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Internal SFUND Box Number _35_ OF 283 

Initials/Date: _LDS /_3-8-2007_ 
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/V9-je# -/-?/U -5 " -J. 

] r ^ 

f 

I C F INCORPORATED International Square, 1850 K Street, Northwest, Washington, D.C. 20006 (202) 862-1100 

March 19, 1986 

MEMORANDUM 

TO: Barbara Hostage 

FROM: Jim Duffy and Steve Wyngarden 

SUBJECT: State Records of Accidental Releases of NARM to the Environment 

The authority to license and regulate the use of naturally occurring and 

accelerator-produced radioactive material (NARM) is maintained by individual 

state governments. Thus, in our attempt to obtain information or data on the 

occurrence bf any accidental releases of NARM to the environment, we contacted 

persons within the radioactive materials divisions of state environmental 

agencies. All of the states we contacted have reporting requirements for the 

accidental release of NARM. 

Information was obtained from a total of twelve states; six agreement 

states and six non-agreement states. The six agreement states are California, 

Florida, New York, Washington, Tennessee, and South Carolina. The six 

non-agreement states are New Jersey, Ohio, Pennsylvania, Massachusetts, 

Vermont, and Oklahoma. According to the Nuclear Regulatory Commission1 

(NRC), the state regulations specific to NARM for Massachusetts and Oklahoma 

are more stringent than the federal regulations contained in 10 CFR Part 20. 

None of these twelve states operates a data base containing information on 

releases of NARM to the environment. In general, the state personnel we spoke 

with had little to no data and were not aware of any substantial accidental 

releases to the environment of NARM within their respective states in the past 

three to five years. A few of the states did have information on accidents 

involving NARM (e.g., medical misapplications), but none of these incidents 

involved releases to the environment. 

A number of the persons we contacted expressed the opinion that accidental 

releases of NARM would be rare because of the conditions under which these 

materials are used. NARM is used predominantly in small quantities and in 

closed environments (e.g., laboratories in hospitals). 

telephone conversation between Barbara Hostage, EPA, and Lidia Roche, 

NRC, February 1986. 
P.3 

Barbara Hostage 

March 19, 1986 

Page Two 

After speaking with these state personnel, we feel that it may prove 

beneficial for EPA to contact these state agencies and formally request in 

writing information on any accidental releases of NARM to the environment. 

The information we obtained was generally limited to the individual knowledge 

of the person we spoke with, and better documented conclusions may be needed 

for the record to support the radionuclide RQ rulemaking. To avoid extra work 

on the part of the states, perhaps we could send to each state contact a 

letter summarizing our telephone conversation and asking for confirmation that 

we have adequately characterized their knowledge of NARM releases. Such 

letters, once confirmed by the state contacts, could be used to supplement the 

record for the rulemaking. 

We plan to discuss this issue with you in more detail before proceeding 

further.