Cleanup Levels and ARARs Radiation Guidance

EPA’s recommended guidance for selecting remedies at radioactively contaminated Superfund sites. Guidance documents are grouped into three categories below. “UMTRCA” refers to the Uranium Mill Tailings Radiation Control Act.

• Overall cleanup levels and ARARs
• UMTRCA soil
• Ground water

Overall Cleanup Levels and ARARs

• Radiation Site Cleanup - CERCLA Requirements and Guidance: archived online training from June 2007. Note: this training is not a guidance.

EPA and the Radionuclides Team of the Interstate Technology and Regulatory Council (ITRC) collaboratively developed the training. Modules 2 and 3 focus on CERCLA requirements and EPA's guidance for remediating radioactively contaminated sites.

• Headquarters Consultation for Radioactively Contaminated Sites (PDF)(4 pp, 420 K)
  OSWER Directive 9200.1-33P, NTIS Order #PB2000 963304, July 2000.

This memorandum requests that EPA Regional offices consult with Headquarters on CERCLA response decisions involving on-site management of radioactive materials (e.g., capping of material in place, building disposal cells) or 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 (PDF)(20 pp, 1 MB)
  OSWER Directive 9200.4-18, NTIS Order #PB97 963210, August 1997.

This memorandum provides clarifying guidance for establishing protective cleanup levels for radioactive contamination at CERCLA sites. Cleanups of radionuclides are governed by the risk range (generally 10-4 to 10-6) for all carcinogens established in the National Contingency Plan when ARARs are not available or are not sufficiently protective. Dose limits in the NRC decommissioning rule (e.g., 25/100 millirems per year) 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 (PDF)(4 pp, 412 K)
  OSWER Directive 9200.4-23, NTIS Order #PB97 963246, August 1997.

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 that dose limits in the NRC decommissioning rule should generally not be used to establish cleanup levels under CERCLA.

• Interim Final Evaluation of Facilities Currently or Previously Licensed NRC Sites under CERCLA (PDF)(9 pp, 1 MB)
  OSWER Directive 9272.0-15P, NTIS Order #PB2000-963301, February 2000.

This memorandum provides interim guidance to clarify EPA's role under CERCLA at facilities previously or currently licensed by the NRC. This guidance is in response to EPA increasingly receiving requests to conduct response actions under CERCLA at previously or currently licensed facilities, or to make a determination if a past or proposed NRC decommissioning would meet CERCLA cleanup levels.

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UMTRCA Soil

• Use of Soil Cleanup Criteria in 40 CFR Part 192 as Remediation Goals for CERCLA Sites (PDF)(6 pp, 726 K)
  OSWER Directive 9200.4-25, NTIS Order #PB97 963308, February 1998.

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) (PDF)(9 pp, 983 K)
  OSWER Directive 9200.4-35P, NTIS Order #PB2001-963301, April 2000.

This memorandum provides guidance regarding the circumstances under which the "benchmark dose" criteria in Criterion 6(6) should generally be considered an ARAR in developing a response action under CERCLA for sites with radium-226, radium-228, thorium-230, thorium-232, 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 “Use of Soil Cleanup Criteria” memorandum listed above (OSWER Directive 9200.4-25).

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Ground water

• Use of Uranium Drinking Water Standards under 40 CFR 141 and 40 CFR 192 as Remediation Goals for Groundwater at CERCLA sites (PDF)(11 pp, 420 K)
  OSWER Directive 9283.1-14, NTIS Order #PB2001-963302, November 2001.

  This memorandum addresses the use of uranium standards in 40 CFR Part 141 (maximum contaminant levels) 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 provides links to ground water-related guidances and reports used frequently by remedial project managers. Although the documents do not focus on radioactive contaminants, decision-makers 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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Superfund Risk Assessment Radiation Guidance

This page provides EPA remedial project managers with recommended Agency guidance, models and training resources for conducting risk assessments or developing risk-based cleanup concentrations at radioactively contaminated Superfund sites.

• Risk assessment document
• Risk assessment models
• Risk assessment training

Risk Assessment Documents

• Radiation Risk Assessment At CERCLA Sites: Q & A (PDF)(44 pp, 2.23 MB) May 2014. Includes transmittal memo "Distribution of OSWER Radiation Risk Assessment Q & A's Final Guidance" OSWER 9200.4-40, June 2014.

This fact sheet provides an overview of current EPA guidance for risk assessment and related topics for radioactively contaminated CERCLA sites. It provides answers to several commonly asked questions regarding risk assessments at radioactively contaminated CERCLA sites. It also provides further guidance that dose assessments should only be conducted under CERCLA where necessary to demonstrate ARAR compliance, and that dose-based ARARs should be 12 millirems per year or less to be considered protective. In addition, it provides guidance on how to comply with indoor radon standards. This fact sheet supersedes an earlier Q&A from December 1999 (PDF)(23 pp, 2.1 MB).

• Soil Screening Guidance for Radionuclides: User's Guide (PDF)(49 pp, 443 K)
  OSWER No. 9355.4-16A, NTIS Order #PB2000 963307, October 2000
• Soil Screening Guidance for Radionuclides: Technical Background Document (PDF)(152 pp, 2 MB)
  OSWER 9355.4-16, NTIS Order #PB2000 963306, October 2000.

These guidance documents provide information on soil screening for radionuclides when setting remediation goals at CERCLA sites with radioactive contamination. The "Soil Screening Guidance for Radionuclides: User's Guide" presents standardized exposure parameters and equations for calculating radionuclide PRGs for residential land use exposures. An electronic version of these risk assessment and unsaturated zone equations have been superceded by the Radionuclide Preliminary Remediation Goals for Superfund electronic calculator (see below).

• Chapter 10, "Radiation Risk Assessment Guidance" (PDF)(37 pp, 1 MB) of the Risk Assessment Guidance for Superfund (RAGS) Part A
  OSWER Publication EPA/540/1-89/002, NTIS Order #PB90 273830, December 1989.

This chapter of RAGS Part A covers data collection and evaluation, exposure and dose assessment, toxicity assessment, and risk characterization for sites contaminated with radioactive substances. Some of the guidance in the chapter has been updated in more recent OSWER directives (e.g., 9200.4-18 and 9200.4-31P) listed above.

• Chapter 4, "Risk-based PRGs for Radioactive Contaminants" (PDF)(10 pp, 1.9 MB) of Risk Assessment Guidance for Superfund (RAGS) Part B
  OSWER Publication EPA/540/R-92/003, NTIS Order #PB92 963333, December 1991.

This chapter of RAGS Part B presents standardized exposure parameters and equations that should be used for calculating radionuclide PRGs for residential and commercial/industrial land use exposures. The guidance in this chapter for PRGs has been updated in more recent OSWER directives (e.g., 9355.01-83A) and by the Radionuclide Preliminary Remediation Goals for Superfund electronic calculator.

• Appendix D, "Radiation Remediation Technologies" (PDF) (9 pp, 1.1 MB) of Risk Assessment Guidance for Superfund (RAGS) Part C
  OSWER Publication 9285.7-01C, NTIS Order #PB 92 963 334, October 1991.

This appendix to RAGS Part C provides guidance on using risk information to evaluate and select remediation technologies for sites with radioactive substances.

• Chapter 5, "Standards, Advisories, and Guidance for the Management of Radioactive Waste," of CERCLA Compliance with Other Laws Manual: Part II. Clean Air Act and Other Environmental Statutes and State Requirements (PDF) (175 pp, 985 K)
  OSWER Publication EPA540/G-89/009, NTIS Order #PB90 148 461, August 1989.

This chapter provides guidance on the potential applicability or relevance and appropriateness of standards for management of mill tailings and on other radiation standards that may be used as ARARs for CERCLA actions. Some of the guidance in this chapter has been updated in more recent OSWER directives (e.g., 9200.4-18, 9200.4-25 and 9200.4-31P) listed above.

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Risk Assessment Models

• Radionuclide Preliminary Remediation Goals for Superfund electronic calculator. Includes transmittal memo Distribution of OSWER of Radionuclide Preliminary Remediation Goals (PRGs) for Superfund Electronic Calculator (PDF)(4 pp, 98 K)
  OSWER Publication 9355.01-83A, NTIS Order #PB2002 963301, February 2002.

This electronic calculator provides information on establishing PRGs for radionuclides at CERCLA sites with radioactive contamination. The Radionuclide Preliminary Remediation Goals for Superfund electronic calculator presents standardized exposure parameters and equations that should generally be used for calculating radionuclide PRGs for residential, commercial/industrial and agricultural land use exposures, tap water and fish ingestion exposures, and migration of radionuclides through the unsaturated zone. For relevant training, see Radiation Risk Assessment – Radiation Risk Assessment: Updates and Tools.

• Preliminary Remediation Goals for Radionuclides in Buildings (BPRG) electronic calculator. Includes transmittal memo Distribution of Superfund Preliminary Remediation Goals for Radionuclides in Buildings (BPRG) Electronic Calculator (PDF)(4 pp, 509 K)
  OSWER Publication 9355.0-114, August 2007.

This electronic calculator provides information on establishing preliminary remediation goals for radionuclides in buildings (BPRGs) at CERCLA sites with radioactive contamination. The  calculator presents standardized exposure parameters and equations that should generally be used for calculating radionuclide BPRGs for buildings with a residential or a commercial/industrial use. For relevant training, see the online course Decontamination and Decommissioning of Radiologically-Contaminated Facilities.

• Preliminary Remediation Goals for Radionuclides in Outdoor Surfaces (SPRG) electronic calculator. Includes transmittal memo Distribution of Superfund Preliminary Remediation Goals for Radionuclides in Outdoor Surfaces (SPRG) Electronic Calculator (PDF) (3 pp, 853 K) OSWER Publication 9355.5-26, January 2009.

This electronic calculator provides information on establishing preliminary remediation goals for radionuclides in outside hard surfaces (SPRGs) at CERCLA sites with radioactive contamination. The calculator presents standardized exposure parameters and equations that should generally be used for calculating radionuclide SPRGs for outside hard surfaces (e.g., building slabs, outside building walls, sidewalks and roads) with a residential or a commercial/industrial use. For relevant training, see the online course Decontamination and Decommissioning of Radiologically-Contaminated Facilities.

• Radionuclide ARAR Dose Compliance Concentrations (DCCs) for Superfund electronic calculator. Includes transmittal memo Distribution of OSWER of Radionuclide ARAR Dose Compliance Concentrations (DCCs) for Superfund Electronic Calculator (PDF)(4 pp, 665 K) OSWER Publication 9355.0-86A, NTIS Order #PB 2004 102517, January 2004.

This electronic calculator provides information on establishing ARAR dose compliance concentrations (DCCs) for radionuclides at CERCLA sites with radioactive contamination. The calculator presents standardized exposure parameters and equations for use in calculating radionuclide DCCs for residential, commercial/industrial and agricultural land use exposures as well as tap water and fish ingestion exposures. For relevant training, see Radiation Risk Assessment – Radiation Risk Assessment: Updates and Tools.

• ARAR Dose Compliance Concentrations Goals for Radionuclides in Buildings (BDCC) electronic calculator. Includes transmittal memo Distribution of Superfund ARAR Dose Compliance Concentrations Goals for Radionuclides in Buildings (BDCC) and ARAR Dose Compliance Concentrations Goals for Radionuclides in Surfaces (SDCC) Electronic Calculator (PDF)(3 pp, 959 K)
  OSWER Publication 9355.5-30, January 2010.

This electronic calculator provides information on establishing ARAR dose compliance concentrations for radionuclides in buildings (BDCCs) at CERCLA sites with radioactive contamination. The calculator presents standardized exposure parameters and equations that should generally be used for calculating radionuclide BDCCs for outside hard surfaces (e.g., building slabs, outside building walls, sidewalks and roads) with a residential or a commercial/industrial use. For relevant training, see the online course Decontamination and Decommissioning of Radiologically-Contaminated Facilities.

• ARAR Dose Compliance Concentrations Goals for Radionuclides in Buildings (SDCC) electronic calculator. Includes transmittal memo Distribution of Superfund ARAR Dose Compliance Concentrations Goals for Radionuclides in Buildings (BDCC) and ARAR Dose Compliance Concentrations Goals for Radionuclides in Surfaces (SDCC) Electronic Calculator (PDF) (3 pp, 959 K)
  OSWER Publication 9355.5-30, January 2010.

This electronic calculator provides information on establishing ARAR dose compliance concentrations for radionuclides in outside hard surfaces (SDCCs) at CERCLA sites with radioactive contamination. The calculator presents standardized exposure parameters and equations that should generally be used for calculating radionuclide SDCCs for outside hard surfaces (e.g., building slabs, outside building walls, sidewalks and roads) with a residential or a commercial/industrial use. For relevant training, see the online course Decontamination and Decommissioning of Radiologically-Contaminated Facilities.

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Risk Assessment Training

• Radiation Risk Assessment - Radiation Risk Assessment: Updates and Tools: archived online training from May 2007. Note: this training is not a guidance.

EPA and the Radionuclides Team of the Interstate Technology and Regulatory Council (ITRC) collaboratively developed this training. This training clarifies the variations between the dose approach used at some sites and EPA's risk-based approach. Modules 3 and 4 focus on EPA's radiation assessment tools for Superfund sites – Radionuclide Preliminary Remediation Goals (PRGs) for Superfund and the Radionuclide ARAR Dose Compliance Concentration (DCCs) for Superfund electronic calculator (see above). These tools can facilitate better decision making for accelerated cleanups.

• Decontamination and Decommissioning of Radiologically-Contaminated Facilities: archived online training from April 2008. Note: this training is not a guidance.

EPA and the Radionuclides Team of the Interstate Technology and Regulatory Council (ITRC) collaboratively developed this training. Module 3 focuses on EPA's radiation assessment tool for decontamination and decommissioning activities at Superfund sites, the Preliminary Remediation Goals for Radionuclides in Buildings (BPRG) electronic calculator (see above). The tool can facilitate better decision making for accelerated cleanups.

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Community Involvement Resources for Radioactively Contaminated Superfund Sites

Fact sheets and videos for helping the general public understand the Superfund process at radioactive contaminated sites.You will need Adobe Reader to view some of the files on this page. See EPA’s About PDF page to learn more.

Community involvement fact sheets and videos for use at radioactively contaminated Superfund sites are listed below:

• Superfund Radiation Risk Assessment: A Community Toolkit

This toolkit includes 22 fact sheets to help the general public understand more about EPA's risk assessment process at radioactively contaminated Superfund sites. It also provides brief overviews on EPA's risk assessment calculators and provides information regarding radionuclides commonly found at Superfund sites.

• Superfund Radiation Risk Assessment and How You Can Help, An Overview (March 2005 video) and the transmittal memo Distribution of Superfund Radiation Risk Assessment and How You Can Help, an Overview Video for the General Public (PDF)(2 pp, 624 K) OSWER 9200.4-37, March 2005.

The video describes the Superfund risk assessment process for radioactive contamination – what it is, how it works and how members of the public can get involved.

• EPA Policies and Tools for Enhancing Community Involvement at CERCLA sites 

This website contains additional information on frequently used EPA resources for community involvement at Superfund sites. Although the information does not focus on radioactive contaminants, community involvement coordinators at CERCLA sites with radioactive contamination should find them useful. At CERCLA sites, the process EPA uses to addresses radiological contaminants is the same as the process used to address non-radiological (chemical) contaminants.

Related Radiation Guidance from non-Superfund EPA Programs and Offices

Radiation documents from EPA programs and offices other than the Superfund program that may be useful for Superfund remedial project managers are grouped into four categories on this page:

• Remediation technologies
• Ground water
• Surveys and sampling
• Technically Enhanced Naturally Occurring Radioactive Material (TENORM)You will need Adobe Reader to view some of the files on this page. See EPA’s About PDF page to learn more.

Remediation Technologies

• Technology Reference Guide for Radiologically Contaminated Surfaces (PDF) (150 pp, 5.8 MB)
  EPA 402-R-06-003, March 2006

This guide identifies surface decontamination technologies that remove radiation contaminants from building, structure and equipment surfaces. Technology profiles provide information on chemical and physical contamination technologies, including target contaminants, waste management issues, operating characteristics and associated cost. The information presented in this guide enables comparison of the technologies for site-specific use.

• Technology Reference Guide for Radioactively Contaminated Media (PDF) (228 pp, 11 MB)
  EPA 402-R-07-004, October 2007

This guide references technologies that treat radioactive contamination in liquid media, including ground water, surface water and wastewater, as well as solid media, including soil, sediment and solid waste. Technology profiles provide information on each of 21 applied technologies, enabling comparisons for site-specific use. The guide also profiles five emerging technologies.

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Groundwater

• Regulator’s Guide to Management of Radioactive Residuals from Drinking Water Treatment Technologies (PDF) (81 pp, 889 K)
  EPA 816-R-05-004, July 2005

This guide helps state regulators, technical assistance providers and field staff address radionuclide residual disposal by outlining options to address elevated radionuclide levels in community water systems. It covers best available technologies (BATs), small system compliance technologies (SSCTs), byproducts of these technologies, waste disposal options and considerations, and federal statutes and regulations governing waste disposal.

• Simulating Radionuclide Fate and Transport in the Unsaturated Zone: Evaluation and Sensitivity Analyses of Select Computer Models (PDF) (186 pp, 16.6 MB)
  EPA/600/R-02/082, July 2002.

This report provides a detailed technical analysis of five unsaturated zone fate and transport models for radionuclides. It supports the information provided in Part 3 - Unsaturated Zone Models for Radionuclide Fate and Transport (PDF) (25 pp, 383 K) of the Soil Guidance for Radionuclides: Technical Background Document on determining the general applicability of the models to subsurface conditions, and an assessment of each model's potential applicability to the soil screening process.

• Field Demonstration of Permeable Reactive Barriers to Remove Dissolved Uranium from Groundwater, Fry Canyon, Utah (PDF) (89 pp, 4 MB)

This report describes a long-term field demonstration project at the Fry Canyon site in southeastern Utah to assess the performance of permeable reactive barriers for the removal of uranium from groundwater.

• Understanding Variation in Partition Coefficient K_d Values
  EPA 402-R-99-004A&B, August 1999.

This three-volume report describes the conceptualization, measurement and use of the partition (or distribution) coefficient K_d parameter. It also discusses the geochemical aqueous solution and sorbent properties that are most important in controlling adsorption/retardation behavior of selected contaminants.

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Surveys and Sampling

• Inventory of Radiological Methodologies for Sites Contaminated with Radioactive Materials (PDF) (114 pp, 905 K)
  EPA 402-R-06-007, October 2006.

This document provides guidance to site managers and their contractors managing the cleanup of areas contaminated with radioactive materials. It includes an overview of methodologies for the identification and quantification of radionuclides likely to be present in soil and water at cleanup sites. The goal is to help project managers understand key concepts, requirements and practices of radioanalytical laboratory analyses of environmental samples.

• Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)
  EPA 402-R-97-016, December 1997

This manual provides information on planning, conducting, evaluating and documenting environmental radiological surveys of surface soil and building surfaces for demonstrating compliance with regulations. The manual was a collaborative effort by several agencies.

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Technically Enhanced Naturally Occurring Radioactive Material (TENORM)

• Potential for Radiation Contamination Associated With Mineral and Resource Extraction Industries (PDF) (19 pp, 152 K)
  April 2003.

This guidance provides a listing of the various types of mineral and other sites that might have associated technically enhanced naturally occurring radioactive material (TENORM).

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Memorandum of Understanding (MOU) with the National Regulatory Commission (NRC)

You will need Adobe Reader to view some of the files on this page. See EPA’s About PDF page to learn more.EPA and the NRC developed this MOU to identify the interactions of the two agencies for only the decommissioning and decontamination of NRC-licensed sites and the ways in which those responsibilities will be exercised. Except for Section VI, which addresses corrective action under the Resource Conservation and Recovery Act (RCRA), this MOU is limited to the coordination between EPA, when acting under its Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) authority, and NRC, when a facility licensed by the NRC is undergoing decommissioning, or when a facility has completed decommissioning, and the NRC has terminated its license. EPA believes that implementation of the MOU between the two agencies will ensure that future confusion about dual regulation does not occur regarding the cleanup and reuse of NRC-licensed sites.

Memorandum of Understanding between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites(8 pp, 106KB) OSWER 9295.8-06, signed by EPA on September 30, 2002, and the NRC on October 9, 2002. Distributed through the transmittal memo Distribution of Memorandum of Understanding between EPA and the Nuclear Regulatory Commission (10 pp, 137KB). Letters between EPA and NRC concerning site-specific consultation under the MOU are available online.

EPA and the NRC developed this MOU to identify agency responsibilities for the decommissioning and decontamination of NRC-licensed sites. Except for Section VI, which addresses corrective action under the Resource Conservation and Recovery Act (RCRA), the MOU focuses on the coordination between EPA when acting under its CERCLA authority and the NRC when a facility licensed by the NRC is undergoing decommissioning, or when a facility has completed decommissioning, and the NRC has terminated its license. The goal of the MOU is to make sure there is no future confusion about dual regulation regarding the cleanup and reuse of NRC-licensed sites.

The transmittal memo includes guidance to EPA Regions to facilitate Regional compliance with the MOU and to clarify that the MOU does not affect CERCLA actions that do not involve the NRC (i.e., the MOU does not establish cleanup levels for CERCLA sites).