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).
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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.