1.1.1 Incident Category

Time-Critical Removal Action 

1.1.2 Site Description

On 01 October 2015, Connecticut Department of Energy and Environmental Protection (CT DEEP) responded to a call from a residential property owner regarding radioactive materials discovered on the property located in Middlebury, Connecticut. The property owner had inherited the residence from her deceased father, a retired surgeon, who had apparently brought the radioactive materials from the facility where he had his medical practice to his residence at some time prior to when he retired in 1986, but likely several decades earlier.

A CT DEEP Radiation Control Physicist mobilized to the Site with hand-held radiation monitoring instruments. Gamma radiation monitoring of the source exceeded the upper range of an Eberline RO-20 hand-held ion-chamber instrument. Screening with an identiFINDER field gamma spectrometer determined that the isotope was Radium 226 (Ra-226). The Radiation Control Physicist contacted additional CT DEEP personnel for assistance with containerizing, securing, and removing the sources from the residential property to the CT DEEP Radiation Laboratory. The decision by CT DEEP to perform an emergency removal was based on their assessment that the orphan medical sources presented an immediate, imminent, substantial and reasonable threat of radiation and radioactive contamination to the environment, homeowner, and the public. After removing the orphan medical sources, CT DEEP radiation personnel conducted radiation and contamination surveys to determine no radiological contamination remained above background conditions at the residential property.  

On 02 October 2015, CT DEEP contacted EPA to obtain technical assistance in regards to the Ra-226 orphan medical sources now located within the CT DEEP radiation laboratory. A temporary storage location and container within the laboratory was engineered in order to secure the sources as CT DEEP began to explore options for transportation and disposal. From October through January, CT DEEP consulted regularly with EPA.   On 28 January, 2016, CT DEEP made a formal request to EPA for assistance with proper transportation and disposal of the Ra-226 sources.

On 09 March 2016, EPA OSCs Mike Barry and Natalie McClaine, EPA Health & Safety Officer/Radiation Safety Officer Tony Honnellio, and START members Eric Ackerman and Paul Callahan performed a PA/SI and documented the temporary storage conditions and verified the characteristics of the Ra-226 orphan medical sources.

1.1.2.1 Location

The Site is located at the CT DEEP radiation program laboratory at 9 Windsor Avenue in Windsor, Hartford County, Connecticut. The geographic coordinates of the Site are:

42º 48’ 7.5” North latitude; and

72º 39’ 40.2’ West longitude.

1.1.2.2 Description of Threat

The CERCLA hazardous substances, according to 40 CFR Ch. 1 §302.4 - Radionuclides, that are being released, or for which there is a threat of release, are listed in table 1 below:

Table 1: Orphan Medical Sources Inventory

CT DEEP personnel detected gamma radiation as high as 120 millirem per hour (mrem/hr) at one meter distance from the orphan medical sources, as well as elevated alpha radiation levels. Using the Specific Gamma Ray Dose Constant for Ra-226, CT DEEP personnel calculated the total source strength to be approximately 196 milliCuries (mCi); the CERCLA reportable quantity of Ra-226 is 100 milliCuries (mCi).

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On March 9, 2016, EPA and START conducted a PA/SI and discovered the following inspection results:

Table 2: Measured Radiation Levels on 09 March 2016

N/A = Not monitored at this location

If CT DEEP personnel were permitted access to the storage room containing the temporary Ra-226 orphan medical sources subsurface pit they could exceed their annual limit of radiation exposure for both radiation and non-radiation workers. Within the storage room and the temporary containment structure, the Ra-226 continues to decay to radon gas and then into daughter products via alpha decay. This alpha decay has and will continue to contaminate the areas nearest to the storage pit until the parent Ra-226 materials are properly disposed of.

2.1.1 Narrative

On March 9, 2016 EPA, START and CT DEEP met at the Site to conduct a PA/SI.  

On May 16, 2016, an Action Memorandum was signed by the Office Director of the Office of Site Remediation and Restoration authorizing a removal action with the extramural removal project ceiling of $326,700.

On 9/23/2016, EPA,START, CT DEEP, ERRS, and the ERRS subcontractor mobilized to the Site to conduct a removal action "mock-up", setup the transfer/repackaging area and perform rehearsals. 

On 9/24/2016, the radium sources were transferred from the temporary storage area and packaging and packed in approved Type A packages and shipped off site to the disposal facility. The CTDEEP lab temporary storage and packaging area was decontaminated, radiation surveys were performed and released for unrestricted use. Subcontractor tools and equipment used during the removal remained in custody at the CTDEEP radiation lab to allow radioactive residual contamination to decay away to background levels. CTDEEP personnel performed radiation surveys and provide Health Physics support. All personnel demobilized from the scene at the completion of site activities. 

On 9/28/2016 the 55 gallon-drum of miscellaneous low-level radioactive material comprised of used PPE, the original and temporary packaging material ( a lead-lined wood box and a steel pipe) and other miscellaneous materials was removed and transported to a licensed radioactive material storage facility.

On 9/29/2016 the subcontractor's tools and equipment staged for decay of residual radioactivity were cleared by CT DEEP radiation program personnel at background levels and were picked up by the subcontractor. 

2.1.2 Response Actions to Date

• Conducted a Site walk with EPA contractors to determine appropriate equipment, personnel and utilities required. 
• Developed a draft work procedure and Site Health and Safety Plan.
• Evaluated options for packaging sources.
• Obtained end disposal clearance at a certified facility.
• Procured and fabricated radioactive shipping packaging per radioactive materials shipping regulations.
• Finalized the work plan and health and safety plan.
• Rehearsed removal with mock-ups to minimize exposure and contamination.
• Mobilized personnel and equipment to the site.
• Delineated work zones and decontamination areas.
• Secured & controlled access by the public and project personnel to site and active work areas to keep radiation exposure as low as reasonably achievable (ALARA).
• Removed, packaged, labeled and shipped the Ra-226 sources and 55-gallon drum of PPE and misc packaging materials to licensed disposal facilities.
• CTDEEP lab was decontaminated and radiation surveys cleared areas impacted at background levels.
• The subcontractor, Cabrera, picked up their tools and equipment after clearance by CTDEEP to background levels.    

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

EPA obtained signed access agreements from the Director of the Radiation Division at CT DEEP.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

 Removal activities on site are complete and no further activities are anticipated. This Final POLREP will be updated final trailing costs when they are available and the ERRS Task Order and START TDD will be closed after all administrative activities are completed.  The removal action report will be drafted, finalized and distributed to the project team and site file. When all activities are completed the site file will be archived and the Administrative Record generated and filed.

2.2.1.1 Planned Response Activities: see above

2.2.1.2 Next Steps: see above

See above.

2.2.2 Issues: None

2.4.1 Narrative

A task order of $225,000 has been issued to ERRS.

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

2.5.1 Safety Officer

Mike Firsick - Supervising Radiation Control Physicist, Radiation Division at CT DEEP

Tony Honnellio, EPRB - Radiation Program & Safety Officer

2.5.2 Liaison Officer

Initial coordination with the CTDEEP Commissioner's Office was performed by the EPA LNO. On 9/27/2016 CTDEEP Commissioner's Office and Radiation Program expressed thanks for EPA's work on this site.

2.5.3 Information Officer

3.1 Unified Command
EPA-OSC

EPA-Radiation Program Lead

CTDEEP-Radiation Program Manager

ERRS RM and Radiation Subcontractor Manager

3.2 Cooperating Agencies

EPA OSC Mike Barry

EPA OSC Natalie McClaine

EPA Safety Officer/Radiation Program Contact Tony Honnellio

ERRS - Removal Manager

START - 1

Cabrera - Two Radiation Control Technicians (RCT)

Chase Environmental  - 2

CTDEEP Radiation Program - 3

Total personnel on site:

EPA-3, ERRS & Subcontractors-4, START-1, CTDEEP-3, Total-11

6.1 Internet location of additional information/report
:

https://www.epaosc.org/site/site_profile.aspx?site_id=11446

6.2 Reporting Schedule