Field Operations Plan for the Armstrong Building

Field Operations Plan for the Armstrong Building

Submitted to:

Holt Hauling and Warehousing System, Inc. Post Office Box 8268

Philadelphia, Pennsylvania 19101-8268 (609) 742-3153

by:

Integrated Environmental Management, Inc. 1680 East Gude Drive, Suite 305

Rockville, Maryland 20850 (301) 762-0502

Report No. 97013/G-4161 December 16, 1997

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TABLE OF CONTENTS

Holt Hauling and Warehousing System, Inc. "Field Operations Plan for the Annstrong Building"

December 16, 1997, Revision 0

Page i

ACRONYMS AND ABBREVIATIONS, , , , ' , , , , , , , , , ..... , ... , .. , .. , ... iii

INTRODUCTION ' ..... ,."., .... " .. ,., .. " ...... ,., .. ",.,",., 1

PRELIMINARY HAZARD ANALYSIS ,., .. ,., .... ,.,., ... ,., ... ,.,",. 2 Ambient Radiation Exposure Potential , , , ' , . . , , , , . ' . , . , , . , . . . . , , , , . , , 2 Airborne Radiation Exposure Potential During Surveys . , . . . . . , . . . . . , . , ... , 3 Airborne Radiation Exposure Potential During Coring , . , . , , , , . , . , . . . . ' , .. , 4 Total Radiation Dose Potential . , , , , .... ' , , . , . , . , .. , , , . , . ' .. , ' , , , .. 5

RELEASE CRITERIA ... , . , , . , ....... , . , ..... , . , , ..... , . , , . , . , , , , . 6

SURVEY METHODS ... , . , .. , . , . , .. , .. , .. ' .. , , .. , . , . , . , , . , , , . , , , ' . 7 Preparation for Surveys ' , , , . , , . , , , , ' , , , , . . . . , . . . . . . . . . . . . . . . . . . . 7 Determination of Background . , , , , , , , , , ' , , , , , , , , , , , , , , , , ' , , , ' , , , , , 7 Scanning Surfaces for Alpha Radiation, , , , , , , ' , , , , , . , .. , ..... , , . , , , , ' 8 Measurement of Total Surface Contamination """"""""""""" 8 Measurement of Removable Surface Contamination """""""""'" 10 Measurement of Dose Equivalent Rates on the Roof , , , , , , , , , , , , , , , , . , . , . 10 Floor Drain Monitoring """"""""""""""""""'" 10

SAMPLING AND ANALYSIS METHODS """"""""""""""" 11 Purpose for Sampling . . , . . . . . . . . . . . , . . . . . , . . . . . . , . . . , . , , . , . . . , 11 FloorfWall Sampling Protocols ... , ... , , . , . , , ....... , . , . , .. , . , , , . , 11 Roof Sampling Protocols . . . . , . . , . . , . , . , . . . . , . . , . , . , . , , , , . . , , , , , 11 Floor Drain Sampling Protocols " , .............. , . , . , ... , , , . , .. , ' 12 Analyses Performed ... , , . , ...... , . , . , , .. , ............ , , , , , . , . 12

HEALTH AND SAFETY PLAN, ............ , .. , , ... , . , ...... , , . , , . ,. 13 Site Entry , . . . , . . . , , . , . ' . . , . . . . , . , , . . . , . . . . . . . . , , . . . , , , . . , . 13 Control of Work """""""""""""""""""""" 13 Employee Training in Radiation Protection ~ . , , , ' , . . . ' . . . . . . . . . , . . , . , . 13 Emergency Procedures .... , ......... , .. , . , , , ..... , . , ..... , ' . , , 14 ALARA ' . , . , .... , .. , , ......... , , , . , ..... ' .. , .. , .. , , . , .... 14 Contamination Controls """ .. " ... ' .. , , , .. , . , , . , , . , . 15 Protective Clothing .. ,." ........... ,.,., ............. ,.,.... 15 Personnel Monitoring ......... , ...... , ... , ........... , .. , . , , .. 15 Non-radiological Hazards ,., ........... ,.",................... 16 Lighting . . , , , . , , . . , . . . , . . , , , . . . . , ' . , . , . . . , . . , , , , . , . , , . , . , , 17

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QUALITY ASSURANCE PROJECT PLAN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Project Organization and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Quality Assurance Objectives and Sampling Strategy . . . . . . . . . . . . . . . . . . . . . 21 Field Operations ............................................ 24 Laboratory Operations ........................................ 24 Sampling and Measurement Procedures ............................. 25 Sample Collection, Preservation and Handling ......................... 26 Sample Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Custody During Field Sampling Operations ........................... 27 Custody During Shipping ...................................... 28 Custody During Laboratory Operations ......................... 28 Final Evidence Files .......................................... 29 Equipment Calibration and Operational checks . . . . . . . . . . 29 Analytical Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Data Validation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Data Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Data Reporting ............... . . . . . . . . 32 Internal Quality Control ....................................... 33 Quality Assurance Performance and System Audits ...................... 33 Personnel Qualifications ....................................... 34 Preventative Maintenance Procedures and Schedules ..................... 34 Data Assessment Procedures .................................... 35 Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Quality Assurance Reports ...................................... 37

REFERENCES ................................................. 39

TABLES ... ................................................... 40 Table 1 - Release Criteria ...................................... 41 Table 2.~SummlU'yof D~taQJJal:ity()ttJectives ......................... 42 Table 3 Sample Containers and Preservatives ........................ 43 Table 4 - Sample Preparation and Analysis Methods . . . . . . . . . . . . . . . . . . . , . 44 Table 5 -Quality Control Measures and Frequency. , , , , , .. , , ' , . , , , .. , . , , 45 Table 6 Minimum QA Sample Requirements , . , .... , , .. , . , . , . , , , , , , , , 46

FIGURES , . , , . , .. , , , . , , , . , , , , . , .. , , , , , , .. ' , , , , . , . , . ' . , , , .. , . , . 47 Figure 1 - Project Organization, , , . , , .. , , , , , . . ' , , , , , , . , . , , , , , , . , . , 48 Figure 2 - Chain of Custody Form, . 49

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ACRONYMS AND ABBREVIA TlONS

ALARA AMAD ANSI ASME ACS CEDE CERCLA CLP COC DPM DQO FADL FOP FS HASL HSP IEM LCS LCSD MDC MDL MS MSD NJDEP NPL OSHA pCi/g QAPjP QA/QC RIIFS RPD RSP SAP SOP SOW TEDE USACE USDOE USDOT USEPA USNRC

As Low As Reasonably Achievable Activity Median Aerodynamic Diameter American National Standards Institute American Society of Mechanical Engineers American Chemical Society Committed Effective Dose Equivalent Comprehensive Environmental Response, Compensation AND Liability Act Contract Laboratory Program Chain of Custody Disintegration Per Minute Data Quality Objective Field Activity Daily Log Field Operations Plan Feasibility Study Health and Safety Laboratory Health and Safety Plan Integrated Environmental Management, Inc. Laboratory Control Sample Laboratory Control Sample Duplicate Minimum Detectable Concentration Method Detection Limit Matrix Spike Matrix Spike Duplicate New Jersey Department of Environmental Protection National Priorities List Occupational Safety and Health Athninistration Picocurie per Gram Quality Assurance Program Project Plan Quality Assurance/Quality Control Remedial Investigation/Feasibility Study Relative Percent Difference Radiation Safety Procedure Sampling and Analysis Plan Standard Operating Procedure Statement of Work Total Effective Dose Equivalent United States Army Corps of Engineers United States Department of Energy United States Department of Transportation United States Environmental Protection Agency United States Nuclear Regulatory Commission

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INTRODUCTION

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Previous owners of the Holt Hauling and Warehousing System, Inc. (Holt) Armstrong Building (Holt's Gloucester City facility) manufactured lantern mantles. As part of that process, natural thorium, a radioactive element, was used. After the property was vacated, it was discovered that residual contamination remained in certain locations on the grounds and inside of the main building. The magnitude of this contamination, evaluated originally by the New Jersey Department of Environmental Protection (NJDEP) and later by a contractor to the U. S. Environmental Protection Agency (USEPA), was considered to be sufficient to place the property on the National Priorities List (NPL) for clean-up under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).!

Under CERCLA, funds are established for the cleanup of "uncontrolled" hazardous waste sites.' However, there is a requirement that procedures be followed to evaluate remedies, determine the appropriate extent of the remedy, and ensure remedial measures are cost effective. Consequently, once a site is listed on the NPL, clean-up is not immediate. First a remedial investigation (RI) into the nature and extent of contamination and the potential for its impact on people and the environment must be performed. Concurrently, a feasibility study (FS) is conducted to select the most appropriate remedial alternative, taking into account effectiveness, implementability, and cost. Only after the preferred alternative is approved by the appropriate regUlatory body can clean-up take place.

To address the radiological issues in the Armstrong Building, Holt has entered into a Consent Order with the USEPA wherein an RIfFS will be performed by Holt, with oversight provided by the USEPA andfor its contractors. The specific tasks to be performed under the Consent Order are described in the USEPA's "Statement of Work for the Armstrong Building Investigation, WelsbachiGeneral Gas Mantle Contamination Site, Gloucester City, New Jersey".

Two of the specific tasks are to submit to the USEP A an RIfFS Work Plan and schedule, and a Field Operations Plan (FOP). The purpose of this report is to satisfy the FOP requirements. Included herein is an evaluation of the radiological and other hazards expected to be encountered during the field work, a discussion of the criteria that acquired data will be evaluated against, the methods and procedures for performing radiation surveys and sampling, the site health and safety plan, the quality assurance project plan (QAPjP), and the means by which records will be maintained.

I 47 FR 31180, July 16, 1982,40 CFR 300.61-300.71.

2 This program is commonly known as "Superfund".

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PRELIMINARY HAZARD ANAL YSIS


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In general, the potential radiation dose that workers or the general public may incur from exposure to radioactive materials is influenced by a number of factors. These include the amount of radioactivity involved, the types of radiation emitted by the material, the chemical and physical form of the material, the solubility of the material, its particle size distribution, the duration of the exposure, the inhalation pathways (including the potential for both airborne material and resuspended material), the ingestion pathways involving contaminated water, food stuffs and animal feeds, and the demographic and physiological characteristics of the population exposed.

Radiological information acquired to date in the Armstrong Building indicates that the ambient exposure rates are low, and that there is little removable contamination. Nonetheless, for planning purposes, it is assumed that individuals working in the buildtng during the on-site activities may be exposed to low-levels of ambient gamma radiation or resuspended radioactivity. In addition, exposures to radon and thoron progeny are also possible.

As the design basis for the Work Plan, hypothetical radiation doses to on-site workers from the aforementioned exposure scenarios were determined. The intent of this effort is to establish conservative exposure scenarios (i.e., well above the average case). Therefore, assumptions necessary to complete the dose and hazard assessments were selected conservatively such that the maximum reasonable value would result. The following is a description of the approach and the results obtained.

Ambient Radiation Exposure Potential Evaluation of the ambient radiation exposure of workers performing on-site activities requires knowledge of the exposure rate in the location of interest, along with the likely duration of the exposure. The following is the calculation methodology used:

where DE the total 'exposure '(microR) to workers, 1;.' = the exposure rate (microR per 'hour) in the work location, and t = the exposure duration (hours). The following are the assumptions used for this analysis:3

• The ambient gamma exposure rate at various locations where surveyors stand is conservatively assumed to be equivalent to the mean of the

3 For this Work Plan and throughout the RI, it is conservatively assumed that the dose equivalent rate, the absorbed dose rate, and the exposure rate are equivalent.

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Holt Hauling and Warehousing System, Inc, "Field Operations Plan for the Armstrong Building"


maximum measured values in the preliminary site survey, or 131 microR per hour.

A hypothetical surveyor remains in the Armstrong building 10 hours per day, six days per week for a total of two (2) weeks, or a total of 120 hours.

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5 From these assumptions, the maximum possible exposure of a hypothetical surveyor during these 6 operations is:

DE = 131 microR x 120 hr x _.;..1.;..m",ic.:IIi:.cR-.-- = 16 milliR hr 1,000 microR

8 The radiation exposures actually incurred by the surveyors will be significantly less than 16 milliR 9 shown above due to the fact that the assumed exposure rate is not uniform throughout the building,

10 and that the maximum measured exposure rates are only associated with discrete areas of elevated 11 concentration (i.e., "hot spots").

12 Airborne Radiation Exposure Potential During Surveys 13 To estimate the exposure that may be incurred by a hypothetical surveyor from radioactivity that 14 becomes resuspended during survey activities requires knowledge of the amount of material that 15 may be re-suspended, the radionuclide concentration of the re-suspended material, the breathing 16 rate of the surveyor while in the vicinity of the material, and the duration of the surveyor's 17 exposure. For this scenario, the following was assumed:

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All surfaces within the Armstrong Building are assumed to be uniformly contaminated to the maximum removable activity level measured during the scoping study, or 1,300 disintegrations per minute per 100 square centimeters (Room 17 of the third floor).

Typical resuspension factors (defined as the ratio of air to surface contamination) range from 10'3 to 10'7 m,l, with 10" nil taken as the mean value.

The. surveyor's respiratory rate .is equal to that of an adult male performing light work for a minute volume of 20 liters per minute, or 1.2 ni per hour 4

No respiratory protection is used by the surveyor.

The surveyor remains in the work area for a total of 120 hours.

The airborne radioactivity has a one (1) micrometer activity median aerodynamic diameter (AMAD) particle size.

4 International Commission on Radiological Protection. Report No. 23, "Reference Man", 1974.

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• A factor to convert intake of 232Th plus progeny Committed Effective Dose Equivalent (CEDE) is 1.5 millirem per picocurie intake.s

• The external dose from submersion in a contaminated cloud is negligible.

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For this scenario, the maximum possible CEDE incurred by the hypothetical surveyor would be 13 millirem. The actual doses incurred by these individuals will be significantly less due to the fact that the removable contamination appears to be highly localized.

Airborne Radiation Exposure Potential During Coring To estimate the exposure that may be incurred by a hypothetical surveyor from radioactivity that becomes resuspended during sampling operations that involve coring into the floor of the Armstrong Building requires knowledge of the amount of material that may be re-suspended, the radionuclide concentration of the re-suspended material, the breathing rate of the surveyor while in the vicinity of the material, and the duration of the surveyor's exposure. For this scenario, the following was assumed:

• The Microshield computer code was used to estimate the radionuclide concentration in a 5 If by 6 in deep slab of concrete that exhibits a contact exposure rate of 550 microR per hour.6 This concentration is 3x104 pCi of 232Th plus progeny per gram of concrete.

• The airborne mass concentration is 200 micrograms per cubic meter, which is the maximum dust loading for dusty occupations. 7

• The surveyor's respiratory rate is equal to that of an adult male performing light work for a minute volume of 20 liters per minute, or 1.2 rri' per hour8

• No respiratory protection is used by the surveyor.

• The surveyor remains in the airborne cloud for a total of eight (8) hours during coring.

5 U. S. Environmental Protection Agency, FGR-II, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion', EPA-S2011-88-070, September, 1988.

6 MicroShield vS.Ol, Grove Engineering.

7 National Council on Radiation Protection and Measurements, Repon No. 91, 'Recommendations on Limits for Exposure to Ionizing Radiation", June 1, 1987.

8 International Commission on Radiological Protection, Repon No. 23, "Reference Man", 1974.

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December 16,1997, Revision 0

The airborne radioactivity has a one (1) micrometer activity median aerodynamic diameter (AMAD) particle size.

A factor to convert intake of 232Th plus progeny Committed Effective Dose Equivalent (CEDE) is 1.5 millirem per picocurie intake.9

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• The external dose from submersion in a contaminated cloud is negligible.

For this scenario, the maximum possible CEDE incurred by the hypothetical surveyor would be 86 millirem. The actual doses incurred by these individuals will be significantly less due to the likelihood of significantly greater (non-respirable) particle sizes during coring operations, his/her distance from the coring activity, and the prudent use of dust suppression systems during the activities.

Total Radiation Dose Potential Since a single individual may perform all of the aforementioned tasks associated with the RI, the maximum possible dose this hypothetical surveyor would incur is 115 millirem. Compared to the primary dose limit for occupational workers (5,000 millirem per year), the minimum dose projection that mandates the use of internal dosimetry (500 millirem per year),10 and the average background radiation dose received by members of the US population (360 millirem per year)," the maximum projected radiological impact of the RI on a hypothetical surveyor under these highly conservative scenarios is small. Actual exposures are likely to be significantly less.

9 U. S. Environmemal Protection Agency, FGR-ll, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion', EPA-520/1-88-070, September, 1988.

10 U. S. Nuclear Regulatory Commission, 10 CFR 20, "Standards for Protection Against Radiation,' §20 .1502(b)( 1).

II National Council on Radiation Protection and Measurements, NCRP Report No. 93, "Ionizing Radiation Exposure of the United States Population", 1987.

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RELEASE CRITERIA



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2 Release criteria for the Armstrong Building RI are based on exposure limits found by the USEP A 3 to be acceptable for the decommissioning of nuclear facilities (USEPA, 1997). These limits are:

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A maximum dose to a member of the general public resulting from residual radioactivity at a site of 15 mrem/year.

An annual dose to a member of the general public of 3 rnremlyear, below which no further consideration of radiological concerns is warranted.

The U. S. Nuclear Regulatory Commission (USNRC) had utilized a series of pathways analyses 9 (see Conceptual Model section of the Work Plan) to convert these annual doses into concentrations

10 on surfaces and within structural materials [USNRC, 1992]. Values for each of the two dose 11 limits mentioned above for 232Th in equilibrium with all of its progeny are shown in Table 1.

12 The values associated with 15 mremlyear are utilized in this plan as the release criteria. The 13 values associated with 3 mremlyear are utilized to establish the minimum sensitivity requirements 14 for the surveys and for analytical work.

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SURVEY METHODS

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2 Preparation for Surveys 3 Prior to the start of the RI work at the Annstrong Building, the following tasks will be completed:

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All excess equipment/material in the building will be surveyed and either released as clean material or isolated for further investigation .

. Dust and/or water accumulations on the floors will be surveyed and removed.

A reference grid will then be established based upon the contamination potential of the area (see the section in the work plan entitled "Survey Design"). Finally, scale drawings of each survey area will be prepared, indicating facility features as well as the reference grid system.

Determination of Background Background measurements of alpha surface activity and ambient gamma dose equivalent rate will be made at each of three (3) separate locations that are in areas of the Annstrong Building that are unaffected by past operations. Care will be taken to match conditions between the background locations and the survey areas (e.g., surface type, etc.) Measurements will be made in these locations at the beginning and at the end of each work shift. If the variance in values exceeds...± 50%, additional measurements will be made in order to assure a representative average value.

The following equation will be used to detennine the average background result for each work shift:

n

L BKG; BKG.

ve ~ --"'-----__

n

21 where BKG", = the average background measurement result, i = the measurement number, 22 BKGi = the result for measurement "i", and n = the number of measurements made. Values of 23 BKG"e will be used to arrive at the net measurement result from surveys perfonnedon that day. 24 Additional infonnation on the methodology for obtaining background data can be found in 25 Integrated Environmental Management, Inc. (lEM) Radiation Safety Procedure (RSP) No. RSP-26 018, "Surveillance", a copy of which will be available at the Armstrong Building for the duration 27 of the project.

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Scanning Surfaces for Alpha Radiation12

Holt Hauling and Warehousing System. Inc. "Field Operations Plan for tbe Annstrong Building"

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Scanning of the floors and lower levels of the walls (Le., within two feet of the floor) will be performed to determine the potential for excess alpha contamination being present. For the floors, a Ludlum Model 239-1F/Model12 floor monitor (or equivalent) will be used to conduct a 100% survey of floor surfaces. This instrument uses a gas flow proportional detector that will be set for alpha sensitivity to monitor the floor surfaces. Technicians will move the monitors over the floor a t a speed not to exceed 3 feet/second. Any meter response will result in the technician's marking the floor area for further investigation.

For lower wall surfaces, a similar survey will be conducted with a Ludlum 43-8912224 meter (or equivalent) operated in the alpha mode. This instrument uses a 100 crrt zinc sulfide detector to detect alpha contamination. The technician will move the meter within 0.25 inches of the wall surfaces at a speed not to exceed 4 inches/second. Any meter response will result in the technician's marking the surface for further investigation.

Wall areas that are 2 meters off the floor or higher have a low potential for contamination. Therefore. they will not be scanned. Instead. they will be surveyed in accordance with the procedures described in the next section.

Horizontal surfaces at the upper levels of each area (e.g., light fixrures, I-beam flats, horizontal pipe runs) may have been deposition sites for airborne radioactivity. Therefore, these areas will be scanned in a manner similar to the wall surfaces. To gain access to these areas, technicians will utilize either movable stairs or scaffolding.

Measurement of Total Surface Contamination Total (fixed plus removable) alpha contamination will be measured by direct survey with a Ludlum 43-8912224 alpha/beta contamination meter (or equivalent) set to the alpha channel and set with a six-second integration time. Instrument readings will be taken within 0.25 inches of the affected area surface.

The instruments to be used will be rurned on and permitted to stabilize (approximately 30 seconds) before proceeding further. In addition, pre-operational checks to ensure functionality will be completed. The individual performing the survey will sign and date the completed survey form. Additional information on the methodology for pre-operational surveys and measuring total surface contamination can be found in RSP-008, "Instrumentation", RSP-009, "Contamination Control", and RSP-018, "Surveillance", copies of which will be available at the Armstrong Building for the duration of the project.

12 The basis for the survey speeds, the detectible activities, and the counts corresponding to the release criteria are contained in Appendix A of the RIIFS Work Plan for the Armstrong Building.

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For areas where scans indicate the potential presence of alpha contamination, the following measurement criteria will be used:

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For areas of 100 cm' or less, a count will be taken of the entire area.

For areas greater than 100 cm', the number of sample points will be determined utilizing the methodology in NUREG-1505 (NRC, 1992), Section 5.

The criterion for the six-second counts will be nine counts above background, which is equivalent to 571 dpm/lOO cm' (the surface contamination level equivalent to 15 rnrem/year for Thorium-232 in equilibrium with its progeny). Areas exhibiting this amount or alpha radioactivity or greater will be included in the scope of the feasibility study.

A similar technique will be used for elevated horizontal surfaces. If scans of these areas indicate the presence of alpha radiation, six-second counts will be taken, as described above. If alpha activity above the release criterion is found, the following actions will be taken:

• A smear of the contaminated area will be collected, and

• A second count over the smeared surface will be taken.

The smear will be counted in accordance with the next section. If the smeared area still shows alpha activity above the release criterion, the area in question will be included in the scope of the feasibility study.

Wall areas higher than 2 meters above the floor will be surveyed using the same methodology established for large areas identified by the scans. NUREG-1505, Section 5 criteria will be utilized to determined the number of survey sites needed. These sites will be selected randomly over the wall surface.

For those areas where NUREG-1505 is used to select the number of samples, the data collected will be analyzed utilizing two statistical tests:

• The Wilcoxon Rank Sum test (used to determine if an entire area exceeds the release criterion), and

• The Quantile test (used to detect the presence of hot spots)

Areas where these test indicate the presence of excess contamination levels will be included in the scope of the feasibility study.

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Measurement of Removable Surface Contamination



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Removable contamination will be measured with dry smears wiped over a surface area of at least 100 cm2

• For this measurement, a filter paper or cloth disc will be placed on the surface to be smeared. The disk will be moved over an "S"-shaped area using moderate pressure, covering approximately 100 cm2 (16 in2

), or about 20 inches in length, or the entire surface if it is less than 100 cm2 in area, and then placed in a sample holder such that individual smears are separated from each other to prevent cross contamination (e.g., smear booklet or glassine envelope)l3 A sample number that uniquely identifies the smear will be recorded on the sample holder and on the survey form.

The smears may be submitted to an analytical laboratory for determination of gross alpha and! or gross beta activity (disintegrations per minute) or may be counted "in-house". The methodology for in-house counting, along with the methodology for background determination and assuring quality control, is described in RSP-019, "Smear Counting", RSP-009, "Contamination Control", and RSP-018, "Surveillance", copies of which will be available at the Armstrong Building for the duration of the project.

Measurement of Dose Equivalent Rates on the Roof A walk-over survey of the roof will be conducted using a Bicron MicroRem meter. Any area that exhibits a dose equivalent rate of two-times-background will be monitored a second time at a height of six inches from the roof surface to determine the boundaries of the elevated readings. Areas found to have dose equivalent rates two times background or higher shall be marked for subsequent sampling

Floor Drain Monitoring The floor drain serving the third floor restroom will be surveyed utilizing a Ludlum Model 133-2!12 waterproof GM detector. In conducting this survey, the technician shall insert the probe as far into the drain trap as is physically possible. If the count rate for the meter increases by a factor of two or more, samples of the material in the drain trap will be obtained for analysis (see next section).

13 For small penetrations, such as cracks or anchor-bolt holes, cotton swabs will be used to wipe the area of concern.

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SAMPLING AND ANAL YSIS METHODS

Purpose for Sampling


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For those areas where alpha radioactivity is found in levels exceeding release criteria, it will be important to determine the depth to which the radioactivity has penetrated. Therefore, a sampling program will be established for all areas where direct surveys have identified for inclusion in the feasibility study .

Each area where alpha radiation levels exceed release criteria will have a number of sampling sites established, using the criteria in NUREG-lS0S, Section 5. A similar number of sampling sites will be established in an unaffected area, to establish the level(s) of background radioactivity.

Samples of accumulated dust on elevated surfaces will be collected based on the alpha survey results. Similarly, samples of roofing material will be collected where dose equivalent rates indicate the presence of excess gamma-emitting radioactivity. Finally, a sample of accumulated sediment in the third floor restroom drain trap will be collected based on the GM survey results. These samples will be analyzed to determine whether the elevated radiation levels detected are associated with the thorium decay chain.

Floor/Wall Sampling Protocols Samples of affected area structures will be collected at the surface of the wall or floor, and at depth into the floor or wall. Surface samples will be collected utilizing a rotary hammer. The hammer will chip off the top few millimeters of surface structure, which will be collected for analysis. A sufficient area will be chiseled to collect a sample large enough to meet the requirements of the analytical laboratory.

Once the surface has been removed, a concrete coring tool will be utilized to collect a sample from the structure to a depth of two inches. Each sample will be separated into halves, with one sample representative of the depth down to one inch and the second representative of the depth from one inch down to two inches. Coring operations shall be performed without water to minimize the potential for contaminant migration, if it exists.

Each sample will be placed in a suitable package, given a unique identification number, labeled, and sent to Outreach Laboratory for analysis. As required by the QAPjP, a suitable number of split samples will also be collected and sent to the lab.

Roof Sampling Protocols Samples of roof areas which exhibit elevated dose equivalent rates will be collected using the coring tool used for the concrete floor and a special cutting bit. The number of samples collected shall be based on NUREG-1S05 criteria [USNRC, 1995]. Each sample will be collected through all layers of the roof. The samples will be packaged upon removal, given a unique identification number, labeled, and shipped to Outreach Laboratory for analysis.

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Page 12

Floor Drain Sampling Protocols 2 A sample of accumulated sediment from the third floor restroom drain trap will be dredged using 3 a plumber's snake or other suitable means. The sample will be packaged upon removal, given a 4 unique identification number, labeled, and shipped to Outreach Laboratory for analysis.

5 Analyses Performed 6 Each sample will be analyzed by the methodologies of isotopic thorium and gamma spectroscopy.

The isotopic thorium analysis will provide quantification of the concentration of 232Th and 228Th 8 in each sample. The gamma spectroscopy analysis will provide information on the relative 9 equilibrium of 232Th progeny (particularly 228 Ac,224Ra and 208TI) and also provide information on

10 the presence of other radionuclides, particularly from the uranium decay chain.

11 Analytical results will be reported in accordance with the QAPjP. After validation, the results for 12 structural materials at depth for the floors, walls, and roof will be used as input to the statistical 13 tests specified in NUREG-1505:

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The Wilcoxon Rank Sum test (used to determine if an entire area exceeds the release criterion), and

The Quantile test (used to detect the presence of hot spots)

17 Acceptable levels of thorium in these samples will be the volumetric concentrations associated with 18 232Th in eqUilibrium with its progeny at are equivalent to a annual dose during renovation (or 19 demolition) activities of 15 mremlyear. The results of these tests will determine the depth to 20 which remediation activities will have to go to remove excess thorium at the Armstrong Building.

21 If the floor drain sample results shows a concentration of Thorium-232 in excess of the volumetric 22 limit in NUREG-1500, the remediation of that drain will be included in the scope of the Feasibility 23 Study.

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HEAL TH AND SAFETY PLAN

Site Entry The Field Manager will enter the work area before any work begins in order to verify that work zones are established. The daily site entry procedure will include the following:

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Confirm the proper placement of emergency information and operational status of equipment.

Visually scan for signs of actual or potential life or health threatening hazards;

Note the physical conditions of the site and determine potential exposure pathways;

Identify new boundaries of the work zones; and

Document site activities in a "Field Activity Daily Log", including observations related to field conditions and the site, radiological surveys performed, articles screened, and samples collected.

Control of Work The methods for controlling work in temporary restricted areas will be as described in RSP-012, "Control of Radiological Work". A copy of this procedure will be available at the Armstrong Building for the duration of the project.

Employee Training in Radiation Protection Tailgate safety meetings pursuant to Radiation Safety Procedure No. RSP-020, "Tailgate Safety Training", will be conducted by the Field Manager at the beginning of each shift or whenever new personnel arrive at the job site in order to discuss health and safety procedures to be followed during the day's work activity. (A copy of this procedure will be available at the Armstmng Building for the duration of the project.) The information discussed will be recorded on a "Tailgate Safety Meeting" form and will serve as confirmation that the information was discussed with those persons whose signature is on the form. At a minimum, the following topics will be discussed during Tailgate Safety Meetings:

• Potential contaminants which may be encountered.

• The hazards associated with the potential contaminants

• Protective measures described in this Plan

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• Issue, use and retrieval of personnel monitoring devices, if used;

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The potential for visitors to be at work areas, and the limits on what the visitors will be allowed to do;

Work zone setup and decontamination procedures; and

• Emergency procedures.

Emergency Procedures This Health and Safety Plan (lISP) is established to allow the RI to be conducted without adverse impacts on worker health and safety. In the event of an accident or other emergency situation, appropriate measures will be taken in order to reduce the impact on worker health and safety.

Minor accidents will be handled on site by the Field Manager. There will be a first aid kit at the site to handle minor incidents. Should there be an incident that cannot be handled by the Field Manager (e.g., a major accident), then Holt will be informed of the location and type of incident, and the need for assistance. The Field Manager will notify Holt of all first aid cases so that the potential for radionuclide uptake through wounds can be assessed.

In the event that outside medical attention is needed, the hospital nearest to the Armstrong Building will be used. The Field Manager will accompany injured persons who have not been frisked and released to the hospital to perform contamination monitoring and decontamination activities, as necessary, prior to treatment.

A list of emergency response telephone numbers will be compiled and distributed during tailgate safety training. Prior to the start of each day's work activities, the nearest telephone will be identified for use during an emergency. The list of emergency phone numbers will be readily available on site, along with directions to the nearest hospital.

ALARA IBM has the responsibility for providing a work-place environment in which employees, visitors and contractors are adequately protected from hazards, including the hazards associated with exposure to radiation and radioactive material. While the exposures associated with the RI are expected to be low, if any, all exposures are assumed to entail some risk to the employee. Therefore, IBM has adopted the following three principles to govern all work activities with the potential for exposure to radiation or radioactive materials:

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No activity or operation will be conducted unless its performance will produce a net positive benefit.

All radiation exposures will be kept as low as reasonably achievable (ALARA) considering economic and societal costs.

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Page 15

• No individual will receive radiation doses in excess of applicable federal or administrative limits.

In addition to administrative controls implicit in this Plan, the requirements for exit surveys and personnel dosimetry will provide confirmation of the adequacy of the ALARA program .

Contamination Controls To assure radioactive materials remain under control, each worker involved in the RI will be frisked prior to leaving the work area. In addition, the clothing of each worker will be frisked frequently during survey/sampling operations. Equipment and materials will be frisked and decontaminated, as necessary, prior to exiting the work area. Radiation Safety Procedure No. RSP-009, "Contamination Control" describes the features of the program. (A copy of this procedure will be available at the Armstrong Building for the duration of the project.) Records of all actions will be maintained.

Protective Clothing The initial level of protection for the survey activities will be Level D. with hard hats and steeltoed boots. In addition, the Field Manager shall determine the appropriate amount of thermal protection to be worn by survey/sampling personnel, to prevent the possibility of hypothermia. When sampling activities of structural materials are underway, safety glasses with side shields and heavy-duty gloves will also be used. Upgrading or downgrading of the level of protection will be made by the Field Manager based on prevailing conditions.

Personnel Monitoring Individual monitoring for internal and external exposures is not required for the RI.l4 However, thermoluminescent dosimeters will be worn by personnel as deemed necessary by the Field Manager. If worn, the dosimeters will be retrieved and maintained by the Field Manager at the conclusion of each work day. At the termination of the on-site work, the dosimeters will be forwarded to the vendor for processing, with results included in the project record. The external exposure control program, including the minimum qualifications and capabilities of the dosimeter vendor, is described in RSP-016, "Exposure Control" and RSP-029, "External Exposure Monitoring". Copies of these procedures will be available at the Armstrong Building for the duration of the project.

To confirm that internal radiation exposures of personnel are consistent with the design basis of this FOP, personal breathing zone sampling may be performed during periods of high dust loading. Samplers will be charged, calibrated, deployed and retrieved by the Field Manager. Filters will be collected on a daily basis and held for decay for 24 hours. They will then be

14 Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation" states that individuals with the potential to receive greater than 500 millirem from external sources in a calendar year shall be monitored for radiation exposure. As shown in a previous section of this report, the potential does not exist for members of the Project Team to exceed 500 millirem per year for the survey and sampling activities during the RI.

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Page 16

counted in-house or forwarded by overnight mail carrier to an analytical laboratory for detennination of gross alpha activity. Any filters with gross alpha activity significantly in excess of background (e.g., two times background) will be analyzed for the presence of thorium isotopes by the off-site analytical laboratory . The sampling program is described in greater detail in RSP-022, "Air Sampling" and RSP-019, "Smear and Leak Test Swab Counting", copies of which will be available at the Armstrong Building for the duration of the project. A "Chain of Custody Fonn" will be completed and will accompany filters transferred to the analytical laboratory.

Non-radiological Hazards The major non-radiological hazards to be encountered by field personnel are exposure to cold, working on moveable stairs/scaffolds, conducting surveys and sampling activities on the roof, and operating the sampling equipment.

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Exposure to cold will be addressed by the appropriate specification of protective clothing.

Moveable stairs/scaffolds will comply with Occupational Safety and Health Administration (OSHA) requirements contained in 29 CFR 1910.29. The Field Manager shall ensure that all survey personnel utilize the stairs/scaffold in a safe manner. l5 He shall also ensure that no one IS

18 working under the area where the elevated activities are taking place.

19 Operations on the roof will be conducted by two people. No individual will stand within three feet I 20 of the roof s edge. Technicians will alert the Field Manager of any visible or other indication of ,,, 21 the lack of adequate structural support on the roof. In this event, the Field Manager will suspend

22 all roof activities, until a HSP addendum addressing the hazards found is generated and approved.

23 Operation of the sampling equipment may create hazards from electrical shock (for electrical 24 equipment), ventilation (for gasoline-powered equipment), and flying debris. The Field Manager 25 shall review safe operations with all sampling technicians. He shall coordinate sampling activities 26 with Holt personnel to ensure that the facility provides adequate support (i.e., electric power and 27 ventilation). He shall inspect all sampling areas to ensure that they are laid out safely, and that 2. all personnel in the vicinity of the sampling operations have appropriate protective equipment 29 Finally, he shall review the sampling activities on an ongoing basis to ensure that the safety 30 measures described above are adequate. He shall add additional safety measures as needed to 31 ensure that activities are completed without incident.

32 During the surveys and sampling of elevated horizontal surfaces. the technicians may encounter 33 insulation that show signs of degradation. If such signs are observed, the technicians may perfonn

15 A safe manner" includes ensuring that technicians avoid collisions with elevated objects (e.g., light fixtures) as the stairs/scaffold are being moved.

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IJf!fJt,~g.. ...•.. ... •.. . .... .... ... ..•... .••.. ...••.... ..... .• . . ... ... ........ ........•..... .. . •...... .. PrlOtt0\V0rkill~.inalIarea,£l1e. FietdM,Mage£s{l:tll. ensnF.e·tlmtthere.isadequate·lightlng to

. performsurvey(s~pUngaerivities •. If ligillingis noi sufficient, the Field Mimager shall contact theJ;l9Itrepresentati.v¢tQPt\JVid:e theligl)jt~llglevel&need:ed.where .lIurvJ;l:yfs<Ill'lplingactivitiesate tQ~eplace. . . . . . .

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QUALITY ASSURANCE PROJECT PLAN



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2 The purpose of the QAPjP is to describe the operational procedures and quality assurance and 3 quality control (QAfQC) requirements needed to support the collection of technical data for all 4 phases of the RIfFS in the Armstrong Building. These QAfQC procedures ensure that data 5 generated during the RIfFS are representative of actual field conditions and meet the project's data 6 quality objectives (DQOs) as described in the Work Plan. The DQOs for this RIfFS are important 7 to the QAPjP because they establish objective criteria against which progress can be measured in 8 a quantitative manner.

9 As stated in the Work Plan, the main objective of this remedial investigation is to determine 10 whether the levels of residual radioactive contamination within the Armstrong Building exceed 11 levels that would result in a total effective dose equivalent (TEDE) limit of fifteen (15) mrem per 12 year cited in the NUREG-J500 [USNRC, 1994). The 15 mrem/year limit is therefore a proposed 13 upper bound limit for this project. At the other extreme, the survey results will also be used to " determine whether "As Low As Is Reasonably Achievable" (ALARA) goals are realized. ALARA 15 has been established for this project at 3 mremfyear.

16 Once the limits have been determined, decision errors are established, as discussed in NUREG-17 1505 [USNRC, 1995), so that errors are not made in the eventual judgment regarding the free-18 release of the Armstrong Building. These errors are known as "Type I" (or false positive) and 19 "Type II" (or false negative) errors. Therefore, a fundamental, underlying goal of this QAPjP is 20 to ensure that an appropriate judgment is made about the status of the Armstrong Building. This 21 can only be accomplished when the data that are collected are sound and defensible.

22 Holt recognizes that the pursuit of quality assurance is more than an abstract program; rather, it 23 is integral to every decision made in the course of carrying out planned activities. Therefore, a 24 concerted effort will be made during the RIfFS to establish a level of excellence and to achieve 25 results that meet a rigorous standard of performance. 26

27 This QAPjP was developed using guidance provided by the USEPA. This QAPjP has been "organized using the EPA's suggested format for a quality assurance project plan [USEPA, 1988)] 29 A description of the project, including. but not limited to, the site's history (including a facility 30 description, contaminant identification, and results from previous investigations), project planning, 31 the survey and sampling design for this remedial investigation, discussions of risk assessment and 32 remedial alternatives, project management, and the tentative schedule for the field investigation 33 can be found in the RIfFS Work Plan.

34 As discussed previously, a variety of different sampling media will be collected as part of this 35 investigation. These include samples of structural materials (e.g., brick, concrete and roofmg 36 material) to determine levels of natural radioactivity, a sample collected from the only known floor 37 drain in the Armstrong Building (located in a former restroom), concrete core samples from

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contaminated areas, and miscellaneous samples of other media, as appropriate. The specific analyses to be performed for each media are noted in this QAPjP.

The presence of natural thorium and its associated decay products will be emphasized in determining sample concentrations. Gamma ray spectroscopy and isotopic thorium analyses will be utilized to accomplish this objective. Gamma ray spectroscopy, a technique used to identify gamma ray emitters, serves a two-fold purpose in this project: it establishes whether "equilibrium" conditions are present between the parent and thorium radioactive decay series and secondly, it identifies any other important gamma-emitting contributors that may be present. Thorium isotopic analyses are performed using the radioanalytical techniques of sample dissolution, chemical separation and alpha spectroscopy. This technique is important in determining the concentrations of individual thorium isotopes. The combination of these two types of analyses will allow comparison to the surface and volumetric concentration limits specified in NUREG-1500 [USNRC, 1994]. Other analyses specified for this project will include the collection and counting of smears for the levels of removable alpha activity. Air filters will be counted to determine gross alpha and beta concentrations.

Project Organization and Responsibilities Figure 1 shows the organizational chart for this project and the individuals or contract organization responsible for ensuring the quality of the field and laboratory operations and the data collected. The following is a brief summary of each participant's responsibilities.

• The Program Manager is responsible for project technical oversight. This individual will review and approve the Rl Work Plan and Field Operations Plan, and the Rl report; review the quality of data collected; and provides an interface between Holt, project personnel, and the USEPA.

• The Peer Reviewer provides technical support and peer review of all deliverables.

• The Field Manager has overall responsibility for the collection of onsite measurements and samples; oversees radioactive sample shipments; provides technical oversight and consultation on major QA issues; makes all on-site decisions in the event that unexpected conditions or circumstances (whether radiological or non-radiological in nature) are encountered; acts as site Health and Safety Officer; performs the survey activities specified in this Plan; completes the Rl Report. 16

• The Sampling QA Manager provides technical assistance; prepares and reviews the QAPjP; coordinates with the project laboratory; oversees QA

!6 Mr. Duff will serve a dual role as both the Field Manager and Site Health and Safety Officer.

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activities t.o ensure c.ompliance with the QAPjP; tracks lab.orat.ory submittals and sample analyses and ensures delivery .of data; c.o.ordinates validati.on .of sample data; m.onit.ors the remedial investigati.on; prepares and submits QA rep.orts.

• Field Pers.onnel are resp.onsible f.or perf.orming .onsite radi.ol.ogical surveys as specified in the W.ork Plan, under the directi.on .of the Project Field Manager.

• The Lab.orat.ory Project Manager serves as primary p.oint .of c.ontact f.or the analytical services provided by Outreach Lab.orat.ory; resp.onsible f.or providing sample analytical results and data rep.orting; supp.orts the lab.orat.ory QA Officer in the perf.ormance .of internal QA checks .on the rep.orted data; submits c.omplete data packages when required; c.orrects any transcripti.on .or c.omputati.onal errors identified during QA checks.

• The Lab.orat.ory QA Officer ensures that sample receipt and cust.ody rec.ords are pr.operly handled; data are rep.orted within specified turnar.ound times; instruments are calibrated and maintained as specified; internal QC measures and analytical meth.ods are perf.ormed as required; c.orrective acti.on is taken; appropriate pers.onnel are n.otified when problems arise; and data and QA inf.ormati.on is rep.orted.

Page 20

As an additi.onal QC measure, H.olt and Outreach will c.ollab.orate .on a Statement .of W.ork (SOW) that specifies the f.oll.owing items:

• Summary .of analyses, including a sc.ope .of services that lists all analytical variables and, f.or each sample matrix and analysis requested, the t.otal number.of field samples and laborat.ory QA samples, the per-analysis price, and t.otal c.ost .of the analytical service pr.ovided

• Sample delivery and st.orage, including method .of delivery, schedule .of samples,andpers.onnel withauth.ority to n.otifythe.lab.orat.oryof any changes in the schedule; and requirements f.or physical st.orage .of samples, h.olding times, chain-.of-cust.ody (COC), and sample l.ogb.o.ok pr.ocedures

• Turnar.ound time fr.om date .of sample delivery.

• Deliverable requirements, including supp.orting documentati.on and specificati.on .of data f.ormat

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Holt Hauling and Warehousing System, Inc "Field Operations Plan for the Armstrong Building"


• Analytical methods to be followed, including any modification from standard procedures)7

• QA/QC requirements, including acceptance of the DQOs for this project and performance evaluation testing requirements

• Progress report requirements and notice of laboratory and data auditing rights by Holt.

• Responsibilities for payment of acceptable analyses, including a requirement that all invoices be reviewed by the QA manager

Page 21

Copies of the SOW will be provided to the QA manager to assist in the review of data returned by Outreach Laboratory. In addition, Outreach will submit its QA manual for review and approval by the QA Manager. This manual will include, at a minimum, the following components: the laboratory's overall QA policy; management QA responsibilities (i.e., laboratory organization. personnel, and responsibilities); employee training provisions: facilities and equipment; maintenance activities; document control (including notebook/logbook procedures, sample labeling and tracking and chain-of-custody procedures); project initiation procedures and responsibilities; sample security; analytical methods; procedures for sample preparation and analysis and standards preparation; detection limits; data reporting and validation; quality control; corrective actions; audits; and QA reporting procedures.

No changes in the QAPjP procedures will be permitted without written documentation of the reason for, and an explanation of, the intended change. All changes will be subject to approval by the QA Manager. Copies of the written documentation will be included in all affected reports generated for this project.

Quality Assurance Objectives and Sampling Strategy Data quality objectives for this project were developed using the seven step process provided by the USEP A (EPA, 1994). The production of valid and acceptable data begins with setting sound DQOs prior to the collection of field samples and measurement data. Establishing appropriate DQOs satisfies the goals of all parties to reach agreement on the intended use of the data and an understanding of the available analytical procedures and resources to accomplish the task.

The Work Plan identified that the primary overall objective of this project was to meet the 15 mrem/year TEDE, a level at or below which the Armstrong Building can be released for unrestricted use. In addition, the Work Plan identified additional DQOs for instrument selection and associated operating procedures in order to provide a high degree of reliability that 232Th contamination would be detected at specified levels.

17 The QA Manager shall be informed of, and approve all, analytical procedural changes.

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The DQOs discussed above will be supported by the following secondary objectives:

• Implementing IEM Radiation Safety Procedures (RSP's) and Outreach Standard Operating Procedures (SOPs) that will ensure the consistency and thoroughness in the data generated .18

• Assessing the quality of the data generated to ensure that: all data are scientifically valid, of known and documented quality, and are legally defensible, where appropriate.

• Achieving an acceptable level of confidence in the decisions that are made from the data by controlling the degree of total error permitted in the data. This is accomplished using QC checks.

• Ensuring that the quality assurance procedures outlined in this plan are properly implemented by reviewing records of all surveys and analyses performed and conducting compliance inspections and audits (if required). In addition, execution of corrective actions for any nonconformances identified during this remedial investigation will be verified.

Page 22

QA objectives in the context of measurement and sampling data are further expressed in terms of accuracy (bias and precision), completeness, representativeness, and comparability. These quality characteristics are briefly defined as follows:

• Bias - The degree of agreement of a measurement (or an average of measurements) of the same parameter. Bias is one component of the accuracy of measurements.

• Precision - A measure of mutual agreement among individual measurements of the same property, usually under prescribed similar conditions. Various measures of precision exist, including laboratory and field duplicate measurements. Precision is the second component of the accuracy of measurements .

• Completeness - A measure of the amount of valid data expressed as a percentage obtained from a measurement system compared with the amount that was expected to be obtained under normal conditions. Field and analytical data may be specified at different completeness levels.

" !EM's RSP's are comparable to SOPs used by other organizations.

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Representativeness - The degree to which data accurately and precisely represent the true value of a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. Representativeness of field and laboratory data is attained through the use of consistent methods of data collection including field methods, sampling procedures, and sample preservation. In general, representativeness is typically thought of as a means of collecting representative samples or selecting representative sample aliquots during laboratory analyses.

Comparability - The confidence with which one data set can be compared with another. All data in a particular data set will be obtained by the same methods to ensure comparability of the results. Comparability of data is obtained by following established protocols for sample collection and analysis and recording field and laboratory data in consistent units.

Page 23

The type of analysis, applicable analytical reporting units, detection limit goals, accuracy (expressed as bias), precision, and holding times for this project are presented in Table 2. The laboratory volumetric detection limit of one (1) pCil g established for gamma spectroscopy and isotopic thorium analysis was based on both the levels Outreach laboratory can attain and the background concentrations normally found in the natural environment. It is expected that analysis of brick, concrete, and other media samples in the Armstrong Building, collected from areas unaffected by previous site operations, will have concentrations approximating the limit stated above. This detection limit is well below the concentration provided in NUREG-1500 (Table 1 which is equivalent to a TEDE of 3 mrem/yr. In addition, the surface concentration detection limits of 10 dpm/IOO cm2 and 10 dpm for gross alpha and beta smears and air filters, respectively, are also well below the 3 mrem/year dose limit cited in the NUREG. Detection limits of this sensitivity ensure that surface contamination and volumetric limits equivalent to the stated goal of meeting the IS mrem/yr limit can be easily reached.

For field activities, DQOs for instrument selection and associated operating procedures to detect 232Th contamination include establishing probabilities of greater than 99% that contamination will be. detected above the 15 mrem/year release criteria by the floor monitor and hand-held meters during scanning activities. It also includes the determination of a minimum detectable concentration (MDC) and counting time for the hand-held instrument that will meet the 3 mrem/year limit for 232Th in equilibrium with its progeny.

To confirm that project DQOs for precision and accuracy are achieved, analytical results for both field and laboratory QC samples will be evaluated. The equations used to assess precision and accuracy are well documented and can be found in the Outreach Laboratory QA manual. Further information on instrument detection limits for each QC measure are listed in the section of this QAPjP entitled "Data Assessment Procedures". While the degree of completeness is based on accuracy and precision levels (which, in turn, are dependent on the analytical method and type of

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sample matrix), this project assumes completeness levels of 100%. Barring the loss of samples or field data that does not meet the specified DQOs, this percentage can be achieved.

Representativeness will be obtained, as noted above, through the use of consistent data collection methods. Comparability issues will be aided by the fact that a single contract laboratory will be used during this RIfFS. Attainment of these quantitative DQOs will ensure that the data collected are of appropriate quality for their intended uses. Data that do not meet target DQOs, however, will be qualified during data validation, and their limitations will be noted in the Q AfQC reports for the project (as discussed in the section of this QAPjP entitled "Quality Assessment Reports").

One (1) in every ten (10) samples will be typically split and submitted for analysis. In an ideal situation, the analysis would provide identical analytical results. Since this can not be reasonably expected, one of the project goals is to demonstrate that split samples fall within one (1) standard deviation of the other. Split samples will be submitted blind to Outreach.

Field Operations The field sampling strategy for obtaining data that meet the project objectives is described in the Sampling and Analysis Plan. To ensure that field samples and quantitative field measurements are representative of the media collected and conditions being measured, sample measurement and collection methods will follow the procedures that appear in a previous section.

Field QC measurements will include both source and background checks. In addition, control charts (or a suitable alternative) will be utilized to document instrument variability in relation to established statistical parameters and to note trends in instrument response.

QC samples collected in the field will consist of duplicate ("split") samples. The rationale for the collection of this type of sample is to determine the extent of variability in the field samples (i.e., the measure of representativeness and precision). Duplicate field samples will be submitted as blind samples to Outreach for analysis.

Laboratory Operations Outreach has a quality assurance program composed of several components. These include:

• Quality Assurance Manual

• Standard Operating Procedures (SOP's)

• Inter-Comparison Programs

• Quality Control Samples (internal)

• Audits

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• Training

2 • Laboratory Sample Tracking System



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3 The laboratory's Quality Assurance Manual describes the QA policies, intentions, and criteria for • establishing acceptable performance. In addition to providing the mechanism to ensure that the

data collected is valid, defensible, and of known precision and accuracy, the manual establishes 6 criteria to help identify deficiencies in procedures or instrumentation.

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Outreach has twenty-five (25) laboratory administrative procedures SOPs covering topics ranging from sample receiving and identification to laboratory access control.

Outreach participates in several external programs which support the internal quality assurauce program and serve to reconfirm the accuracy and reliability of the laboratory's data.

In the laboratory, internal QC samples are analyzed to determine the accuracy and precision of each analytical method. For isotopic thorium analyses. these samples will typically include blanks, laboratory control samples (LCSs), duplicate samples. and matrix spike samples. Samples analyzed by gamma spectroscopy will typically employ blanks, LCS's. and duplicates. Gross alpha and beta analyses will typically utilize filter standards, QC LCS's and duplicate samples. A method blank and standard will be prepared with each analytical batch or run for every 20 samples. Alternative or additional QC samples may be required by the individual analytical methods. Laboratory QC samples are discussed in greater detail in the section of this QAPjP entitled "Internal Quality Control".

Regarding audits, the laboratory is involved in several performance evaluation study programs regulated by government agencies. Outreach's performance was validated by the United States Corps of Engineers ("USACE Validated") in the fall of 1997 for laboratory operations involving radioactive materials. Lab inspections may be conducted for interested parties at any time.

Training records are kept for each laboratory employee indicating training on instrument operations, analytical procedures, or attendance at seminars or special courses.

Outreach utilizes a sample tracking system to maintain sample holding times, track sample flow and sample status, fulfill chain-of-custody requirements, and monitor turnaround times.

Sampling and Measurement Procedures The overall quality of the data collected during a remedial investigation study largely depends on the quality of the field measurement and sampling activities. Procedures have been written to provide definitive guidance on consistent, technically-sound techniques for collecting quality data. The following procedures and techniques for radiation measurements and sample collection and handling will apply:

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Selecting and documenting the number and locations of suitable background and above-background sampling locations (RSP No. 023, "Building/Structure Surveys")

Performing radiation exposure rate and contamination survey measurements (RSP No. 018, "Surveillance")

• Collecting smear samples for levels of removable radioactivity (RSP No. 019, "Smear and Leak Test Swab Counting")

• Collecting breathing zone air samples when required (RSP No. 22, "Air Sampling")

• Decontaminating equipment and work surfaces prior to commencing sampling and between each sampling event (RSP No. 009, "Contamination Control")

• Classifying, packaging, and shipping samples after collection (RSP No. 015, "Packaging and Transportation of Radioactive Material")

• Completing field data sheets, sample log forms, chain of custody forms, and field notebooks (RSP No. 18, "Surveillance")

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If during the course of the RI, exceptions and/or modifications to any portiones) of the aforementioned RSP's are deemed necessary, all responsible parties will be informed and approval solicited from the USEPA prior to implementing these changes. Any exceptions or modifications will be documented. In addition, in order to cover situations not specifically covered in an individual RSP, consensus or industry-wide documents, such as those from federal agencies (e.g., the USEPA, USNRC, etc.), the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), etc. are often cited.

Sample Collection, Preservation and Handling Sample container, preservation, and handling requirements, as well as the approximate sample mass or volume required by Outreach Laboratories for each analysis and matrix type, are summarized in Table 3. Preservation and special handling are not required for the analyses expected to be conducted for this project; therefore, these requirements do not apply in this instance. Sample containers will remain closed until used. Samples will be collected independently of all other samples, that is, previously collected samples will be separated for the putpose of eliminating any potential for cross-contamination. As they are collected, samples will be fully labeled, recorded on the sample COC form and in the field activity daily log (FADL) along with other pertinent data, and placed in coolers only if warranted by the type of sample (This is not expected to occur for this project.). Samples will be shipped in keeping with the provisions noted in the section of this QAPjP entitled "Sample Custody". Field QC samples will be clearly

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identifiedonthcsamplc fog fonns, .but will be submitted to Outreachasbhnd samples. Sample chaincofcC].ls(!'»1y wiU .be maintained at all times in accordafiCc with the section of thisQAPjP en~I£leduSampleCustody" .

Cotnp1eterecol.-dsofallsampling wiUbemalntaine<l as described in the FOP. Any modifications tO$efie1rl, Sall1p!iIljl:procedu~s in the QAPjP or FOP wiU .be.documented in theFADI,. and sub~.equ.entprojeet progress reports and identified asachangc<fromthe infeoded method. Major modificatioIlS • to the samp:ling strategy or collection. procedures shaH be approved in advance. by the Program Manager and thi:! QA Manager, in consultation with the USEPA.

$l1:l1'1pli:?:C«$tt;Jc!'l fn<otde(tQ mitintain< <s(llllple iIlti:!gtity allde~tabliSh li:!galdefensibility, samplechain-of-custody wllI be maiIltltin~at:llltimesduringthewurse of <hi:! fi:!rnedial investigation. In general, this means that thesampkmeets one ofthefoHowlngconditions:

• It is .in the possession ofa designated individual;

• It is in the view ofa designated individual after receiving possession;

• It is placed in a secure area by a designated individual; or

• Ins in a designated secure area.

nle~¢fote,Jl!eP9~~~$si6n.and. PtQPW~ti)1g.~rsampJesshallbeido~entedat\4itr;tceabl~ftQm . the titn~ the .saI1')ples< arewllected untiltlle· analytical· data have been f(~turned from Ou(reaeh Laboratory. For this remedial investigation, then, samp:le custody will be m;tintained in several ways including the use orCOC fonns and sample labels, assignment of Sample ownership, and the storage of collected sa tuples in a locked container when not in the posses:sion of the sample custodian.

Custody Outing Fi~fd Sampling Op~rations The most important aspect of sample custody is thorough recordkeeping. Procedures for sample

. location <siting·andsampleprepaFation were~iftedpreviBusly arni in appl.icable RSFs, A sample label wmbe completed fOr each sample collected. At the time of sample collection, sample containers will be labeled with the following minimum infonnation required by Outreach to satisfy their internal SOP chaiu-of-custody procedure (GEN-04-1):

• Site name

• Sample number

• Sampling date and time

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• Preservation used (if any)

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3 Supplementary information such as sample description/type, sample volume, and sample location 4 may be recorded on the sample label, but all primary and supplemental information will be 5 recorded on sample log forms by field sampling personnel at the time of collection. Exceptions 6 (such as in those cases where the requested information does not apply) will be documented.

7 At the end of each day and prior to shipping or storage, a COC record will be initiated and B completed by the Field Manager for all samples. Any break in custody or evidence of tampering 9 will be documented. Sample custody is assigned to one individual in order to prevent confusion

10 of responsibility. The COC form to be used is shown in Figure 2. (Outreach Laboratory 11 maintains its own COC form as well.) Finally, information on the sample container labels will 12 be rechecked and verified against sample log form entries and COC forms.

13 Any necessary changes to the COC forms, sample container labels. or field log forms caused, for 14 example, by human error, can be corrected by the person making the entry. This will be 15 accomplished by striking out the error with one line (so as not to obliterate the original entry), and 16 reentering the correct information. The new entries will be initialed and dated.

17 Custody During Shipping 18 All samples will be packaged and shipped to Outreach Laboratory, accompanied by COC forms \9 and sample analysis request forms. Packaging will conform to U.S. Department of Transportation 20 (USDOT) regulations. An example of a sample analysis request form is provided in Figure 2. ,\ These forms will be generated using computer software whenever feasible. Copies of all forms 22 will be retained by the Field Manager.

23 The Field Manager will be responsible for sample custody and appropriate sample storage prior 24 to shipment, as well as shipping samples in a timely manner in order to meet required project 25 deadlines. (Typically, the samples will be packaged and shipped to the laboratory by overnight 26 carrier in order to ensure demonstrable chain-of-custody during transport.) The Field Manager 27 in collaboration with the QA manager will contact Outreach to notify them of the sample shipment.

2B Custody During Laboratory Operations 29 The Laboratory QA Officer will follow Outreach's SOP (GEN-04-I) for chain-of-custody issues. 30 The QA officer will verify receipt for each sample shipment and will contact the QA Manager to 31 ensure that all samples were received and to note any concerns or observations regarding sample 32 integrity. The QA Officer at Outreach will also be responsible for ensuring that the sample 33 tracking program, describing the laboratory custody procedures associated with sample receipt, 34 storage, preparation, analysis, and security, is maintained.

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A variety of records will be generated before, during, and after the RI. The Field Manager will ensure that all records are legible, thorough and unambiguous. Field records will be written in ink, and all records will be signed and dated. Any changes to a record will be made by striking through the item to be changed with a single line, entering the correct information in the immediate proximity of the strike-out, and initialing the change. Whenever possible, standardized forms will be used.

All data and supporting information necessary to substantiate the findings of the RI will be incorporated into the RI Report. Each of the completed forms will become a part of the project file. The project file will be archived by Holt and will be held until such time as its disposal is authorized by the Holt's legal counsel.

As part of its contractual arrangement with Holt, IBM will also maintain a variety of records. These include, but are not limited to, the following:

• Instrument Calibration Certificates

• Sample/Smear Count Record

• Tailgate Safety Meeting Forms

• Personnel Monitoring Records

• Waste Generation/Disposal Records (if generated)

• Standard Operating Procedures

20 Although these records may not be included in the RI Report, they will be archived by IBM until 21 such time as their disposal is authorized by Holt and IBM's legal counsel.

22 Equipment Calibration and Operational checks 23 Field instruments used fOT radiological monitoring will be calibrated in accordance with, and at 24 the frequency suggested by, each instrument's manufacturer's instructions. Field survey 25 instruments used to assess contamination levels will be calibrated using sources traceable to the 2. National Institute of Standards and Technology (NIST); the corresponding efficiency will be 27 determined as a measure of the instrument's response to a known "4 pi" (41t) standard source. 28 Instruments used for the purpose of measuring dose rates (e. g., in microrem per hour) shall be 29 calibrated in keeping with the manufacturer's recommendations.

30 Pre-operational checks of radiological monitoring instrumentation will be conducted and 31 documented a minimum of twice each day. Additional checks may be performed at the discretion 32 of the Field Manager. These checks include, at a minimum, the physical condition of the

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instrument, battery response, high voltage level, and response to a radioactive "check" source. The first check will occur each morning prior to the start of field activities followed by its response at the close of the day's field activities. In this way, any instrument deficiencies can be determined, documented, and corrected before valuable survey time is lost.

Instrument response to a designated check source will be compared on a daily basis to "control levels" as described in RSP-008, "Instrumentation". Instrument responses falling outside of the established arithmetic mean and standard deviation will be removed from service until the situation is corrected. Any deviations of this nature will be documented in the FADL and other appropriate record forms.

Because of the operational nature of large area proportional counters cited in the FOP. more frequent source checks will probably be required when changes in gas flow occur witb this instrument. This is primarily due to the fact that a slow leak of the counting gas eventually occurs when the gas supply is disconnected from the detector following purging, resulting in a reduction in the detector's counting response. If the gas supply is not disconnected, this is not a concern.

Initial and continuing calibration procedures for laboratory instruments will be performed in accordance with the cited analytical method for each analysis. The Outreach QA Officer will be responsible for ensuring the quality of the activities noted in this section.

Calibration standards used in this project will he traceable to NIST, the USEP A, or suppliers who participate in measurement assurance activities with NIST. Radiological and chemical standards shall be traceable to NIST or certified by the USEPA. At the laboratory, standards will be validated prior to use to determine their accuracy (e.g., by comparison with an independent standard).

Alpha and gamma-ray spectrometer system checks will employ energy calibration sources to determine the relationship between "channel number" and the alpha or gamma-ray energy. The frequency of system checks will be typically performed on a daily to weekly basis (determined by the stability of the system). Results of these checks and any required adjustments will be recorded. In addition, the energy resolution and the count rate of a check source will be determined and performed on a frequency, approximating a weekly to monthly time frame for energy resolution and daily to weekly for count rate determinations. Power failures or system repairs will automatically trigger the performance of such checks. Results of all system checks will be documented

Analytical Procedures Radiological analyses for project samples will be analyzed for the presence of natural thorium and associated decay products by gamma ray spectroscopy and isotopic thorium analysis. Smears and air filters will be analyzed for gross alpha and beta levels. Standard methods, using procedures recognized within the industry, will be utilized. Further details regarding these radiological analyses are summarized in Table 4.

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Reagents used by the laboratory for radiological analyses will conform to the specifications of the Committee on Analytical Reagents of the American Chemical Society (ACS) when such specifications are available. Reagents will be examined for purity upon receipt by performing gross alpha/beta analyses. Evidence of reagent contamination (i.e, greater than background levels) will require additional analyses (e.g., a uranium analysis) to determine the nature of the contaminant( s).

The laboratory QC measures to be performed for each radiological analysis, as well as the frequency of analysis and associated QC control limits, are listed in Table 5. The target detection limits summarized in Table 2 for the cited analytical methods are based on meeting surface and volumetric contamination limits specified in NUREG 1500 [USNRC, 1994] and anticipated background levels. The actual detection limits attained may be elevated due to interferences caused by the sample matrices.

Data Validation During field operation, the Field Manager will conduct a daily review of all data collected, validate the field records to ensure they are complete. and attest to the review by providing his signature and the date the review was conducted. He will also keep records of instrument calibrations and daily operational checks in a location that ensures data integrity.

In regard to laboratory operations, for every set of 20 or fewer field samples of a similar matrix analyzed by each analytical method, Outreach Laboratory will submit a data package containing the following minimum data and supporting information:

• A ease narrative and approval signatures

• Problems encountered during sample analysis (if any)

• The analytical methods used

• An analytical report of findings

• A section describing QC issues

The laboratory will be responsible for data reporting, and will perform internal QA checks on the reported data prior to submitting the data packages to Holt for review. Any transcription or computational errors identified during this QA check will be corrected by Outreach. Close contact with the laboratory will be maintained so that any problems of a "quality" nature can be resolved in a timely manner.

Holt will be responsible for the final review and validation of the analytical data, overall data management, and final interpretation of the results. For radiological analyses, data qualifiers will

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be applied when the QC results are outside the project DQOs. The data validation procedures 2 summarized below will be performed for all analyses:

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Reviewing chain-of-custody documentation to verify completeness of the sample set for each data package submitted

Verifying that holding time requirements were met

Reviewing the reported laboratory QC information to verify the initial and continuing calibration information, and that results for laboratory QC samples (e.g., blanks, duplicates, matrix spike samples, LCSs, other QC measures, etc.) were reported and within target required control limits and DQOs for the project

Evaluating the results of the field QC samples

Assessing the impact of laboratory and field QC results and assigning any necessary data qualifiers

Data Reduction Outreach will perform data reduction as specified in the referenced analytical methods and submit a data package with appropriate documentation for all requested analyses. The laboratory QA Officer is responsible for reviewing the laboratory data packages and checking data reduction prior to submittal to Holt. Any transcription and computational errors identified during this review will be corrected by Outreach.

General equations used to determine precision, accuracy, method detection limits, etc. are included in the Outreach QA manual. The methods used to identify and treat laboratory QC outliers are specified in an Outreach SOP, and in the data validation guidelines.

Data Reporting The RI report will include a summary of the field activities, analytical results, and interpretation of the results. The data will be presented in a format conducive toa clear understanding of the survey results. The data will include both the sample results and the uncertainty in the results to a stated level of statistical confidence. An appropriate number of significant figures will be determined so as not to convey a false sense of the reported level of accuracy. Information on any areas where Thorium-232 contamination was detected above the decision level and the subsequent depth of contamination will be reported. Interpretation of the results will be based on a comparison of the survey results to the 15 mrem per year TEDE as described in the RIfFS Work Plan.

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Internal Quality Control 2 For the various sample matrices collected and analytical methods used, several different field and 3 laboratory QC checks will be employed to verify the validity of the data generated. These QC 4 checks are useful because they reveal information about the sample collection techniques, 5 analytical methodology, instrument capability, possible sources of contamination, precision and 6 accuracy of the reported results, and possible interferences due to the sample matrix.

7 Field instruments used for radiological monitoring will be calibrated and operated in accordance 8 with each instrument's manufacturer's operating instructions. Field QC measurements will include 9 both source and background checks. Control charts (or an approved alternative) will be utilized

10 to determine when an instrument response is outside pre-established statistical parameters and to 11 detect problem trends. As discussed earlier, field QC samples will consist of duplicate samples.

12 Laboratory QC measures for each radiological analysis, as well as the frequency of analysis, and 13 acceptance criteria, are listed in Table 5. These measures include:

14 • Method Blanks

15 • Laboratory Control Samples

16 • Laboratory Duplicates

17 • Matrix Spikes

,. Table 6 contains minimum radioanalytical QA sample requirements - specified in terms of the type 19 of matrix and the percentage of the time a particular QC measure will be performed. Matrix spike 20 duplicates may be performed for samples containing background radionuclide concentrations.

21 Quality Assurance Performance and System Audits 22 Performance and system audits for measurement, sampling, and analysis operations will be 23 conducted by the QA Manager and will consist of reviews of the following activities:

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Laboratory analyses (documentation and recordkeeping, analytical methods, and implementation of the procedures in the laboratory QA manual)

29 Performance audits may be conducted prior to and during the time of sample collection, and when 3{) a measurement system in the field or laboratory is generating data, as appropriate. The need for 31 an on-site review of field activities will be determined by the QA manager.

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The system audits may include, but are not limited to, the following components:

• Field and laboratory personnel, facilities, and equipment

• Chain-of-custody procedures and records

• Instrument calibration and maintenance procedures and records

• Standards preparation and verification procedures and records

• Documentation of analytical methods

• Sample storage conditions and other QC procedures

• Data reduction, processing, and reporting procedures

• Documentation control procedures

Outreach Laboratory has written procedures addressing internal QA/QC. These procedures are proprietary in nature; however, to ensure compliance with this QAPjP, Outreach will make these procedures available for review upon request by the QA Manager.

Personnel Qualifications To ensure that radiological measurements and samples are collected in a manner that promotes the validation of the data or the results, all field personnel engaged in monitoring, sampling and analysis tasks, and data generation and reduction, will undergo appropriate training to establish the requisite qualifications. Training will be conducted by the Field Manager. Field personnel will be required to meet the provisions of RSP-006, "Training and Qualifications of Radiation Protection Personnel", The results of this training will be documented.

Preventative Maintenance Procedures and Schedules Preventive maintenance of laboratory instrumentation and field monitoring equipment is essential if project resources are to be used in a cost..effective manner. Preventive maintenance will take essentially two forms: I) a schedule of preventive maintenance activities to minimize downtime and ensure the accuracy of measurement systems; and 2) verification of up-to-date calibrations, satisfactory pre-operational checks, and availability of critical spare parts and backup equipment. Maintenance procedures of this type will documented in field and laboratory records.

The Outreach Laboratory QA officer will be responsible for ensuring that routine preventive maintenance is performed and documented for each analytical equipment used, and that spare parts or additional instruments are available in case of instrument breakdown or failure.

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The Field Manager will be responsible for ensuring that radiological instrumentation used during the course of the RI is properly calibrated and meets daily performance specifications, and backup instrumentation and associated parts (e.g., batteries, instrument cables, etc.) are available as needed .

Data Assessment Procedures Measures of precision and accuracy for this project are described elsewhere in this section. The data validators will verify that QC measures were performed at the frequencies required by each method, and that the QC results obtained were within appropriate control limits defined by the project DQOs. The equations used to verify that project DQOs were met for each QC measurement will be provided and utilized by Outreach during the course of the analyses. These QC measurements typically include:

• Method Blanks

• Laboratory Control Samples

• Duplicate Analyses

• Matrix Spikes

• Detection and Quantification Limits

Discussions of detection and quantification limits, consisting of Limit of Detection (LOD), Method Detection Limit (MDL), and Practical Quantification Limits (PQL), are cited in the Outreach QA manual. Specific detection limits for the analyses proposed for this project are described in Table 2.

Corrective Actions While the entire QA program is designed with the objective of eliminating problems, it serves a critical function in identifying unexpected or unavoidable problems that may be encountered during sample collection and analysis. An important part of any QA program is a well-defined, effective policy for correcting these problems once they have been identified.

Short-term corrective actions fall into two categories:

• Handling of analytical instrument or field equipment malfunctions; and

• Handling of nonconformance or noncompliance with the QA requirements that have been established for this project.

During field operations and sampling procedures, the Field Manager will be responsible for correcting equipment malfunctions. Acceptable equipment operating parameters and control limits

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are specified in equipment manuals and RSP's. If any piece of equipment fails to meet established QC criteria or cannot be properly repaired, it shall be replaced. All equipment malfunctions and subsequent corrective measures taken will be documented in the FADL.

The Outreach QA officer is responsible for ensuring that laboratory results comply with project QC requirements, and that all analytical instruments and laboratory equipment are properly maintained. Immediate corrective action shall be taken by the laboratory if any phase of the sample preparation or analysis process is considered suspect. Any corrective actions taken will be noted in laboratory notebooks.

Appropriate corrective actions will also be initiated in the field or at the laboratory, as discussed above, if any problems are noted during performance or system audits.

In addition to documenting short-term corrective actions taken by field and laboratory personnel, a mechanism is required to address long-term, systemic corrective actions. The need for longterm corrective action may be identified by an overview of compliance with standard QC procedures, control charts, and performance or system audits. Any QC problems that cannot be resolved by taking immediate corrective actions fall into this long-term category. This system will be used to ensure that the condition is reported to the person responsible for the corrective action and follow up plan.

The specific corrective actions necessary will vary, depending on the nature of the problem; however, the essential steps in a "closed-loop" corrective action system are:

• Identifying the problem

• Assigning responsibility for investigating the problem

• Investigating and determining the cause of the problem

• Determining a corrective action to eliminate the problem

• Establishing responsibility for implementing the corrective action

• Verifying the fact that the corrective action has eliminated the problem

• The complete process of establishing and implementing the corrective action will be documented in a project report that specifies the problem areas requiring corrective action and how these areas were detected, the individual initiating the corrective action, the samples or measurements of concern, the acceptable data range, the measures undertaken to correct the problems, and the individual approving the corrective action.

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Page 37

Documentation of corrective action will be routinely reviewed by the QA manager, who has z authority to enforce necessary corrective measures.

3 Quality Assurance Reports 4 Preliminary QA reporting will be performed after completion of the remedial investigation phase 5 of the field work. Reports summarizing field activities will contain copies of, or references to, 6 the following items:

8

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14

15

• Summary of site sampling and measurement locations and conditions

•

•

•

•

•

•

Sample log forms completed at the time of sample collection which document sampling locations, date and time of collection, pertinent field observations noted. and field measurements taken

COC forms, sample analysis request forms.

Monthly progress reports previously submitted during the course of the RI

Corrective action reports documenting any problems encountered during field activities and corrective actions taken

System and performance audit reports completed during the investigation

A summary of any changes made to documented procedures (with appropriate authorizations)

18 Monthly progress reports will be provided addressing field activities or other tasks involved with 19 the RI report. A complete QAIQC report will also be written for the project, summarizing the 20 technical data and noting any significant QA problems that arose. The report will include the Z1 following items:

22 • 23

24 • 25

26 • 27

28 •

29 •

Executive summary of overall data quality and recommendations for data use and limitations

Description of sample collection and shipping, including chain-of-custody and holding time documentation

Description of analytical methods. including determination of method detection limits

Description of data reporting

Description of completeness relative to QAPjP objectives

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Page 38

• Description of initial and ongoing results

•

•

•

•

Description of precision relative to QAPjP objectives

Description of accuracy relative to QAPjP objectives

Description of results for field and laboratory blanks

Identification of all cases where DQOs were not met and summary of the significance of these deviations

38 DRAFT

301517

REFERENCES

UBE;PA, 1988

USEPA,1994

USEPA,.1996

USNRC,1992

USNRC,1994

USNRC,1995

ijolt Hattling and Warehousing System, 'Inc, uField Operations Plan,for the Ar_ong,Building'

December 16, t997. Revision 0

Page 39

EPAf540lG-89IOO4, Gliidancejor Conducting R.emediallnvestigiltidns and Feasibi(ity Studies Under CERCLA, U.S. EnvironmenlltlProtection Agency, Office of Emergency and Remedial Re!>ponse, Interim Final, Washington, I).C., 1988.

EPA QAfG-4, Guidance jor the Data Quality Objectives Process, U.S. EnvirpnmentalProtection Agency, Quality A&surallCe Management Staff, Wasffingtcm, RC., 1994.

EPA.402-R-96-018,Mu1ti-Agency Radiation Survey and Site Investigation Manual,l)ecember,.1996.

NUREG/CR-5512, Residual Radioactive Contamination from De.commissioning - Technical Basis jor Translating Contamination Levels to Annual Total Effective Dose EqUivalent, U.S. Nuclear Regulatory Commission, 1992.

NUREG-1500, Working Draft Regulatory Guide on Release Criteriajor Decommissioning: NRC Staff's Draft jor Comment, U.S. Nuclear RegulalPryCommission, 1.994.

" ",',', '/'

NUREG-1505, A Nonparametric Statistical Methoddlogyjor the Design and Analysis oj Final Status Decommissioning Surveys, U.S. Nuclear Regulatory Commission, Draft Report for Comment, 1995.

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TABLES

40

Holt Hauling and Warehousing System, Inc. fiField Operations Plan for the. Armstrong Building"


Page 40

DRAFT

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Annual Dose Limit (mrem/year)

3

15



Table 1 - Release Criteria

Surface Contamination Limit (dpm/lOO em')

114

571

41

Volumetric Limit (pCi/g)

32.6

163

Page 41

DRAFT

301520

, "",""'"

. ',\tIat~sl$

G'!l1'\llllt spectiQS¢\>PY

I~()tQt!i¢ 'l'llori\ml .

Gross A.)~~~I~}ita (s!l.l~r~)

GI'()SS AlPllillB~ta {",i,fjllcrs}

Method . «!lli¢tenc¢

USP9~ ER200

USEPA. 900:0'

VSllPA ·900.0

.pCltg~

pCil~

dpm

Deteetwll LimifG~/s

Olle(l) pCftg

·One.O) pGilg

lQ dt!!IIIlOOcm2

IOdpm

H~-'t:llatiIIrig::and" WafehQlJsi~$:"~~j>tym. I~; 't'Fleld;:Operati,~:r4lJt:for'tbe ;\rmstro~,g'~uifdinif

i?ece:mber 16-, Im.::l.{:evw,ion'Q'

lJilI$ (pereellt)

75·125

75·125

75·125

25

25

25

25

Holdin!! Th!I¢s

tSQdays

ISO days

a . EnVlf!lllmenP1lMeasurementsLaboratory (Health and Safety Laboratory) PrQCeduresManual

14 bLos AlamPsNatioI1\11 Laboratory Analytical Procedures

IS cUnft¢d States EnyironmentaIProtection Agency Gross AI}Jhalaeta Procedure

d _ .... 16, plcoqun.e,s per :gram

edis~t¢g~<!ff6~l'l'r'mmutepet onellun~d.squ<!te·¢enti~.tt\rs 18 fRelatiVe j>ercenf Difference

19 It is aSS\1medthat data will be available for all samples submitted; therefore, the completeness goal should be 100%.

4-2 DRAFT

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3

•

5

• 1

•

o.ro~s AlPttafijeta (smears)

o.rO&$ A\P~a/ijeta (air mters)

Holt-Mauling: and Warehouslng,Sy,st,QiJ1,Jnc. nField'O~ra#o~_p:~,'for Jhe Armstro.ltg,Buit~-: '

, 'December 16. 1997, RevisK».l:O:

'('able .~- S~ple Cnntainersand Preservatives

One (1)~ll:llon~ipIQCbag for soiids;Ol'le (I)~allon

cubitail1er fodiquids

One (1) gallon ziplQCbag for .,Jolids; Dlle( \)gallou

oubitainet fQt iiq\ti<ls

o.IM$ille Envelope

Glassine Envelope

43

A;ppr!ilWlmte LabQratQry··St!b~~ple

Required

Ollel)tmdr.d (lOO)~raltls fQ[ solids; One (I) liter

for liquids

TWenty"fwe (25) gfilms [(if solids; One (lJ liter

forli'lujcts

Not applicable

Not applicable

Pr~.rvativeand

Haudling

N<>l applicable

N<>t applicable

Not applicable

Not applicable

DRAFT

301522

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I 14

Holt Hauling and Warehousing System, Inc. !tFieJd Operations Plan for the AnnstroJIg Building"


Page 44

Table 4 - Sample Preparation and Analysis Methods

Vari~le

GatnmaRay Identification

Isotopic Thorium

Gross Alpha and Seta Levels (smears)

Gross Alpha and Seta Levels (air filters)

Sample Preparation

Crusb and grind solid samples; no sample

prep!lfation required for liquid media

Crush and grind solid samples; digest and

extract thorium from all media

Not applicable

Not applicable

Method Type

Gamma spectroscopy

Alpha spectroscopy

~

Low Background Alpha/Beta Counting

Low Background Alpha/Beta Counting

Method Reference

a HASL 300, 4.5.:1;3

USEPA 901.1

USDOE ER200c

USEPA 9OO.0d

USEPA 900.0

aEnvironmental Measurements Laboratory (Health and Safety Laboratory) Procedures Manual (Gamma Radioassay Procedure)

bUnited States Environmental Protection Agency Gamma Radioassay Procedure

cLos Alemos National Laboretory Analytical Procedures

dUnited'States Environmental Protection Agency Gross Alpha/Beta Procedure

44 DRAFT

301523

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Page 45

Table 5 - Quality Control Measures and Frequency (Solid Matrix - All Analyses)

QC Control Sample

Method Blank

Laboratory Control Sample

(LCSILCSD)a

Duplicates

Matrix Spik~s (MS/MSD)

Frequency

One (I) for each set of up to 20 samples

One (I) pair for each set of up to 20 samples

One (1) for each set of up to 20 samples

One (1) pair for each set of up to 20 samples

Acceptance Criteria

Results less than MDL C

unless concentration of analyte is greater than or equal to five (5) times the

blank concentration

Percent recovery d between 80-120%; RPD less than or equal to 20 %

Range less than or equal to four (4) times the

MDL for results less than five (5) times the MDL

RPD less than or equal to 30% for values greater than or equal to five (5)

times the MDL

Per cent recovery between 65-135%; RPD less than or equal to 30 %

a Laboratory Control Sample/Laboratory Control Sample Duplicate

bMatrix Spike/Matrix Spike Duplicate

CMethod Detection Limit

dRelative Percent Difference

45

Corrective Action

Stop the analysis and correct the problem;

reprepare and reanalyze the samples

Stop the analysis and correct the problem;

reprepare and reanalyze the samples

Reprepare and reanalyze the duplicates and 25 %

of the samples with positive results to spot check precision of the

batch

Reprepare and reanalyze matrix spikes and 25 % of the samples with positive

results to spot check precision of the batch

DRAFT

301524

3

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, 6

7

8

9

10

11

Analysis

Radiochemistry


December 16.1997, Revision 0

Page 46

Table 6 - Minimum QA Sample Requirements

Standard Matrix a Sample Matrix b Sample Method (QC Check Standard) Duplicate Blank

Spike Duplicate Spike Duplicate

5% 5% 5% 5%c 5%c 5%

a A standard marrix spike (QC Check Standard) is a spike into a blank which is carried through sample preparation and digestion to sample analysis. The blank matrix is a reagent blank for aqueous samples and a standard soil for a solid matrix, if available; if a standard soil is not available, spiking is done on a reagent blank. This spike is also called a QC Check Standard because the standards used to prepare the spiking solution are from a different source than those used for calibration standards.

b A Sample Matrix is a spike into a sample matrix which is carried through sample preparation, digestion, and sample analysis.

CMatrix Spike Duplicates and Sample Duplicates are performed if provided to the laboratory.

46 DRAFT

301525

FIGURES

47

Holt Hauling and Warehousing System. Inc, "Field Operations Plan for the Armstrong Building"


Page 47

DRAFT

301526

2

3

I QA Manager

A. J. Boerner, C.H.P.

I


December l6, 1997, RevistonO

Page 48

Figure 1 - Project Organization

Program Manager C. D. Ber er, C.H.P.

I Field Manager Peer Reviewer

and Health/Safety OIlieer B. A. Kelly, C.H.P., P.E. R. A. Dutf, R.R.P.T.

I

I Field Personnel Analytical Services

(Outreach Laboratory Broken Arrow, OK)

Project Manager - R. Eidson QA Officer - Brian Duzan

48 DRAFT

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Page 49

Figure 2 - Chain of Custody Form

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INTSG~AT~6 EN\llFl61UVlEMTAL MA~AaEMENT ,INC. ANALYSIS REQUEST AND

CHAIN OF CUSTODY RECORD Page of - -Reference No

(1) Client Name (7) Samples Shipment Date (5) Bill to:

(2) Collected By: 181 lab Destination

(3) Job/Task No: 19) lab Contact

14) Project Manager: 112) IEM Technical Contact/Phone 11 01 Report to:

(6) Purchase Order No. (13) Carrier/Waybill No.

111) Required Report Date , - -----~ -- -- ---- ------- ---_.- --- --~ ----~-

ONE CONTAINER PER LINE 114) Sample Number 115) Sample (16) DatelTime Collected (1 n Container Type (18) Sample Volume (19) Preservative (20) Requested Testing Program

Description/Type

(23) Special Instructions

124) Possible Hazard Identification 125) Sample Ilisposal Non-hazard 0 Flammable 0 Skin Irritant 0 Poison B 0 Unknown 0 Return to Client 0 Disposal by lab 0 Archive months

1261 Turnaround Time Required: Normal 0 Rush 0 127) QC Level: 10 110 1110 Project Specnic

1281 Relinquished by: Isignature, date, time): Received by: Isignature, date, time)

Relinquished by: (signature, date, timel: Received by: Isignature, date, timel

j by: . o.t. tim.l· Received bv: . date. timel (See Reverse for Instructions)

301529

INSTRUCTIONS FOR COMPLETING THIS FORM

1. Client Name: Record the name of the client/site location.

2. Collected By: List the name of the person taking these samples,

3. Job/Task No.: Indicate the IEM job/task number, if applicable.

4. Project Manager: Record the (EM project manager's name.

6. Purchase Order No.: Non-IEM personnel should use this space to record the purchase order number authorizing the analysis of these samples. IEM and IEM subcontractors should leave this space blank jf a project number has been given for billing.

0-7. Samples Shipment Date: Indicate the date these samples are shipped to the laboratory.

,. 8. lab Destination: Indicate the laboratory designated for sample shipment. 00 not list more than one lab on this form. Be certain before sending samples that the laboratory you are designating is aware of the shipment and is capable of accepting these sample types and has available capacity.

9. Lab Contact: Give the name of the laboratory contact (typically the lab's project manager).

O. Report to: Give the name, address and phone number of the person to receive the data report for these samples.

11. Required Report Date: Record the date which you and the laboratory contact have determined the results will be reported {include ;:;,: verbal or final report as appropriate},

12. Technical Contact/Phone: Indicate the name of the person to be contacted in case of any questions regarding these samples and the phone number where the contact may be reached the day the samples arrive in the laboratory.

13. Carrier/Waybill Number: If you are sending the samples by a commercial carrier such as Airborne or Federal Express, record the ""courier company name and the waybill or airbill number under which these samples will be shipped (Example - Fed-Ex/#513631771),

4. Sample Number: List the complete, unique identification number of each sample. These numbers must correspond with the :identification numbers on the sample containers and the field sample collection document(s).

15. Sample Description/Type: Provide a short physical description of the sample and the sample type such as soil, sediment, sludge, Iwater, wipe, air, concentrated waste or bulk. (0~;

16. Date/Time Collected: Record date and exact time each sample was collected. Use a 24-hour clock; i.e., 1645 not 4:45 p,m,

:::'.17, Container Type: Indicate the volume, color and type of the sample container LOsed (Example - 1 gallon amber glass, 1 liter dear ,~;;:;plastic, 40 milliliter clear glass).

8. Sample Volume: Estimate the amount of sample in the container. For air samples, indicate the volume of air sampled.

9. Preservative: Indicate what type of preservative, if any, has been used for the samples (Example - ice to 4cC nitric acid, hydrochloric acid),

'20. Requested Testing Program: List the analyses to be performed on each- sample by method number or quotation number.

23. Special Instructions: Use this space to record any special instructions to the lab regarding the processing of these samp!es.

,24. Possible Hazard Identification: Indicate all hazard classes associated with the sample(s).

25, Sample Disposal: Indicate how the samples should be disposed of following analysis, The lab may charge for packing, additional archiving and disposal.

26. Turnaround Time Required: Check "Normal" or "Rush" as determined by the Technica! Contact and the Lab Contact. Rush samples are subject to a surcharge.

--27. ac Level: These should be specific to the analytical laboratory and should not be confused with USEPA Analytical Levels. Project Specific should reference a quotation number or other specifications that have been submitted to the laboratory before beginning work.

28 Signatures: When releasing custody of these samples, use the "Relinquished By" space to sign your full legal name, date and time of - release. After verifying that all samples are present, the person receiving the samples must sign the "Received By" space to take

custody of the samples.

301530

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14

This report was prepared under the direction of Holt Hauling and Warehousing System, Inc.

by

Alex J. Boerner, C.H.P., Brian A. Kelly, C.H.P .. P.E., and R. Alan Duff, R.R.P.T. Integrated Environmental Management, Inc.

9040 Executive Park Drive, Suite 205 Knoxville, Tennessee 37923

(423)531·9140

and

Carol D. Berger, C.H.P. Integrated Environmental Management, Inc.

1680 East Gude Drive, Suite 305 Rockville, Maryland 20850

(301)762·0502

301531

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Field Operations Plan for the Armstrong Building

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