Engineering and Expeditionary Warfare Center

Radiological Sites

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Overview

 

The Installation Restoration Program (IRP) includes the investigation and remediation of contamination from past releases of general radioactive material (G-RAM) in order to protect human health and the environment. G-RAM that may be encountered at ERP sites takes various forms such as radioluminescent devices (e.g., dials, gauges, and markers), as well as contaminated media (e.g., soil, groundwater, and sediment). 

Jump to Resources to access Policies & Guidance, Publications, Related Sites, and Tools

 

Process

 

The types of radioactive materials addressed by the ERP are defined under the Radiological Affairs Support Program (RASP). G-RAM includes technologically-enhanced naturally occurring radioactive materials (TENORM), naturally-occurring and accelerator-produced radioactive materials (NARM), in addition to byproduct, source, and special nuclear materials. Cleanup activities at radiological sites require close coordination with the Naval Sea Systems Command Detachment (NAVSEADET) Radiological Affairs Support Office (RASO), which serves as the technical lead and main authority for all radiological issues. RASO oversees compliance with the Navy’s license for the use and storage of radioactive materials and the DON Low-Level Radioactive Waste (LLRW) Disposal Program.

Regulatory Program Framework

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) regulatory framework applies to activities involving G-RAM at ERP sites. G-RAM contamination assessment and management, while similar to other ERP site types has several unique aspects such as risk/dose modeling (versus concentrations), radiation measurements, and specialized methodologies for performing radiation surveys.

The U.S. Environmental Protection Agency (EPA), the Department of Defense (DoD), Department of Energy (DOE), and the Nuclear Regulatory Commission (NRC) developed the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) to provide a standardized approach for planning, conducting, evaluating, and documenting environmental radiation surveys. The MARSSIM process still operates within an overarching CERCLA regulatory framework. However, there is a difference in terminology between radiological investigative work and traditional chemical contamination investigative work under the CERCLA process. While the use of MARSSIM is recommended, it is not a DoD requirement and its application at a site requires consultation with NAVSEADET RASO and the appropriate regulatory stakeholders.

The MARSSIM process typically starts when the Department of the Navy (DON) prepares the Historical Radiological Assessment (HRA) to document the extent of past radiological operations and any residual effects these operations may have had on a site. (In the absence of an HRA, there may be situations where a Remedial Project Manager (RPM) makes an initial determination that a site has potential G-RAM issues [e.g., radium paint shop, landfill, etc.] through Five-Year Reviews or other investigations). The HRA is equivalent to a Preliminary Assessment (PA) in the CERCLA process where sites are determined to be non-impacted or impacted based upon a detailed review of historical records and interviews. It should be noted that the Navy’s HRA terminology has been modified from MARSSIM (2000) where the term Historical Site Assessment (HSA) is used.

For sites designated for follow-up, further sampling and surveying may then be warranted. As site efforts proceed, radiation survey results are incorporated into key CERCLA documents to serve as the foundation for site decision-making, remedial action, and site closure. Once radioactive contamination has been identified and remediated at an impacted site, MARSSIM recommends a Final Status Survey (FSS) for radiological release of the site for unrestricted use. The FSS is included in the Remedial Action Completion Report (RACR) to fulfill the CERCLA requirement for closure. More information on integrating the MARSSIM process into the CERCLA framework for ERP sites can be found in Chapter 13.3 of the DON Environmental Restoration Program Manual.

Roles and Responsibilities

Multiple DON organizations play a role in the execution of cleanup activities at G-RAM sites. The RPM is responsible for overall management and execution of work at DON ERP radiological sites. Cleanup projects involving G-RAM require specialized knowledge and expertise in radiation science and health physics as provided by NAVSEADET RASO. The public release of information involves several mandatory levels of review and approval including, but not limited to the assigned NAVFAC Public Affairs Officer (PAO) and NAVSEADET RASO/NAVSEA PAO. The key roles and responsibilities for the NAVFAC RPM, NAVSEADET RASO, and PAOs are highlighted in Chapter 13.3 of the DON Environmental Restoration Program Manual.

Resources

 

Topics

Title and Description

ERP Manual

DON Environmental Restoration Program Manual: Chapter 13.3 Radiological Sites (February 2018)

Summarizes the mandate of the ERP as it relates to radiological (G-RAM) contamination in order to identify and determine the best remedy to protect human health and the environment.

LLRW

DoD Instruction 4715.27 Low Level Radioactive Waste (LLRW) Disposal Program (July 2017)

Explains the purpose and applicability of the DoD LLRW Disposal Program, the responsibilities of oversight and compliance, funding, budgets, and the process for requesting a waiver.

OPNAV

OPNAV M-5090.1 Environmental Readiness Program Manual: Chapter 29 Low-Level Radioactive Waste Disposal Program (January 2014)

Defines what constitutes LLRW and describes the purpose of the program, the responsibilities of the parties involved in the disposal of LLRW, and the required training of personnel handling LLRW.

G-RAM

DON Policy on Activities Involving General Radioactive Material (G-RAM) at Environmental Restoration Program Sites (February 2010)

Clarifies the roles of the responsible DON entities concerning the cleanup of G-RAM.

RASP

NAVSEAINST 5100.18B Radiological Affairs Support Program (RASP) (February 2007)

Outlines the responsibilities of NAVSEA to establish, inspect, maintain, and manage Radiation Protection Programs and manage the RASP Radioactive Waste Disposal Program.

Topics

Title and Description

MARSAME

Multi-Agency Radiation Survey and Assessment of Materials and Equipment (MARSAME) (January 2009)

Provides technical information on survey approaches to determine proper disposition of materials and equipment.

MARLAP

Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP) (July 2004)

Provides guidance for the planning, implementation, and assessment of projects that require the laboratory analysis of radionuclides.

MARSSIM

Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (August 2000)

Provides detailed guidance for planning, implementing and evaluating environmental and facility radiological surveys to demonstrate compliance with a dose- or risk-based regulation.

Topics     

Title and Description

RAD Assessment Tool

RESRAD

A code developed by Argonne National Laboratory for conducting radiological risk/dose assessments.

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