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Page 1: 11-153 NRF-43 Sample and Analysis Plan cmh · PDF fileSite NRF-43 Sample and Analysis Plan 22 Pages . ... Sample and Analysis Plan ... by 150 feet with Cs-137 levels greater than 16.7
Page 2: 11-153 NRF-43 Sample and Analysis Plan cmh · PDF fileSite NRF-43 Sample and Analysis Plan 22 Pages . ... Sample and Analysis Plan ... by 150 feet with Cs-137 levels greater than 16.7
Page 3: 11-153 NRF-43 Sample and Analysis Plan cmh · PDF fileSite NRF-43 Sample and Analysis Plan 22 Pages . ... Sample and Analysis Plan ... by 150 feet with Cs-137 levels greater than 16.7

Attachment 1

to NR:IBO-11/153

Site NRF-43 Sample and Analysis Plan

22 Pages

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Sample and Analysis Plan

BWSR EEW: G. Garrett PHONE: (208) 533-5821 DATE: 06/21/11

TASK/CHARGE NUMBER

2005

WORK DOCUMENT NUMBER

BWSR-SAP-019-11

SAP TITLE Sample and Analysis Plan (SAP) for the Characterization of the CERCLA Site 43.

PART A: SAP REVIEW AND APPROVAL BWSR EEW PEER REVIEW

BWSR OPERATIONS SUPERVISOR

BWSR ERW REVIEW

BWSR INDUSTRIAL SAFETY ENGINEER REVIEW

BWSR QUALITY ENGINEER

BWSR ENVIRONMENTAL AND WASTE MANAGER

BMPC RADILOGICAL CONTROLS ENGINNEERING REVIEW

BMPC ENVIRONMENTAL ENGINEERING REVIEW

APPROVED BY: BMPC ENVIRONMENTAL CLASSIFIER

DATE

PART B: SAP CHANGE/P&I RECORD (Additional space on next page) CHANGE LETTER/P&I NUMBER DATE ENTERED CHANGE/P&I ENTERED BY CHANGE BRIEFED BY/DATE

PART C: SAP CLOSEOUT REVIEW BWSR ENVIRONMENTAL ENGINEER DATE BWSR QUALITY ENGINEER DATE

BWSR DOCUMENT CONTROL SPECIALIST DATE

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BWSR-SAP-019-11

ii

PART B: (continued) CHANGE LETTER/P&I

NUMBER DATE ENTERED CHANGE/P&I ENTERED BY CHANGE BRIEFED BY/DATE

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BWSR-SAP-019-11

iii

LIST OF EFFECTIVE PAGES PAGE NUMBERS: CURRENT CHANGE: SAP Pages i and ii Original

SAP Page iii OriginalSAP Pages 1 through 10 OriginalAttachment 1 Pages1 and 2 OriginalAttachment 2 Page 1 OriginalAttachment 3 Page 1 OriginalAttachment 4 Pages 1 through 4 Original

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BWSR-SAP-019-11 Page 1

SAP for the Characterization of the CERCLA Site 43.

TABLE OF CONTENTS…………………………………………………………………………… ……………….1 1.0 INTRODUCTION .............................................................................................................................. .2 2.0 PROJECT OBJECTIVES ................................................................................................................... 4 3.0 TRAINING/BRIEFING REQUIREMENTS .......................................................................................... 4 4.0 SAMPLING DESIGN AND PROCEDURES ...................................................................................... 5 5.0 SAMPLE MANAGEMENT AND DOCUMENTATION ........................................................................ 8 6.0 SAMPLE ANALYSIS AND ANALYTICAL METHODOLOGY ............................................................ 9 7.0 QUALITY CONTROL (QC) REQUIREMENTS ................................................................................ 10 8.0 SAFETY AND PERSONAL PROTECTION ..................................................................................... 10 9.0 REFERENCES ................................................................................................................................ 10 ATTACHMENT 1 SAMPLE AND ANALYSIS INITIAL BRIEF SHEET

ATTACHMENT 2 SAMPLE INSTRUCTIONS

ATTACHMENT 3 REQUIRED SAMPLES

ATTACHMENT 4 NRF-43 PICTURES AND SAMPLE RESULT GRIDS

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BWSR-SAP-019-11 Page 2

SAP for the Characterization of the CERCLA Site 43.

1.0 Introduction

The purpose of this Sample and Analysis Plan (SAP) is to collect and assess the analytical data obtained from environmental soil samples collected at the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Site NRF-43 (Seepage Basin Pump Out Area). This is to ensure the soil that is to be remediated meets the Waste Acceptance Criteria (WAC) for the purposed disposal at the Idaho CERCLA Disposal Facility (ICDF) landfill. The sampling will be performed in accordance with Technical Work Document #BWSR-TWD-2005-001 that incorporates this SAP. Background The Old Sewage Basin (NRF-21A) was constructed in 1956 and expanded in size in 1957. It consisted of an open pond used for non-radiological discharges. In 1956, NRF-21A was cross-contaminated by the radioactive discharge system. In August 1958, the contents of the Old Sewage Basin were pumped out to the area adjacent to NRF-21A and this became the Seepage Basin Pumpout Area (NRF-43). This is the only known discharge of radioactive water to the NRF-43 area. The amount of radioactivity released from NRF-21A at the time of the pump out is not known. Surveys performed in 1958 at the Seepage Basin Pump Out Area indicated radiation levels of 0.5 milliRem per hour. The Old Sewage Basin was closed in 1960 when the current sewage lagoons were constructed northeast of NRF. The Old Sewage Basin was then filled in the early 1960s with soil and lava rock excavated from the S5G construction. Historic sampling has shown some detectable levels of radioactivity in the NRF-43 area. The Old Sewage Basin and the surrounding area were routinely surveyed and sampled as part of the NRF Environmental Monitoring Program from 1977 to 1993. Elevated levels of cesium-137 (Cs-137) were detected in the Seepage Basin Pump Out Area in 1977 (457 pCi/g) and 1983 (26 pCi/g). For those contaminated areas, the exact sample locations and whether the contamination was cleaned up after the discovery are unknown. The Old Sewage Basin and the Seepage Basin Pump Out Area were added as CERCLA sites in 1991. During the NRF Comprehensive Remedial Investigation/Feasibility Study (RI/FS), CERCLA remedial investigation samples were collected from both areas in 1996 using a regulatory approved sampling plan that employed a random sampling pattern over the existing sites. The highest Cs-137 activity detected in the Seepage Basin Pump Out Area in 1996 was 31.5 pCi/g. Based on the sample results and risk assessments performed under CERCLA, the Seepage Basin Pump Out Area (NRF-43) was designated a “No Further Action” site and the Old Sewage Basin (NRF-21A) was designated a “Remedial Action” site in the NRF Final Record of Decision (ROD). An engineered cover was constructed over Old Sewage Basin (NRF-21A). The “No Further Action” designation for NRF-43 required institutional controls to be implemented at the site. These controls are presented in the NRF Institutional Controls Plan and include installation of warning signs, excavation controls, and annual inspections. The NRF Final ROD established a remediation goal for Cs-137 of 16.7 pCi/g. The remediation goal was based on the protection of human health to “prevent external gamma radiation exposure from all radionuclides of concern that exceed a total exposure pathway excess cancer risk of 1 in 10,000 for the future 100-year residential receptor.” The ROD assumed that remediated sites would remain under Federal government control for at least 100 years. The contaminant of concern is Cs-137 as evidenced from historic sampling of the site as well as sampling conducted under the NRF Comprehensive RI/FS and as discussed in the NRF Final ROD. The current annual sampling of areas within NRF-43 is conducted in support of the NRF Environmental Monitoring Program and is not part of the CERCLA response actions.

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BWSR-SAP-019-11 Page 3

SAP for the Characterization of the CERCLA Site 43.

In 2009, one sample result from the annual radiological soil samples collected from around NRF-21A in support of the NRF Environmental Monitoring Program was above the remediation goal for Cs-137 of 16.7 pCi/g. The location of this sample was determined to be just inside the boundary of the CERCLA “No Further Action” Site NRF-43. Follow-up sampling around this sample location revealed an area of contamination approximately 100 feet (ft) by 150 feet with Cs-137 levels greater than 16.7 pCi/g. The Environmental Protection Agency (EPA) and the Idaho Department of Environmental Quality (IDEQ) were notified of the elevated Cs-137 levels from the 2009 sampling events. In 2010, additional sampling at NRF-43 included the collection of soil radiological samples. A field radiological survey was done using a gamma scintillation survey meter to select the sample locations. Also, the sampling targeted those areas with the highest probability of having contaminants based on existing information (e.g., previous sample results, low spots, crevices, etc.) and where the radiological survey showed instrument readings above background levels. The following criteria were used for this survey and sampling effort:

1. If the instrument readings within a 50 ft by 50 ft grid were at the background level, then at least one soil sample was collected within the grid.

2. If instrument readings greater than twice the background level were detected within a 50 ft by 50 ft grid, the grid was designated as an area to be both surveyed and sampled more extensively.

3. For the case when instrument readings were greater than the two times the background level at specific locations within a 50 ft by 50 ft grid, these locations were selected for the collection of additional soil samples (a minimum of two soil samples were collected).

4. If the soil sample result(s) was equal to or greater than the CERCLA clean-up level for Cs-137, the 50 ft by 50 ft grid was divided into 10 ft by 10 ft grids around the elevated sample area then the field survey coverage was increased to 100% of the area and additional samples were collected within these smaller grids.

5. Samples collected from all locations were analyzed by NRF Chemistry for gamma emitters (specifically, cesium-137 and cobalt-60). However, Cs-137 is considered to be the primary contaminant of concern for Site NRF-43.

During the 2010 survey, Cs-137 was detected in two other distinct areas just inside or adjacent to the original boundary of NRF-43 on the east side. The surface soil sample results indicate that these areas are consistent with a discharge of liquid to the surface (i.e., contamination was found in low spots within or adjacent to NRF-43). The exact location of the area where the contaminated liquid from the old sewage basin was pumped out is not known and the original boundary of the pump out area was estimated by older photographs that showed bulldozer marks, elevation drawings, and evidence of debris. The three areas where elevated Cs-137 was found are in close proximity to each other and vary in size with a combined total area of about 18,000 sq. ft. The levels of radioactivity detected in these areas were above the CERCLA clean-up level for Cs-137 established in the NRF Final ROD. NRF-43 Site Location Pictures (Attachment 4 pages 1 and 2) show the sample areas where surveys and sampling were performed in 2010, including the area of contamination found in 2009, in relationship with the original NRF-43 Boundary. Sample results and grid locations of the 2009 and 2010 sample surveys are shown on Attachment 4 pages 3 and 4. The sampling data was evaluated by comparing the results to background and the CERCLA clean-up level for Cs-137 established in the NRF Final ROD. This sampling helped determine the location of the elevated Cs-137 areas within the pump out area.

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BWSR-SAP-019-11 Page 4

SAP for the Characterization of the CERCLA Site 43.

2.0 Project Objectives

The primary objective of this sampling effort is to obtain analytical data of the soil to be remediated from the CERCLA Site NRF-43 (the Old Sewage Basin Pump Out Area) for waste characterization to ensure that the soil meets the Waste Acceptance Criteria (WAC) for disposal at the ICDF. Even though radionuclides are the only identified contaminants of concern, a conservative sampling approach is being used that include off-site analyses of the soil to be remediated for other constituents including PCBs for waste characterization purposes. 3.0 Training/Briefing Requirements

3.1. The Engineer of Environmental Work (EEW), or designated representative, will conduct an

initial briefing of the entire sampling effort prior to the start of work. The briefing will be documented on a Sample and Analysis Plan Initial Brief Sheet (Attachment 1). This briefing sheet will stay attached to the SAP for documentation of the briefing.

BWSR Environmental Badge # Date

3.2. Equipment List

120 ml glass amber sample bottles 250 ml glass amber sample bottles Sample labels, seals, waste disposition stickers Chain of Custody (COC)/Analytical Request Form Logbook Cleaning solution (Alconox/Liquinox, DI water, Ethanol) Leather gloves Safety glasses Plastic butter dishes Tape measure Core drill Sample Collection Tools: stainless steel auger buckets and extensions Handle for the auger buckets Spatula/Scoop Scale Stainless steel bowls and pans Teri towels Para film

3.3. A representative of the BWSR Environmental department will verify that all sampling supplies and equipment are assembled and readily available to the work group. BWSR Environmental Badge # Date______

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BWSR-SAP-019-11 Page 5

SAP for the Characterization of the CERCLA Site 43.

4.0 Sampling Design and Procedures An authoritative sampling approach will be utilized for this sampling project to provide the highest activity values for disposal at the ICDF. All sample data provided by the commercial laboratory will be validated by an independent subcontractor. Details of this sampling project are discussed below. To meet the waste profile requirements of the ICDF WAC, the volume of contaminated soil and the number of waste characterization samples need to be determined. The ICDF waste profile and sample guidance document, Reference 9.2, presents the guidelines for determining the required number of waste characterization samples for off-site analyses, which are based on soil volume. On site radiological sample results that are > 16.7 pCi/g Cs-137 will be used to estimate the volume of contaminated soil. To assist in the determination of the sample locations, the grids in Attachment 4, Pages 3 and 4 showing levels > 16.7 pCi/g Cs-137 will be surveyed with field instruments in accordance with BWSR-TWD-2005-001. The location within each grid surveyed with the highest field instrument reading will be selected for the collection of samples to be submitted to NRF Chemistry for radiological sample analysis. To determine the depth of contamination, discrete core samples will be taken every eight inches of depth until an eight inch core sample result for a given location is <16.7 pCi/gm Cs-137. The estimated volume of soil to be remediated will be calculated based on the radiological analytical results that are > 16.7 pCi/g Cs-137 from the samples collected from all of the designated grid sample locations. Then the number of sample sets to be sent off-site for analysis in order to meet the ICDF WAC will be determined based on this estimated volume. All radiological soil samples with levels > 16.7 pCi/g Cs-137 for off-site analyses will be held and ranked from highest to lowest activity level. Based on the analytical methods identified in Table 4.1, the amount of sample material required for a single off-site sample set has been estimated to be approximately 2000 grams of soil. In order to acquire the necessary sample material for the off-site sample sets, the radiological soil samples will be combined starting from the highest activity level and working to the lowest activity level as discussed below. This approach will provide the highest activity values for the radiologically contaminated soil to be remediated. For clarification, assume 500 radiological soil samples were collected and identified as containing > 16.7 pCi/g Cs-137 during the performance of the sampling effort in accordance with BWSR-TWD-2005-001 and that 10 core samples are needed to collect a complete sample set. The volume of contaminated soil to be remediated is based on the extent of radioactivity identified during the radiological sampling effort. The radiological soil samples are placed in order from highest to lowest activity with 16.7 pCi/g Cs-137 being the lowest activity. Suppose that five off-site sample sets are required to satisfy the WAC for ICDF for the estimated volume of soil to be remediated. Starting with the radiological soil sample with the highest activity level and working down the first 10 radiological samples would be combined to form the first off-site sample set and the next ten radiological samples would be combined to form the second off-site sample set and so forth until five off-site sample sets were formed.

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BWSR-SAP-019-11 Page 6

SAP for the Characterization of the CERCLA Site 43.

Table 4.1 contains pertinent information for the samples to be analyzed by the off-site laboratory. This table includes sample hold times, sample size, sample preservation requirements, and container specifications for each sample analysis. The TCLP analyses are combined into one jar in order to minimize the amount of radioactive material in shipment and at the lab. The collection of the off site sample sets will be performed in the following manner.

4.1. Prior to collection of the samples, sample containers with their respective lids will be individually weighed.

4.1.1. Lids and containers will be maintained as unique sets.

4.1.2. The tare weight will be recorded on each container.

4.2. Decontamination 4.2.1. To prevent cross-contamination of samples all sample collection tools will be

decontaminated prior to use and between sample sets as stated:

4.2.1.1. Swab with Reagent Alcohol

4.2.1.2. Visually inspect the tools to ensure there is no visible dirt or other possible contamination.

Table 4.1

Analysis

Hold Times for

Extraction and

Analysis

Sample Size Preservative Container Type/Size

Radiochemistry Fe-55, Ni-63,

Total Sr, Tc-99, I-129, Isotopic Pu,

Isotopic U Am-241, Gamma

Spec

6 Months 6 Months 100 grams None 120 ml amber glass

jar

C-14 6 Months 6 Months 5 grams None 120 ml amber glass

jar

Tritium 6 Months 6 Months

100 grams 200 grams (MS/MSD)

None 120 ml amber glass jar

TCLP Metals, TCLP Volatiles,

TCLP Semi-Volatiles,

TCLP Herbicides, TCLP Pesticides

Metals:28 days to

Extraction. 28 days to Analysis.

All Others: 14 days to

Extraction. 14 days to Analysis

105 grams

20- 60C

120-ml amber glass jar

Total Metals

28 days to Extraction 28 days to Analysis

1.0 gram 3.0 grams (MS/MSD)

20- 60C 120 ml amber glass jar

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BWSR-SAP-019-11 Page 7

SAP for the Characterization of the CERCLA Site 43.

Analysis

Hold Times for

Extraction and

Analysis

Sample Size Preservative Container Type/Size

Total Volatiles

14 days to Extraction 14 days to Analysis

1-120 ml with no head space

3-120 ml (MS/MSD)

20- 60C 120 ml amber glass jar(s)

Total Semi-Volatiles

14 days to Extraction 14 days to Analysis

1-250 ml with no head space 20- 60C 250 ml amber glass

jar

Total Herbicides

14 days to Extraction 40 days to Analysis

10 grams 30 grams (MS/MSD)

20- 60C 120 ml amber glass jar

Total Pesticides

14 days to Extraction 40 days to Analysis

10 grams 30 grams (MS/MSD)

20- 60C 120 ml amber glass jar

PCBs 40 days to Analysis

10 grams 30 grams MS/MSD

20- 60C 120-ml amber glass jar

Total and Amenable Cyanides

14 days to Extraction 14 days to Analysis

10 grams 30 grams (MS/MSD)

20- 60C 120 ml amber glass jar

4.3. If unusual conditions are encountered, contact the EEW for resolution.

4.4. Attachment 3 will be completed by EEW and Work Group as follows:

4.4.1. All radiological core samples will be counted by NRF Chemistry. Only the radiological core samples proven by NRF Chemistry analysis to be > 16.7 pCi/g Cs-137 will be used to generate the sample sets for off-site analysis.

4.4.2. BWSR and NRF Waste & Shipping will determine the number of samples sets required for ICDF and will issue an individual Attachment 3 for each sample set required with unique sample numbers identified.

4.4.2.1. Matrix spike (MS) and matrix spike duplicates (MSD) will be collected as directed by the EEW and Waste and Shipping and recorded on Attachment 3.

4.4.3. If there is not enough radiological core samples > 16.7 pCi/g Cs-137 to make-up the off-site sample sets identified in step 4.5.2, additional radioactive soil will be collected from those grids identified as having the highest level of radioactivity.

4.5. Once enough radioactive soil has been collected to perform the required off-site sampling as identified on Attachment 3, collect the sample sets as follows:

4.5.1. Rank the radiological core samples from highest to lowest activity from the NRF Chemistry results.

4.5.2. Using the appropriate number of radiological core samples for samples for each set as explained in the narrative of section 4.0, collect the off-site sample sets per Attachment 2.

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BWSR-SAP-019-11 Page 8

SAP for the Characterization of the CERCLA Site 43.

4.5.3. Record on Attachment 3 the grid locations and depth of each radiological core sample used for the off-site sample sets.

4.6. Submit all samples to NRF Chemistry for gamma counting prior to shipping.

4.7. Sample debris generated from the sample locations will be collected, and staged in an approved PCB sample debris storage location (i.e. PCB-BWSR-001). The bags of sample debris are not RCRA hazardous per HEF 2766. The bags generated will be handled per NRF 2450 “Guilty Until Proven Innocent” and will be labeled with a PCB Waste sticker (NRF stock item MIS 61002) and labeled with a PCB label and Out of Service Date and marked as follows:

BWSR-SAP-019-11 Sample numbers

Date

4.8. Contact BMPC Environmental Engineering (3-5478) and report the number of each analyzes that will be done for data validation purposes.

5.0 Sample Management and Documentation 5.1. After collection of the samples:

5.1.1. Sample collection data will be entered on a COC. This form will accompany the sample material from the time of collection to the time it is received by the analytical laboratory and will be maintained with the results.

5.1.2. The samples will be stored and shipped at 20- 60C.

5.1.3. The logbook, COC forms, laboratory analytical results, and Appendices will serve as official documentation of the sampling evolutions.

5.2. Each individual sample that is collected will be identified with a unique sample number that will be recorded in the logbook. The sample number log is maintained, and numbers are assigned by BMPC Waste and Shipping. Sample bottles will have labels and seals attached that contain the following information: Sample number, name of collector, date and time of collection, place of collection, and type of sample.

5.3. Log book documentation.

All information pertinent to the sampling effort will be recorded in a bound field logbook with consecutively numbered pages. Any anomaly encountered, or changes made to this sampling evolution will be recorded in the logbook.

5.3.1. The following information at a minimum will be included: � Sample ID numbers. � Location of the sampling point and a description of the sample matrix. � Name and badge number of EEW (G. Garrett, F00004). � Name and badge number of field contact/sampler. � Generator of the waste (BWSR). � Type of process producing the material (e.g. sampling for the purpose of soil characterization). � Type of material (e.g. tools, equipment, liquid, etc.). � Suspected material composition (e.g. soil). � Purposes of sampling (characterization for control and disposition determination). � Date and time of sample collection. � How transported to lab (Shipped Fed-Ex or other approved method to a lab determined by NRF

Waste and Shipping). � Field observations (e.g. unusual odors, difficulty in sample collection, appearance of the sample

materials, etc.). � Identification of personnel present during the sampling effort.

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BWSR-SAP-019-11 Page 9

SAP for the Characterization of the CERCLA Site 43.

� Technical work document and SAP identification numbers at the top of each page (BWSR-TWD-2005-001, BWSR-SAP-019-11).

� Deconning of sampling equipment (identify when it is done and how). � Equipment used to collect sample (e.g. auger bucket, stainless steel scoop, etc.). � Description of any QC samples collected (e.g. matrix spike and matrix spike duplicates). � Sample shipment release number.

The following table shall be copied into the logbook and completed as samples are collected and the indicated information is obtained.

Table 5.1 Data Recording Table (Example).

Bottle Sample

#

Analysis

Date

Time

Tare (g)

Gross (g)

Net (g) Size (ml)

RAD Levels

Release #

Comments

Do not photocopy and tape this table into the logbook. It must be copied in black ink.

5.4. A unique sample number will be assigned to each sample and recorded in Attachment 3. The sample identification number will be clearly marked on the sample labels and seals affixed to each sample and on the COC/analytical request form. The COC form will be returned by the laboratory with the sample results and will be retained with the analytical data. All necessary forms and labels should be obtained from the BWSR Environmental Department (243-1395).

5.5. At the completion of sampling, the completed SAP and the logbook will be turned over to the EEW for inclusion in the project file.

6.0 Sample Analysis and Analytical Methodology 6.1. TCLP Metals are performed per SW-846 Methods 1311/6010/7470.

6.2. TCLP Volatiles are performed per SW-846 Methods 1311/8260

6.3. TCLP Semi-Volatiles are performed per SW-846 Methods 8270

6.4. TCLP Pesticides are performed per SW-846 Methods 8081

6.5. TCLP Herbicides are performed per SW-846 Methods 8151

6.6. Total Metals are performed per SW-846 Methods 6010/7471.

6.7. Total Volatiles are performed per SW-846 Methods 8015/8260

6.8. Total Semi-Volatiles are performed per SW-846 Methods 8270

6.9. Total Pesticides are performed per SW-846 Methods 8081

6.10. Total Herbicides are performed per SW-846 Methods 8151

6.11. Total and Amendable Cyanides are performed per SW-846 Methods 9010 or 9012

6.12. PCBs are performed per SW-846 Methods 3540/8082.

6.13. Radiochemistry performed by NRF Chemistry is per local procedures.

6.14. Commercial Lab Radiochemistry is performed as follows:

6.14.1. Gamma Spec per DOE RP-730 MOD.

6.14.2. Total Sr per EML SR-03-RC MO.

6.14.3. Isotopic Pu, Isotopic U, and Am-241 per DOE-A-01-MOD.

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BWSR-SAP-019-11 Page 10

SAP for the Characterization of the CERCLA Site 43.

6.14.4. Ni-63 and Fe-55 per DOE STL-RC-0055.

6.14.5. C-14 per EERF C-01-1.

6.14.6. I-129 per EML Iodine GA-0.

6.14.7. TC-99 per EML TC-02-RC MO.

6.14.8. Tritium per EPA 906.0 MOD.

7.0 Quality Control (QC) Requirements 7.1. Decontamination will be performed prior to sampling (unless tools are new or unused) and

after collection of each sample set in accordance with Section 4.2.

7.2. Gamma specs will be done on all samples at NRF Chemistry for shipping purposes and for comparison to the commercial lab results.

7.3. Additional quality control will be reliant on the quality control program provided by the laboratory, the sample collection procedures, the COC system, split samples, and the MS/MSD samples.

8.0 Safety and Personal Protection 8.1. Radiological and safety controls are established in BWSR-TWD-2005-001

9.0 References 9.1. NRFOSQ-ESH-EE-10-111 Submittal of the Recommended Course of Action for CERCLA

Site NRF-43

9.2. ICDF Complex Waste Profile and Verification Sample Guidance

9.3. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW 846, United States Environmental Protection Agency

9.4. NRF Environmental Controls Manual (NRF 2450 Current Revision)

9.5. Final Record of Decision, Naval Reactors Facility, Operable Unit 8-08, September 30, 1998.

9.6. Radiological and Environmental Characterization of CERCLA Site 43 BWSR-TWD-2005-001

9.7. Job Hazard Analysis (JHA) BWSR-TWD-2005-001

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Page 1

Attachment 1 Sample and Analysis Initial Brief Sheet

Sap Title: SAP for the Characterization of the Dig 43 Soil.

Date SAP # BWSR-SAP-019-11 Associated TWD # BWSR-TWD-2005-001 1. Introduction 2. Project Objectives 3. Radiological Controls 4. Sampling Design and Procedure 5. Sample Management and Documentation 6. Analysis and Methodology 7. Quality Control 8. Safety Requirements and Concerns 9. Equipment and Supplies 10. Shipping Requirements 11. Waste Disposition 12. Questions and Special Concerns Notes:_____________________________________________________________________________

________________________________________________________________________________

Name & Badge # Date Name & Badge # Date

BWSR Environmental Representative Conducting Brief

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Page 2

Name & Badge # Date Name & Badge # Date

BWSR Environmental Representative Conducting Brief

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BWSR-SAP-019-11 Page 1 Attachment 2

Sampling Instructions for Soil

Sample Sets shall be taken as identified on Attachment 3.

Figure 1: Grid layout Sample Tray/Catch 1/30th of sample shall be taken from each grid location.

1 2 3 4 5 6

7 8 9 10 11 12

13 14 15 16 17 18

19 20 21 22 23 24

25 26 27 28 29 30

Instructions:

A. Mix the sample matrix until it looks homogenous. Then spread the soil sample matrix evenly in the sample tray area.

B. The sample tray area will be divided into 30

equal grids. See Figure 1.

C. 1/30th of an individual sample will be drawn from each of the 30 squares to get the total amount of material for the sample.

1. For example, if you are collecting the

TCLP Metals sample, you would collect 3.5 grams from each grid at its respective sub-square location so that you get a total of 105 grams.

D. Apply COC labels and seals to each sample jar

after the required amount of sample matrix for the sample has been collected.

E. Fill in the Chain-of-custody.

F. Repeat steps C. through E. for each sample

required in the sample set.

G. Decontaminate the sample tools per Step 4.2

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BWSR-SAP-019-11 Attachment 3 Required Samples

Page __of ___

Sample Location Sample Number Analysis Sample Size

(Glass Amber bottles)

Sample Set

#___

11-_____

Radiochemistry Fe-55, Ni-63, Total Sr, Tc-99, I-129, Isotopic Pu, Isotopic U

Am-241, Gamma Spec

100 grams / 120 ml

11-_____

C-14 5 grams / 120 ml

11-_____ Tritium 100 grams / 120 ml 200 grams (MS/MSD)

11-_____

TCLP Metals, TCLP Volatiles,

TCLP Semi-Volatiles, TCLP Herbicides, &

TCLP Pesticides

105 grams / 120 ml

11-_____ Total metals 1.0 grams / 120 ml 3.0 grams / 120 ml (MS/MSD)

11-_____ Total Volatiles 1-120 ml (No head space) 3-120 ml (No head space)

(MS/MSD) 11-_____ Total Semi-Volatiles 1-250 ml (No head space)

11-_____ Total Herbicides 10 grams / 120 ml 30 grams / 120 ml (MS/MSD)

11-_____ Total Pesticides 10 grams / 120 ml 30 grams / 120 ml (MS/MSD)

11-_____ PCBs 10 grams / 120 ml 30 grams / 120 ml (MS/MSD)

11-_____ Total and Amenable Cyanides 10 grams / 120 ml 30 grams (MS/MSD)

Record location and depth of radiological core samples used for sample set.

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BWSR-SAP-019-11 Attachment 4 Page 1

NRF 43 Location

Site Picture 1

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BWSR-SAP-019-11 Attachment 4 Page 2

NRF 43 Location

Site Picture 2

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BWSR-SAP-019-11 Attachment 4 Page 3

1b 1.1 1.3 20 13

1a 1.8 12 29 3

5b 1 1.4 85 83 87 46

5a 0.9 4.8 30 3.7 38 36

4a 4b 5a 5b 1a 1b

10 ft � North

2009 Data

20-9 50 ft X 50 ft Grid Coordinate Notes

Sample < 10 pCi/g Original Sampling Point (56 pCi) not shown

Sample � 10 pCi/g and < 16.7 pCi/g Second round of sampling not shown where grids were subsequently divided into 5 ft x 5 ft grids

Sample � 16.7 pCi/g

Grid desigantions are in the lower left hand corner (20-11, 23-11, etc.)

Previous NRF Chemistry sample results in pCi/gm are in each 10 ft x 10 ft subgrid

2009 Sample Results NRF 43

Bold Lines are 50 ft x 50 ft Grid Boundaries

0.7

326

1.2 1.4 1.6

15

8.6

42

9.256

22-8

16 5

34 15.63.4

6.4

308.3 20 9.6

7.7

21

3.4 7.6

5.8 5.1

3.3

0.9

12 28 10

24

42 7.930 11 13

0.6 1.2

23

11

12

2.4

0.1224 12

28

1

�3

0.2

3

2

1

1 2

1

20-7

4

5

4

0.6

0.6

18

2

20-8

0.8 0.6 1.6

65

32

14

4.4

4

2

8.3

5

4

67

4.8

10

44

4.9

0.1 0.13 3.4 15

2.6

3.7 4

3

118

1.2

2.4 1.8

6.7

17

18

22

2245

0.6 2.1

28

2.2

1.1 265.30.420-9

1

3

2

0.14

33

55390.9 1.7 0.9 28

2.9 2

0.6

89150

0.6

1.7

1.3

63

25

1.87.6

51 2 3 4

22-6

22-7

2.2

1.5 1.5

20-10

0.7 1.2

26

0.7 0.15 5.3 19

2.1 2.3

21-10

1.3 4 10 6.6 5.7

3.5 1.6 2.4 2.8

14

27 23 44 24 34

20 3.7 6.2 14

5.1

22-10

10 3.8 8 2.7

6.1 2 9.5

3.6

9.2 5.3

3.2 0.7

1.8 5.3

1.2 0.4

2.4 1.2 22-9

6.8 33 5.633 61 29 6.2 5

6.1

37

4.1

9.5 15

34 9.4

3.5

4.9

1.31.6

1

2.6

4.3 53

1

5

4

3

2

1

20-11 21-11

1.5

22-11 23-11

23-10

23-9

15 7.4 5.7

3.1 2.2

9 4.2 6.7

23-8

5

4

3

2

23-7

1 2

20-6

1.8

3.8 0.7

443.1

6.7 5.2 21-7

4 5353

21-6 23-6

5

4

3

2

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BWSR-SAP-019-11 Attachment 4 Page 4

10 Feet

Grid desigantions are in the lower left hand corner (1-A, 1-B, etc.)

Previous NRF Chemistry sample results in pCi/gm are in each 10 ft x 10 ft subgrid

Sample < 10 pCi/g

Sample � 10 pCi/g and < 16.7 pCi/g

Sample � 16.7 pCi/g

0.5

1.4

2.9

1.5

5.1

1.4

1

Red Boundary established based on PRM-5N Radiological Survey only or Sample Results and Survey

1-AA

2.1

0.7

8.3

0.6

1.5

4-AA

3-AA

4-B <0.54-A

8

1.3 36 1.9

<0.5 0.6 37 55

14

3.4 2.9 5.5 2 <0.5

1.7 12

2.2

0.9

27

120

3-B 0.9 & 3.1 2.83-A 1.9 1.2 2.5

2.7 110

1.3 1 11 56 18 16

1.4

0.8

2-B 2-A 0.4 1 1.8

<0.5

0.91-A

2

1

2 3

1-B

1 2 3 4 5 1

1.3

5

4

3

2

1

2010 Sample Results NRF 43

Bold Lines are 50 ft x 50 ft Grid Boundaries

NORTH

5

4

3

2

1

5

4

4 5 1

5

4

3

2

1

3