Site Number: |
01MZ |
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Contract Number: |
EP-S1-16-01 |
D.O. Number: |
008 |
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Action Memo Date: |
5/19/2016 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
9/23/2016 |
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Start Date: |
9/23/2016 |
Demob Date: |
9/29/2016 |
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Completion Date: |
9/29/2016 |
CERCLIS ID: |
N/A |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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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
Source
|
Quantity
|
Dimensions
|
Measured
Dose Rate at 1 meter (mrem/hr)
|
Calculated
Activity (mCi = mg)
|
Per Source
Activity (mCi = mg)
|
Ra-226 Tubes
|
2
|
3” length
|
3/16” diameter
|
120
|
145
|
72.5
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Ra-226 Needles
|
9
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½” length
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1/16” diameter
|
12
|
15
|
1.7
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Ra-226 Plaque
|
1
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1”x1” square
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3/16” thick
|
30
|
36
|
36
|
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
Matrix/Analytical Parameter
|
Gamma Radiation, micro Rem per hour (urem/hr)
|
Alpha Radiation, Counts per Minute (CPM)
|
Background Readings
|
8-10
|
0
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Hallway
|
20
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N/A
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Door to room
|
50
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N/A
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Over pit/vault
|
150,000
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0
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On floor next to pit/vault
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N/A
|
80
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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.
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