although this memo does not focus on radiation issues, its general policy is part of the determination in OSWER directive 9200.4-18, mentioned previously, that dose limits in the NRC decommissioning rule should generally not be used to establish cleanup levels under CERCLA.
"Use of Soil Cleanup Criteria in 40 CFR Part 192 as Remediation Goals for CERCLA Sites" February 12, 1998.
OSWER Directive 9200.4-25, NTIS Order Number (PB97 963308), 6p.
Available on-line from OSWER (6 pp, 726K).
This memorandum provides guidance regarding the circumstances under which the subsurface soil cleanup criteria in 40 CFR Part 192 should generally be considered an applicable or relevant and appropriate requirement (ARAR) for radium or thorium in developing a response action under CERCLA.
"Remediation Goals for Radioactively Contaminated CERCLA Sites Using the Benchmark Dose Cleanup Criteria in 10 CFR Part 40 Appendix A, I, Criterion 6(6)" April 11, 2000.
OSWER Directive 9200.4-35P, NTIS Order Number (PB2001-963301), 9p.
Available on-line from OSWER (9 pp, 983K).
This memorandum provides guidance regarding the circumstances under which the "benchmark dose" criteria in Criterion 6(6) should generally be considered an applicable or relevant and appropriate requirement (ARAR) in developing a response action under CERCLA for sites with radium-226, radium-228, thorium-230, thorium-232, or uranium-234, and/or uranium-238 as contaminants of concern. Because of the interrelationship between the standards under 40 CFR Part 192 and those under Criterion 6(6), this memorandum should be used in conjunction with the memorandum entitled "Use of Soil Cleanup Criteria in 40 CFR Part 192 as Remediation Goals for CERCLA Sites" (OSWER Directive 9200.4-25, February 12, 1998).
"Interim Final Evaluation of Facilities Currently or Previously Licensed NRC Sites under CERCLA" February 17, 2000.
OSWER Directive 9272.0-15P, NTIS Order Number (PB2000-963301), 9p.
Available on-line from OSWER (9 pp, 1M).
This memorandum provides interim guidance to clarify EPA's role under CERCLA at facilities previously or currently licensed by NRC. This guidance is in response to EPA increasingly receiving requests to either 1) conduct response actions under CERCLA at previously or currently licensed facilities, or 2) make a determination if a past or proposed NRC decommissioning would meet CERCLA cleanup levels.
"Use of Uranium Drinking Water Standards under 40 CFR 141 and 40 CFR 192 as Remediation Goals for Groundwater at CERCLA sites" November 6, 2001.OSWER Directive 9283.1-14, NTIS Order Number (PB2001-963302), 10p.
Available on-line from OSWER (11 pp, 420K).
This memorandum addresses the use of uranium standards in 40 CFR Part 141 (MCLs) and 40 CFR Part 192 (UMTRCA) when setting remediation goals for ground waters that are current or potential sources of drinking water at CERCLA sites.
Other OSWER Policies for addressing Groundwater at CERCLA sites:This website contains a number of guidances and selected other reports on ground water which are used frequently by Superfund Remedial Project Managers. Although these documents do not focus on radioactive contaminants, site decisionmakers at sites with radioactively contaminated groundwater should find them useful. This is because at CERCLA sites, EPA addresses radiological contaminants in a manner consistent with non-radiological (chemical) contaminants, except to account for the technical differences between radionuclides and chemicals.
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