COMMONWEALTH OF KENTUCKY MAXEY FLATS DISPOSAL SITE · 2020-05-07 · 61 Forsyth Street, SW Atlanta, GA 30303-3104 (404) 562-8935 John Maybriar, Director KY Department for Environmental

Title: PSVP App.D1: QAPP Revision Number: 0

Date: March 2018 Page 1 of 60

COMMONWEALTH OF KENTUCKY

MAXEY FLATS DISPOSAL SITE

INSTITUTIONAL CONTROL WORK PLAN

APPENDIX D

PERFORMANCE STANDARD VERIFICATION PLAN

SUB APPENDIX D1

QUALITY ASSURANCE PROJECT PLAN



Quality Assurance Project Plan

For

Maxey Flats Disposal Site

2597 Maxey Flats Road

Hillsboro KY, 41049

NOTE: This is a Project-Specific Quality Assurance Project Plan, additional details

related to this plan may be provided by reference in these Maxey Flats Disposal Site,

Institutional Control (IC) Documents: IC Work Plan, IC Performance Standards

Verification Plan, and the IC Health and Safety Plan.

Prepared by

Commonwealth of Kentucky

Department for Environmental Protection

Division of Waste Management

Superfund Branch

Contacts:

Larry Hughes, Superfund Branch Manager, (502) 564-6716

[email protected]

Jeff Webb, Maxey Flats Section Supervisor, (606) 783-8680

[email protected]

Prepared for

US EPA Region 4

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303-3104

(404) 562-9900



March 2018 Approval Page, Commonwealth of Kentucky ____________________________________ Date: ___________________ Larry Hughes, Superfund Branch Manger ____________________________________ Date: ___________________ Jeff Webb, Maxey Flats Section Supervisor ____________________________________ Date: ___________________ Matt McKinley, Radiation Control Branch Mgr.



Approval Page, US EPA Region 4 ____________________________________ Date: ___________________ Pamela J. Langston Scully, Remedial Project Manger



Table of Contents

1.0 PROJECT MANAGEMENT ...................................................... 10

1.1 Distribution List ..................................................................................... 10

1.2 Project Organization ............................................................................. 10 1.2.2 Program Manager ................................................................................................... 12 1.2.3 Project Manager ...................................................................................................... 12 1.2.4 Quality Assurance Managers .................................................................................. 12 1.2.5 Field Operations Leader ......................................................................................... 12 1.2.6 Field Personnel ....................................................................................................... 12 1.2.7 Project Personnel Sign-Off ..................................................................................... 12 1.2.8 Communication Pathways ...................................................................................... 13

1.3 Problem Definition and Background .................................................... 15

1.4 Project and Task Description and Schedule ....................................... 19 1.4.1 Project Description ................................................................................................. 19 1.4.2 Task Description .................................................................................................... 19

1.4.2.1 Surface Water .................................................................................................. 19

1.5 Quality Objectives and Criteria for Measurement Data ........................ 23 1.5.1 Project Objective ..................................................................................................... 23 1.5.2 Summary of ROD identified RAO and ARAR Contaminants ................................. 24 1.5.3 Objectives and Project Decisions .......................................................................... 27 1.5.4 Action Levels .......................................................................................................... 28 1.5.5 Measurement Performance and Acceptance Criteria ............................................ 31

1.5.5.1 QA Objectives for Measurement Data ............................................................. 31

1.5.5.2 QA Objectives for Field Sample Data .............................................................. 31

1.5.5.3 Quality Control ................................................................................................. 31

1.5.5.4 Measurement Quality Objectives ..................................................................... 31

1.6 Special Training Requirements and Certification ................................. 33

1.7 Documents and Records ...................................................................... 33 1.7.1 QA Project Plan Distribution ................................................................................... 34 1.7.2 Field Documentation and Records ......................................................................... 34 1.7.3 Laboratory Documentation and Records ................................................................ 34 1.7.4 Annual Reports ....................................................................................................... 34

2.0 DATA GENERATION AND ACQUISITION ............................. 36

2.1 Sampling Design .................................................................................. 36 2.1.6.4 Groundwater ....................................................................................................... 42 2.1.7 Sample Volume and Measurements ...................................................................... 42 2.1.7.1 QC Sampling ....................................................................................................... 42 2.1.7.2 Sample Preservation ........................................................................................... 43 2.1.7.3 Holding Time ....................................................................................................... 43

2.2 Sampling Methods ..................................................................................... 43

2.3 Sample Handling and Custody ............................................................. 44

2.4 Sample and Measurement Identification ................................................. 44

2.5 Chain of Custody Procedures ................................................................. 45 2.5.1 Field Custody Procedures ....................................................................................... 45 2.5.2 Transfer of Custody and Shipment ......................................................................... 45 2.5.3 Laboratory Custody Procedures ............................................................................. 45



2.6 Analytical Methods ..................................................................................... 47 2.6.1 Field Measurements Methods ..................................................................................... 47 2.6.2 Field Analyses Methods ............................................................................................... 48 2.6.2.1 Screening .................................................................................................................. 48 2.6.2.2 Definitive ................................................................................................................... 48 2.6.3 Off-Site Laboratory Analyses Methods ........................................................................ 48

2.7 Quality Control Requirements .................................................................... 48 2.7.1 Field Sampling Quality Control .................................................................................... 49 2.7.2 Field Measurement/Analysis Quality Control ............................................................... 49 2.7.3 Laboratory Analysis Quality Control............................................................................. 49

2.8 Instrument and Equipment Testing, Inspection, and Maintenance ...... 50 2.8.1 Field Measurement Instruments and Equipment .................................................... 50

2.9 Instrument and Equipment Calibration and Frequency .............................. 52 2.9.1 Field Measurement Instruments and Equipment ........................................................ 52

2.10 Inspection and Acceptance Requirements for Supplies and Consumables ......................................................................................................................... 52

2.10.1 Field Sampling Supplies and Consumables .......................................... 53 2.10.2 Laboratory Analyses Supplies and Consumables ..................................................... 53

2.11 Data Acquisition Requirements ................................................................ 54

2.12 Data Management .................................................................................... 54

3.0 ASSESSMENT AND OVERSIGHT .............................................. 55

3.1 Assessments, Oversight, and Response Actions ...................................... 55

3.2 Reports to Management ............................................................................. 55

4.0 DATA REVIEW AND USABILITY ................................................ 56

4.1 Data Review, Verification, and Validation Requirements ........................... 56

4.2 Verification and Validation Methods ........................................................... 57 4.2.1 Data Verification ...................................................................................................... 57

4.3 Reconciliation with User Requirements ..................................................... 58

5.0 REFERENCES ............................................................................ 59



List of Tables

Table 1-1: Distribution List ……………………………………………………………. 7

Table 1-2: Organizational Contacts …………………………………………………..11

Table 1-3: Sampling Schedule ………………………………………………………..20

Table 1-4: Groundwater COC ARARs ……………………………………………….23

Table 1-5: Surface Water COC ARARs (Chemical) ………………………………..23

Table 1-6: Surface Water COC ARARs (Radiological) ……………………………24

Table 1-7: Contaminant Monitoring Action Level Summary ……………………….27

Table 1-8: Schedule of ICP Data Submittal and Monitoring Reports……………..32

Table 2-1: Predetermined Peak Outlet Outflow…………………………..……….40

Table 2-2: Owner’s Manual Links for Field Equipment …………………………….48

Table 2-3: Field Sampling Supplies…………………………………………………..50

Table 2-4: Laboratory Supplies ……………………………………………………….50

List of Figures

Figure 1-1: Organizational Chart …………………………………………………….. 8

Figure 1-2: Personnel Sign-Off Sheet ……………………………………………….10

Figure 1-3: MFDS Location……………………………………………………………13

Figure 1-4: MFDS Property Boundaries ……………………………………………..14

Figure 1-5: Surface Water Sampling Locations …………………………………….18

Figure 1-6: Groundwater Sampling Locations ………………………………………19

Figure 2-1: IMP Monitoring Locations 107C and 143 ………………………………38

Figure 2-2: MFDS Chain of Custody Form ………………………………………….43



List of Appendices Appendix A: MFDS Sampling and Analysis Plan

Appendix B: MFDS Laboratory Manual

Appendix C: CHFS Laboratory Procedures



List of Acronyms CD ............................................................................................Consent Decree CHFS ....................................................... Cabinet for Health and Family Services CMP ...................................................................... Custodial Maintenance Period DWM .................................................................... Division of Waste Management EDB .................................................................................... East Detention Basin EEC ................................................................. Energy and Environment Cabinet FCP ..................................................................................... Final Closure Period HASP ................................................................................. Health and Safety Plan ICP ........................................................................... Institutional Control Period ICWP ..................................................................... Institutional Control Work Plan IMP .......................................................................... Interim Maintenance Period IRP .................................................................................. Initial Remedial Phase lbs. .......................................................................................................... pounds LLRW ...................................................................... Low-Level Radioactive Waste mL ..........................................................................................................milliliter MFDS ............................................................................ Maxey Flats Disposal Site NECO ..................................................................... Nuclear Engineering Company NPL ................................................................................... National Priorities List O&M ....................................................................... Operations and Maintenance PSVP .....................................................Performance Standards Verification Plan pCi ...................................................................................................Picocurie(s) QAPP .................................................................... Quality Assurance Project Plan RA ........................................................................................... Remedial Action ROD ....................................................................................... Record of Decision SOW ........................................................................................ Statement of Work SWMF ................................................................ Stormwater Management Feature US EPA ........................................ United States Environmental Protection Agency



1.0 PROJECT MANAGEMENT

1.1 Distribution List The distribution list (Table 1-1) for this document includes all staff below:

Table 1-1: Distribution List

Pam Scully, Project Manager US EPA Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-3104 (404) 562-8935

John Maybriar, Director KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd. 2nd Floor Frankfort KY, 40621 (502) 564-6716

Larry Hughes, Branch Manger KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd. 2nd Floor Frankfort KY, 40621 (502) 564-6716

Josh Turner, Supervisor KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd. 2nd Floor Frankfort KY, 40621 (502) 564-6716

Matt McKinley, Branch Manger KY Department for Public Health Radiation Health Control Branch 275 E Main St. HSICA Frankfort KY, 40621 (502) 782-5687

Jeff Webb, Environmental Control Supervisor Maxey Flats Section 2597 Maxey Flats Road Hillsboro KY, 41049 (606) 783-8680

1.2 Project Organization The Commonwealth of Kentucky is required to carry out monitoring and maintenance activities at the Maxey Flats Disposal Site (MFDS) during the Institutional Control Period (ICP) as defined in the Consent Decree Statement of Work (SOW). ICP maintenance activities are specified in the ICP Operation and Maintenance Manual (OMM). ICP monitoring tasks are specified in the ICP Performance Standards Verification Plan (PSVP). The PSVP identifies the tasks and procedures for assessing the performance of the Initial Remedial Phase (IRP) Remedial Action (RA), Final Closure Period (FCP), and the monitoring that will be conducted during the ICP to ensure the remedy is protective of the environment. The PSVP addresses both monitoring of physical conditions and contamination. Physical monitoring includes Erosion, Cap Subsidence, and Climatological. Contamination monitoring includes the collection and analysis of tritium samples in both surface and groundwater. Together both physical and contamination monitoring provide the information and data necessary to accurately evaluate the final cap performance and the impact on the environment. This specific Quality Assurance Project Plan (QAPP) provides the quality assurance measures and operating procedures that will be implemented in order to ensure precision and accuracy of contamination monitoring data that will be routinely assessed and reported to US EPA. The QAPP Organizational Chart (Figure 1-1) identifies those responsible for carrying out the ICP Work Plan and shows the reporting relationships between all organizations involved in the project.



QAPP Organizational Chart

LEGEND

Audit/Review Responsibility

Line Management

Figure 1-1: QAPP Organizational Chart

JOHN MAYBRIAR, PROGRAM MANAGER KY Department for Environmental Protection

MATT MCKINELYMCKINLEY, QUALITY ASSURANCE MANAGER

CHS

LARRY HUGHES, PROJECT MANAGER

JOSH TURNER, QUALITY ASSURANCE MANAGER

EEC

JEFF WEBB, FIELD OPERATIONS LEADER

FIELD PERSONNEL, ENVIRONMENTAL SCIENTISTS

REMEDIAL PROJECT MANAGER US EPA Region 4



1.2.1 US EPA Remedial Project Manager

The Remedial Project Manager (RPM) is the direct line of communication between the Commonwealth and the US EPA. The RPM is responsible for operation document approval, conducting five-year reviews and communicating status of the MFDS to the US EPA management.

1.2.2 Program Manager

The Program Manager for the Commonwealth of Kentucky will be responsible for the implementation of the activities of the ICP and ensuring that the obligations required by the Consent Decree are carried out by the Commonwealth to the expectations of the US EPA. The Program Manager will work closely with the Project Manager and the Quality Assurance Manager to assure that accurate monitoring data is collected and reported during the ICP.

1.2.3 Project Manager

The Project Manager for the Commonwealth of Kentucky is the overall manager of technical and administrative activities. The Project Manager provides environmental review and support for the Program Manager and Field Operations Leader and assists the Field Operations Leader in coordinating and scheduling of site work assignment activities that are performed by the Commonwealth of Kentucky employees and subcontractors.

1.2.4 Quality Assurance Managers

The Quality Assurance Managers are responsible for assessing the implementation of the Quality Assurance Project Plan (QAPP). The Quality Assurance Managers will periodically audit quality assurance procedures and conduct final validation of laboratory reports.

1.2.5 Field Operations Leader

The Field Operations Leader is responsible for planning, coordinating, directing, and managing the daily activities of field personnel to ensure all tasks are carried out in conformance with the responsibilities delineated in the PSVP and this document. They will also ensure the soundness of the technical approach used by field personnel for collection of samples and for reviewing the results of field activities to evaluate the integrity of the samples collected. They will manage the analytical data produced in the MFDS Laboratory in hard copy and electronic format and have the data organized and approved for validation. The Field Operations Leader is responsible for managing site maintenance and the integrity of the final cap, perimeter drainage system, fencing, grounds, and monitoring stations.

1.2.6 Field Personnel

The field personnel will ensure all samples are collected, labeled and analyzed in accordance with this document and the PSVP. The field personnel are also responsible for the care of the samples and the chain of custody of the samples until properly transferred or dispatched. They will also provide the labor for inspections and site maintenance as defined in the O&M Plan.

1.2.7 Project Personnel Sign-Off

All key personnel performing tasks as prescribed in this document are required to sign off that they have read the applicable sections of the QAPP and will perform the tasks as described. Figure 1-2 identifies personnel performing work under this document in addition to those associated with document approval. This list will be signed and updated on a separate sheet; it is maintained with this document for review.



Project Personnel Title, by QAPP

Task(s)

Telephone # Signature Date QAPP

Read

Thomas Stewart Radiation Safety Officer

606/783-8680

Jeff Stamper Sample Collector 606/783-8680

ATL Representative

Data Validator 865.291.8930

Scott Wilburn Sample Collector 606/783-8680

Josh Turner QA 502/564-6716

Matt McKinley QA 502/564-3700

Stephanie Brock CHFS RHB Lab Manager

502/564-8390

Larry Hughes Project Manager 502/564-6716

Jon Maybriar Program Manager 502/564-6716

Jeff Webb Field Operations Leader

606/783-8680

Figure 1-2: Personnel Sign Off Sheet [example]

1.2.8 Communication Pathways

The MFDS has a dedicated staff (historically five or less) all of which are involved with sampling, sample preparation, data reduction, and reporting. This provides for daily interaction on all matters related to monitoring and compliance of the MFDS. Although they are in different offices, the MFDS staff are part of the same governmental division as the Program Manager and Project Manager. This provides an open line of communication through various media. The Program Manager, Project Manager, and the MFDS Staff all have established means to communicate with the US EPA. When reporting to the US EPA, it is recommended to do so by email to ensure documentation is provided for the record. It is also recommended that if verbal conversations occur that provide facility guidance, notification, or approval they are followed up with an email summarizing the conversation. The ICP Work Plan elaborates on when and how to communicate with the US EPA through monthly, annual, and five-year review reporting, including change requests, environmental data report, dose evaluations, assessment of site conditions, maintenance reports, equipment maintenance log and ICWP revisions/changes. The Organizational Contacts Table (Table 1-2) provides the name, title, position and contact info for the primary individuals that will be communicate information on approval, compliance, quality control, assessment, performance, and the day to day operations associated with the MFDS.



Table 1-2: Organizational Contacts US EPA REMEDIAL PROJECT MANGER Pam J. Langston Scully, P.E. Remedial Project Manager US EPA Region 4 61 Forsyth Street SW Atlanta, GA 30303 Phone: (404) 562-8935 Email: [email protected]

PROGRAM MANGER John Maybriar, Director KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd 2nd Floor Frankfort, KY 40601 Phone: (502) 564-6716 Email: [email protected]

PROJECT MANAGER Larry Hughes, Branch Manger KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd 2nd Floor Frankfort, KY 40601 Phone: (502) 564-6716 Email: [email protected]

QUALITY ASSURANCE MANGER Josh Turner, Environmental Control Supervisor KY Department for Environmental Protection Division of Waste Management 300 Sower Blvd 2nd Floor Frankfort, KY 40601 Phone: (502) 564-6716 Email: [email protected]

QUALITY ASSURANCE MANGER Matt McKinley, Branch Manger KY Department for Public Health Radiation Health Control Branch 275 E Main St HS1CA Frankfort, KY 40601 Phone: (502) 564-3700 Email: [email protected]

FIELD OPERATAIONS LEADER Jeff Webb, Environmental Control Supervisor KY Department for Environmental Protection Division of Waste Management Maxey Flats Road Hillsboro, KY 41049 Phone: (606) 783-8680 Email: [email protected]

FIELD PERSONNEL Tom Stewart, Environmental Scientist KY Department for Environmental Protection Division of Waste Management Maxey Flats Road Hillsboro, KY 41049 Phone: (606) 783-8680 Email: [email protected]

FIELD PERSONNEL Jeff Stamper, Environmental Scientist KY Department for Environmental Protection Division of Waste Management Maxey Flats Road Hillsboro, KY 41049 Phone: (606) 783-8680 Email: [email protected]

mailto:[email protected]










1.3 Problem Definition and Background The MFDS (Site) is a former commercial low-level radioactive waste (LLRW) disposal facility owned by the Commonwealth of Kentucky. The 941.3-acre facility is located in Hillsboro, KY – approximately 60 miles east of Lexington, Kentucky in the Appalachian plateau of the Knobs physiographic region (Figure 1-3: Location Map). This area is characterized by hills and relatively flat-topped ridges. The 55-acre fenced disposal area lies on a ridge bounded by steep slopes on the west, east, and south, and is approximately 350 feet above the adjacent valleys.

In 1962, the Commonwealth became the first Agreement State, a status granted by the U.S. Atomic Energy Commission, which allowed self-regulation of managing low-level radioactive materials. In that same year, the Commonwealth issued a license to Nuclear Engineering Company (NECO) for LLRW disposal. The license was contingent on the eventual title transfer of NECO’s property and facilities in Fleming County to the Commonwealth to ensure long-term site stewardship. The Commonwealth then leased the operations of the facility back to NECO, creating the nation’s first commercial LLRW disposal facility.

The MFDS operated commercially from 1963 to 1977, disposing of approximately 4.8 million cubic feet of solid LLRW from hundreds of public, private, and government facilities. The waste includes approximately 2.4 million curies of byproduct material, 533,000 pounds of source material, and 950 pounds of special nuclear material. Solid waste forms included clothing, paper, glassware, used equipment, shielding materials, and animal carcasses, all in containers constructed of various materials including cardboard boxes, wooden boxes, and steel drums. Liquid waste was accepted from 1963 to1972 under a license amendment requiring solidification and placement in special trenches designated for liquids.

In 1977, it was determined that trench leachate was migrating off site through subsurface geology. NECO was ordered by the Commonwealth to cease the receipt and burial of radioactive waste. NECO’s license and financial liability were transferred back to the Commonwealth, as required in the Commonwealth’s administrative regulations for proper closure and control of the site.

During commercial operations, waste was disposed of in 46 unlined trenches, except for waste designated as “high specific activity,” which was placed in “hot wells.” A typical disposal trench was 30 feet deep, with accumulated waste covered by 3 to 10 feet of soil. This method of waste placement created an unstable waste matrix in the trenches that left the landfill susceptible to recurrent subsidence events and stormwater infiltration. Beginning in 1972, leachate was pumped from the trenches to prevent overflow from the sumps (10”-36” slotted pipe) that were installed to monitor water levels within the trenches. From 1973 to 1986, an evaporator facility operated on site to reduce the volume of accumulated leachate. The facility processed over 6,000,000 gallons of leachate, resulting in over 100,000 gallons of concentrate that was solidified and disposed of in six additional noncommercial trenches from 1979 to1990. Other site-generated waste was also disposed of in those trenches during that time.



Figure 1-3: MFDS Location



In 1983, the Commonwealth initiated the process to place the MFDS on the National Priorities List (NPL) to ensure proper closure and remediation. In 1986, after comprehensive investigation, the US EPA listed the Site on the NPL under the Superfund Program. The US EPA issued a Record of Decision (ROD) in 1991, detailing RAs and prescribing the three components of the remedy: the Initial Remedial Phase (IRP), the Interim Maintenance Period (IMP), and the Final Closure Period (FCP). The remedy selected by the US EPA was natural stabilization to allow waste in the trenches to subside naturally to a stable condition prior to installation of a final engineered cap. Natural stabilization was anticipated to occur over a period of 30 to 100 years. The final Consent Decree became effective in 1996. The objectives of the IRP, which began in 1998, were met through two activities: 1) landfill dewatering, solidification, and on-site disposal of over 900,000 gallons of leachate, and 2) construction of an exposed geomembrane interim cap, to reduce water infiltration and provide continuous trench stabilization monitoring. During the IRP, the Commonwealth also acquired additional buffer zone properties (Figure 1-4) and filed deed restrictions on those properties, and permanently closed 185 trench sumps within the restricted area. This concluded the IRP and moved the MFDS into the IMP, a period of monitoring and maintenance.

Figure 1-4: MFDS Property Boundaries



During the IMP, which began in 2003, the Commonwealth continued environmental monitoring, cap maintenance, and trench stabilization evaluation. Primary emphases of the IMP were monitoring and evaluation of 83 trench sump leachate levels and cap subsidence monitoring, both of which were key factors in evaluating trench stabilization. The Consent Decree defined the criteria for trench stabilization to be achieved prior to entering the FCP and construction of a final cap.

On November 16, 2012, the US EPA approved the MFDS Trench Stabilization Criteria Evaluation submitted by the Commonwealth, which indicated that natural stabilization was substantially complete. This approval initiated the MFDS’s entry into the FCP. In accordance with the Consent Decree, the Commonwealth selected a supervising contractor to complete the design and implementation of the FCP RA. The Remedial Design (RD) was developed to be completed in two phases. Phase 1 included abandonment of the remaining sumps within the restricted area and disposal of all remaining on-site waste. Phase 2 included final cap and stormwater control construction. Highlights of FCP construction activities are described below.

Sump Abandonment: The Sump Abandonment RA began in February 2014 and was completed in November 2014. The scope of the Sump Abandonment RA included the abandonment of 89 sumps and placing temporary protective covers over all 274 abandoned sumps on the IRP cap. The scope also included the on-site disposal of all wastes generated from IMP and FCP operations. The wastes were disposed of in either large sumps or in the underground stainless-steel storage tank, which was left empty following the IRP for future disposal purposes. This tank was filled with grout in conjunction with sump abandonment.

Final Cap Construction: A reinforced, composite, geosynthetic, and vegetative soil cap was constructed to: mediate subsidence, eliminate water infiltration into the trenches, and allow for drainage. This was accomplished by: 1) Placing 444,000 yd3 of leveling fill to achieve design grade. 2) The installation of geosynthetics: 1,375,000 ft2 of primary geogrid, 1,069,000 ft2 of secondary geogrid, 2,176,000 ft2 of geosynthetic clay liner, 2,251,000 ft2 of 60-mil HDPE liner, and 1,977,000 ft2 of geocomposite drain. 3) Approximately 116,000 yd3 of compacted protective cover fill was placed at a thickness of approximately 1.3 feet over the geosynthetic system. 4) Topsoil was placed and seeded over the protective cover at a thickness of 0.7 feet. Approximately 69,000 yd3 of topsoil was used completing cap construction. The earthen leveling fill and cover material were obtained from onsite borrow sources.

Surface Water and Erosion Control: In addition to maintaining the IMP East Detention basin, the construction of two new detention basins at the base of the south and west drains was completed. Construction of a perimeter stormwater collection system around the final cap was also completed. The stormwater collection system is made of concrete and earthen material that utilizes both surface and conduit flow to divert surface water and waters released from the cap drainage system to the three detention basins.

Remedial construction was accomplished according to the plans and specifications in the approved RD from 2014 through 2017. The FCP will conclude with the issuance of the BoRP Certification of Completion by the US EPA. The MFDS will then enter the ICP where the Commonwealth is responsible for performance monitoring and maintenance for the next 100 years.

Radionuclides are present in groundwater around the disposal trenches and discharge to surface water through seeps. Both surface water and groundwater require monitoring to ensure that ARARs are met at compliance points and at additional locations that provide information about where radiation is originating. Historical sampling prior to placement of the final cap is available and will be used to help analyze the data. The same office/staff that monitored groundwater and surface water during the IRP will conduct the work. Costs are well known and included in budget projects for the Commonwealth.



1.4 Project and Task Description and Schedule

1.4.1 Project Description

Pursuant to the Consent Decree for the MFDS, The Commonwealth is responsible for performing contaminant monitoring associated with the ICP. The objective of this document is to identify the procedures that will be implemented during the ICP to ensure the precision and accuracy of contaminant monitoring activities specified in the ICP PSVP. The ICP PSVP and the Contamination Monitoring program within this document specify:

monitoring locations

types of measurements and samples

verification, validation, and assessment of data

action levels and limits

1.4.2 Task Description

As defined in the PSVP surface water samples for tritium analysis will be obtained routinely from nine (9) locations (Figure 1-5) in drainage channels and streams inside and outside the Site boundary and buffer zone. As defined in the PSVP groundwater in the alluvium will be analyzed for tritium using the Eleven (11) alluvial wells (Figure 1-6) within the Site boundary and buffer zone. Sampling frequency for these locations are presented in Table 1-3. Access to streams and wells within the buffer zone will be limited in perpetuity by deed restrictions and security controls. This action precludes members of the public from being continuously exposed to radionuclides and other contaminants within the buffer zone. Additional details for Sampling Locations, frequency, dose limits and action limits can be found in the ICWP Appendix D - PSVP and in the Sampling Analysis Plan (SAP) (Appendix D1A of this document). Routine tritium samples will be analyzed at the Maxey Flats Disposal Site Lab. If radionuclide analysis for any isotope other than tritium is required, it will be performed at the Cabinet for Health and Family Services (CHFS) Radiation Health Branch (RHB) lab, or a third party contracted lab. The State of Kentucky maintains a contract for third party radionuclide and hazardous material/chemical analysis. The contract is renewed annually, so specific information on the lab is impractical to present in this QAPP. In order for a lab to bid on this contract, they must be accredited and meet all US EPA requirements for sample analysis.

1.4.2.1 Surface Water

(a) 102D

Reasonably Exposed Individual (REI) monitoring: This sampling location is where a member of the public has the potential to be present for an extended period of time. Sampling location 102D is the compliance point due to the confluence of the three creeks, and because the location is outside the buffer zone where exposures could reasonably occur. Sampling data from this location will be used to estimate radiological doses to a REI outside the Buffer Zone. Data from this location will be compared to the 4 mrem/yr US EPA Drinking Water Standard and its derived tritium concentration of 20 pCi/mL on an annual average basis. The standards and frequency are discussed further in Section 1.5.

(b) Perennial streams

Perennial streams within the buffer zone will be monitored for comparison to the 4 mrem/yr US EPA Drinking Water Standard and its derived tritium concentration of 20 pCi/mL on an annual average basis to help determine the origin/reason for changes in concentrations at the REI, if needed. Access to streams within the buffer zone will be limited in perpetuity by deed restrictions and security controls. This action precludes members of the public from being continuously exposed to radionuclides and other contaminants within the buffer zone:

103E: Drip Springs Creek

106: No Name Creek



122C: Rock Lick Creek

(c) East Drain

The East Drain is an intermittent stream that flows from SWMF-1 into No Name Branch. The sampling point within the drain is identified as 144. It is located at the original license property boundary(1). Because of this, it will be monitored for comparison to a 25mrem/yr Total Effective Dose Equivalent (TEDE) and the derived equivalent tritium concentration of 125 pCi/mL on an annual average basis.

(d) Stormwater Management Features

Stormwater flow from the cap is controlled and measured at three locations: the east detention basin [Stormwater Management Feature (SWMF)-1], the south drain retention basin [SWMF-2], and the west drain retention basin [SWMF-3]. The SWMF locations will be monitored for comparison to the 4 mrem/yr US EPA Drinking Water Standard and its derived tritium concentration of 20 pCi/mL on an annual average basis. During the IMP, SWMF-1 was identified as the East Drainage Basin (EDB). SWMF-1 sampling location is the same location. IMP sampling locations 143 and 107C will no longer be collected because their influence is encompassed within SWMF-2 and SWMF-3 respectively.

SWMF-1: Receives runoff from the cap and releases into the East Drain

SWMF-2: Receives Runoff from the South Drain

SWMF-3: Receives Runoff from the West Drain

(e) Background

A weekly background sample will be collected by grab methodology at location 122A, located upstream from surface water influence from the MFDS.

1.4.2.2 Groundwater

Alluvial Monitoring Wells: Located in the Buffer Zone, AW-3, AW-4, AW-6, AW 7, AW-8, AW-9, AW-12, AW-14, AW-15, AW-16, and AW-17 are installed in the alluvium rock layer at the base of the hillslopes surrounding the site. Based on Performance Monitoring Time Lines and decision tress from the IMP Work Plan and conclusions from the US EPA Five Year Reviews two of these wells will be monitored quarterly and three annually for comparison to the 4 mrem/yr US EPA Drinking Water Standard and its derived tritium concentration of 20 pCi/mL on an annual average basis. The additional alluvial monitoring wells will be monitored based on triggers defined in the PSVP. The alluvial wells provide data for assessing the impact on groundwater that has the potential to be a CERCLA drinking water source.



Figure 1-5: Surface Water Sampling Locations



Figure 1-6: Groundwater Sampling Locations



1.4.3 Schedule

Table 1-3: Sampling Schedule

Sample Location(s) Type of Sampling Frequency Analysis/Annual Avg.

Limits

102D, Compliance Point

Time Actuated Automated Composite

Weekly 3H / 20 pCi/mL

SWMF-1, SWMF-2, and SWMF-3

Flow Actuated Automated Composite


144 Time Actuated

Automated Composite

Daily 3H / 125 pCi/mL

103E, 106 and 122C Time Actuated

Automated Composite


AW-7 and AW-16 Manual Grab Quarterly 3H / 20 pCi/mL

AW-6, AW-12, and AW-17

Manual Grab Annually 3H / 20 pCi/mL

122A (Background) Manual Grab Weekly Background

1.5 Quality Objectives and Criteria for Measurement Data

The objectives for the remediation of the MFDS were defined in the ROD and expanded in the SOW to the

Consent Decree. The primary objectives were site stabilization, surface water infiltration control, site

integrity protection, unrestricted use prevention, environmental monitoring plan development and

implementation, and preventing, to the extent possible, the release of contaminants into the environment.

FCP cap construction addressed all the objectives except the environmental monitoring plan, which the

Commonwealth developed by amending and expanding the IMP PSVP.

This QAPP provides the quality assurance measures that will be implemented to ensure the precision and

accuracy of data specified in the PSVP and SAP (Appendix A). The Commonwealth will use this data to

evaluate the remedy and the impact of the Site on the surrounding environment.

1.5.1 Project Objective

The objective of this document is to identify the procedures that will be implemented to ensure the precision and accuracy of data collection activities specified in the ICP PSVP for this project. The requirements of the PSVP are set forth in Task V of the SOW of the Maxey Flats Disposal Site Consent Decree. The PSVP and this document together dictate the frequency, sampling locations, sample collection procedures, analytical procedures, and reporting requirements of specified tasks performed during ICP.

The FCP construction modified the MFDS to be in compliance with both short and long-term remedial action objectives (RAOs) established in the Consent Decree, and in accordance with the ROD. Perpetual maintenance will be necessary to ensure the long-term effectiveness of the remedy and the RAOs. The Commonwealth will evaluate and preserve the performance of the FCP cap via the remedial measures defined in the SOW affiliated with the Consent Decree for the MFDS. These measures include continued contamination monitoring of the surface and ground waters within and outside the licensed boundary, monitoring physical conditions, and continued access control to the disposal area, licensed boundary, and buffer zone.



Based on the Commonwealth’s evaluation of historical environmental monitoring data, the configuration of the site, the mobility of tritium, and the use of realistic exposure pathways, compliance testing and monitoring will be required at the MFDS during the ICP. Sampling will focus on waterborne pathways for radiological activity. Tritium is the most mobile and easily detectable contaminant at the site, therefore the Commonwealth will sample the ephemeral drainage channels, detention basins (SWMFs), streams downstream of the drainage channels, and groundwater within the Site boundary for tritium analysis. Other Radiological and chemical contaminants have not been historically detected in soils, groundwater, or surface water unless tritium activities approach tens of thousands of pCi/mL for liquids and picocuries per gram (pCi/g) for solids. Although Volatile Organic Compounds (VOCs) were buried at the site, these contaminants have not been identified in significant concentrations in surface water samples, and their transport in water is not expected to exceed that of tritium. This evidence justifies monitoring for tritium in water media as a reliable indicator of the movement and potential release of other contaminants until it is determined that other radioisotope indicators are required for adequate Site monitoring. Data obtained from this sampling will be used to evaluate compliance with Remedial Action Objectives and tritium surface water and groundwater Applicable or Relevant and Appropriate Requirements (ARARs). 1.5.2 Summary of ROD identified RAO and ARAR Contaminants

Overall goals to guide the selection and implementation of remedial approaches were defined by RAOs in the ROD. The selected and implemented remedy chosen for the MFDS was natural stabilization and cap construction. The RAOs will be used to evaluate the performance of the implemented remedy throughout the ICP. The RAOs presented in the ROD are to:

Minimize the infiltration of rainwater and groundwater into the trench areas and migration from the trenches

Stabilize the Site such that an engineered cap that will require minimal care and maintenance can be placed over the trench disposal area

Minimize the mobility of trench contaminants by extracting trench leachate, to the extent practicable

Promote Site drainage and minimize potential for erosion to protect against natural degradation

Implement institutional controls to permanently prevent unrestricted use of the Site

Implement a Site performance and environmental monitoring program.

The first and second RAOs were subsequently expanded in the Administrative Order by the SOW to include the following components:

Prevent or mitigate the continued release of hazardous substances, pollutants and contaminants from the Site to underlying bedrock formations and groundwater aquifers

Prevent or mitigate the continued release of hazardous substances, pollutants and contaminants from the Site to surface water bodies and sediments

Reduce the risks to human health associated with direct contact with hazardous substances, pollutants or contaminants within the Site

Eliminate or reduce the risks to human health from inhalation of hazardous substances, pollutants or contaminants from the Site

Eliminate or minimize the threat posed to human health and the environment from current and potential migration of hazardous substances from the Site in the surface water, groundwater, and subsurface and surface soil and rock

Minimize the infiltration of rainwater and groundwater into the trench areas and migration from the trenches

Allow natural stabilization of the Site to provide a foundation for a final cap over the trench disposal area that will require minimal care and maintenance over the long term

Prevent ingestion of and dermal contact with contaminated soil and sediment

Prevent further migration of contaminants into the groundwater



ROD established ARARs for groundwater and surface water Contaminants of Concern (COC) for both chemical and radiological contaminants are presented in Tables 1.4-1.6. Of the ROD identified contaminants, tritium is the most mobile and easily detectable contaminant at the Site. Other ROD identified radiological contaminants have not been historically detected in soil, groundwater, or surface water unless tritium activities exceeds action levels. Therefore, after the IRP, all radiological environmental monitoring at the MFDS has been based on tritium sampling from water borne pathways. In addition, Tritium has been identified by the US EPA as the primary contaminant of concern.



Table 1-4: Groundwater COC ARARs

COC 1991 ROD ARAR (in µg/L unless

noted)

New or Modified Requirement (ug/L)

Arsenic 50 10

Benzene 5 5

Bis(2-ethylhexyl)phthalate 4 6

Chlorobenzene 100 100

Chloroform (trihalomethanes) 100 80

1,2-Dichloroethane 5 5

Lead 50 15

Nickel 100 Rescinded

Toluene 1000 1000

Trichloroethene 5 5

Vinyl Chloride 2 2

Radionuclides

Beta particle and photon radioactivity 4 mrem/yr 4 mrem/yr

Gross alpha particles 15 pCi/L 15 pCi/L

Radium-226 and Radium-228 (total) 5 pCi/L 5 pCi/L

µg/L = micrograms per Liter mrem/yr = millirems per year pCi/L = picoCuries per Liter N/A = Not available * Note: Current KY Groundwater Environmental Performance Standards can be found in 401 KAR 47:030

Table 1-5: Surface Water COC ARARs (Chemical Contaminants)

COC 1991 ROD ARAR

(Human Health – Fish

Consumption)

(µg/L)

1991 ROD ARAR

(Aquatic Life –

Chronic)

(µg/L)

1991 ROD ARAR

(Aquatic Life – Acute)

(µg/L)

Arsenic 0.175 N/A N/A

Benzene 400 N/A 5,300

Bis(2-ethylhexyl)phthalate N/A 3 940

Chlorobenzene 488 50 250

Chloroform (trihalomethanes)

157 1,240 28,900

1,2-Dichloroethane 2,430 20,000 118,000

Lead N/A 3.2 82

Nickel 100 160 1400

Toluene 424,000 160 17,500

Trichloroethene 807 21,900 45,000

Vinyl Chloride 5,246 N/A N/A



Table 1-6: Surface Water COC ARARs (Radiological Contaminants)

COC 1991 ROD ARAR (in pCi/mL unless noted)*

Total whole body exposure (all media) 25 mrem/yr

Americium-241 0.02

Carbon-14 30

Cesium-137 1

Cobalt-60 3

Hydrogen-3 (Tritium) 1,000

Iodine-129 0.2

Plutonium-238 0.02

Plutonium-239 0.02

Radium-226 0.06

Strontium-90 0.5

Technetium-99 60

* It is noted that these values are inconsistent with those listed in Table A-1, Applicable Action-Specific and Contaminant-Specific Requirements for Remedial Alternatives at Maxey Flats. However, according to Section 8.2 of the ROD, Contaminant-Specific ARARs, “The federal standards were lowered in May 1991 so as to limit the allowable dose in unrestricted areas to 100 mrem/yr and to provide specific radionuclide concentrations in Appendix B, Table II. In that these new federal standards are more stringent than the Kentucky regulations, the federal standards shall be the governing ARARs for allowable doses in unrestricted areas.” Therefore, the values listed above are based on the federal standards (i.e., 10 CFR Part 20, Subpart O, Appendix B: Table 2, Column 2, "Water"; https://www.ecfr.gov/cgi-bin/text-idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node= ap10.1.20_12402.b&rgn=div9 and 10 CFR Part 61.41; https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-0041.html).

1.5.3 Objectives and Project Decisions

The ICP, scheduled to last 100 years, follows placement of the final cap and certification of completion of the BoRP by the US EPA. During the ICP, remedy effectiveness, maintenance, and protectiveness will be evaluated at 5-year intervals. As indicated in Section 4.0 of this document, the Commonwealth will provide annual reports to the US EPA regarding data collection, verification, validation, and assessment. The reports will compare data to action and screening levels to evaluate long and short-term potential impacts to the environment. Data acquisition will be assessed in the annual reports to evaluate whether the remedial action objectives continue to be maintained as required by the record of decision.

Performance will be evaluated by comparing surface and groundwater tritium concentrations to screening and action levels. Exceedance of screening levels may result in increasing sample interval and sampling for other parameters. Exceedance of action levels will trigger a series of more detailed evaluations that include sampling for other parameters and additional investigative samples for the purpose of identifying the source of increased contamination. Exceedance of either level will require notification to the US EPA. Exceedance of an action level will require submission of an investigative plan to the US EPA for approval.

If data begins to trend positively, an engineering investigation into the possible causes of the increase and actions necessary to prevent exposure should be conducted. Statistically valid trends must be evaluated to assess if corrective actions are necessary. This evaluation will be based on long-term statistical trends (e.g., annual dose evaluations) rather than single measurements.

Surface water samples will be collected by either automated composite samplers, automated sequential samplers, or by grab sampling methodologies. Both automated methods provide adequate data for determining annual average concentrations that may be utilized for determining radiation doses. Both automated composite and sequential sampling methodologies ensure sufficient data is available for analysis

https://www.ecfr.gov/cgi-bin/text-idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node=%20ap10.1.20_12402.b&rgn=div9

https://www.ecfr.gov/cgi-bin/text-idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node=%20ap10.1.20_12402.b&rgn=div9

https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-0041.html



of the sites impacts on the environment. Automated Sampling will be conducted at 8 intermittent and perennial stream locations. It was determined prior to IMP implementation that a daily collection of four 250mL aliquots provided a representative sample for evaluating dose on an annual basis. Five surface water locations will continue to be monitored by time-based sampling. The three SWMF locations have flow controls and flow meters that allow them to be sampled based on flow. The flow sampling intervals for the SWMFs are based on calculated flow volumes obtained from the following: FCP Design Basis Document; derived weekly maximum flow that is the equivalent of two 100-year storm events; required volume for analysis; and sampler container volume. Flow based sampling collects a smaller aliquot than the 250mL time-based collection volume but by sampling more frequently and only during rain events it provides an equally representative sample. It is anticipated that filed adjustments will be necessary to maximize performance of the flow sampling. This may be accomplished by adjusting the flow sample interval and sample volume. Any changes to these parameters will be noted in the sampling field log book. If flow-based sampling is determined to be inferior to time-based sampling the PSVP also allows for the switch to time-based sampling at the SWMFs. Grab sampling provides adequate data for evaluating locations against historic trends and as an early warning indicator to possible changes in site conditions. During the ICP, only the established background location and investigative samples will be collected by grab methodology. The alluvial groundwater at the Site and buffer zone is defined in the PSVP as a potential drinking water source. Consequently, this ground water will be monitored and assessed using the 11 alluvial groundwater monitoring wells installed at the MFDS. Quarterly samples will be collected from AW-16 and AW-7, which are directly influenced by site drainage. Three additional wells, AW-6, AW-17, and AW-12 will be sampled annually as representative samples of the buffer zone alluvium. Because the Commonwealth controls access to the site and buffer zone, the alluvium groundwater is not a drinking water source and does not represent a potential radiological dose. To be consistent with the principles of As Low As Reasonably Achievable (ALARA), the alluvial wells will still be compared to the US EPA drinking water standard of 20pCi/mL on an annual average basis. Performance monitoring analysis of tritium in water will be conducted at the MFDS laboratory. The MFDS lab participates in a proficiency testing program for radionuclides in water. The onsite laboratories also have established lab procedures (MFDS Lab Manual Appendix D1B). Because the MFDS laboratory does not participate in a proficiency testing program for air or soil samples, required analysis of this media will be conducted at the RHB laboratory, or a state contracted laboratory. The RHB laboratory may also perform analysis of tritium or other isotopes. The RHB lab participates in proficiency testing programs, quality control programs, and has established procedures (CHFS Lab Procedures Appendix D1C). Gross alpha and beta, along with alpha beta, and gamma spectrometry analysis must be performed at either the RHB laboratory or a state contracted laboratory. Standard methods for state contacted labs will not be presented in this QAPP. The State of Kentucky procures a third-party lab contract annually making it difficult to keep their methods updated in this QAPP. Based on the last 15 years of monitoring, it is not anticipated that third party lab analysis will be necessary. If third party lab services are required, the MFDS will consult with the US EPA to evaluate and approve use of a specific lab. With regards to radiation, any statement the Commonwealth makes on public health will come from the CHFS, not DEP. Additional MFDS radiological data can be found in the CHFS’s annual reports and in the monthly DEP data submittals. Verified and validated sampling analysis data shall be used to document exposure of the REI and to establish compliance with ARARs. Section 2 of this document specifies verification and validation procedures.

1.5.4 Action Levels

The 4-mrem/yr drinking water standard dose limit was developed as the tap standard for public drinking water supplies. The intent of the standard was to address large bodies of water (not small or intermittent streams) and water supplies accessed by multiple users. The standard was developed using International Commission on Radiological Protection (ICRP) two calculation methods developed in 1959. This critical organ dose approach was used to develop the National Interim Primary Drinking Water Regulations,



which became effective on June 1977. The 4-mrem/yr drinking water standard for tritium is equivalent to a continuous human ingestion concentration of 20-pCi/mL tritium over an entire year. Newer dosimetry models (such as ICRP 30, ICRP 60, Federal Guidance 11 and 13) have replaced the ICRP2 method, which current science indicates overestimates dose by a factor of four. During ICP, effluent dose will be monitored at the same levels established during the IMP to ensure continued protection of the public health and environment. Dose limits established as relevant and appropriate requirements in the record of decision for evaluating the effectiveness of the remedy are defined below:

The 4-mrem/yr annual drinking water standards and its derived tritium action level of 20 picocuries per milliliter (pCi/mL) will be used to assess the REI location outside the buffer zone where adequate water is present that could provide a reasonable drinking water source. Based on historic data and to achieve ALARA, a screening level equal to 50% of the action level will be observed at this location.

Perennial streams, groundwater, within the buffer zone will be compared to the 4mrem/yr annual drinking water standard and its derived tritium action level of 20 pCi/mL. These locations, although not currently used as drinking water, will be compared to the Drinking Water Standard. Based on historic data and to achieve ALARA, a screening level equal to 50% of the action level will be observed at these locations.

The 25-mrem/yr TEDE standard and its derived tritium action level of 125 pCi/mL will be used to assess the intermittent stream (Location 144) measured at the original license boundary and Storm Water Management Features (SWMF1-3). Based on historic data and to achieve the ALARA principle, a screening level to 80% of the action level will be observed for sampling location 144. Because limited historical data exists for the SWMFs a screening level of 25% will be observed for these locations.

Action levels for specific locations are presented in Table 1-7.



Table 1-7: Maxey Flats Disposal Site

Contaminant Monitoring Action Level Summary

Location

Intermittent Streams Target Limit Action Levels On Site Actions1 Notification Actions

144 SWMF-1 SWMF-2 SWMF-3

25 mrem/yr total all pathways

125 pCi/mL tritium annual average of available data)2

90pCi/l Gross

Alpha,

50pCi/l Gross

Beta

Evaluate data from automated samplers in perennial streams.

Collect grab and samplescomposite samples within affected drainage area(s) to determine potential source of tritium.

Collect grab sample from theseis locations for: filtered gross alpha and beta analysis, and gamma spec analysis

(1) Notify EPA within 14 days of determination.

Location Perennial Streams Target Limit Action Level On Site Actions1 Notification Actions

REI(102D) 103E 106 122C

4 mrem/yr –20 pCi/mL water only

20 pCi/mL tritium (annual average)2

Evaluate data from automated samplers in perennial streams.

Based on analysis of automated sampler data from intermittent and perennial streams, collect grab samples within affected drainage area(s) to determine potential source of tritium.

(1) Notify EPA within 14 days of determination.

Location

Alluvial Groundwater Target Limit Action Level On Site Actions1 Notification Actions

AW-3 AW-4 AW-6 AW-7 AW-8 AW-9 AW-12 AW-14 AW-15 AW-16 AW-17

4 mrem/yr 20 pCi/mL tritium Perform confirmation sampling of the well

Collect down gradient alluvial well samples and assess tritium in drainage area affected by targeted alluvial well.

Evaluate upstream and downstream perennial stream samples

Notify EPA within 14 days

1 When an action level is triggered, all listed activities must be performed. Sequence is unspecified. 2 Based upon conservative ICRP-2 methodology. Dose calculations are performed on an annual average basis in accordance with

Appendix D.



1.5.5 Measurement Performance and Acceptance Criteria

The MFDS lab must participate in a proficiency test to substantiate the accuracy of tritium analysis results, and also participate in third party data validation. Samples will be analyzed in accordance with accepted methodology and internal laboratory quality assurance (QA). Analyses are designed to provide results within the accuracy of routine laboroatory procedures (Appendix B). This provides confidence in the data, which may be used to make engineering design decisions, expansion of the sampling program in response to exceedance of action limits, and to demonstrate compliance with the PSVP Performance Standards. Reporting of tritium analysis will include QC sample data and the analytical raw data. Off site analyses may be conducted at the RHB labs or a third party accrediated laboratory.

1.5.5.1 QA Objectives for Measurement Data

The QA objective for measurement data is to ensure environmental monitoring data of known and acceptable quality is provided to support decisions during the ICP. Laboratory data will be used to determine migration of contaminants to groundwater and surface water, monitor site conditions, evaluate impacts on public health, and evaluate the effectiveness of the FCP RA. Field and laboratory measurement data will be of sufficient quality for data assessment, fact sheet documents, and Site updates to the community, if necessary.

1.5.5.2 QA Objectives for Field Sample Data

The quality assurance objective is to ensure that the collection and handling methods established in the SAP (Appendix A) are followed during the collection of samples and measurements. Trip and equipment blanks will be employed to ensure the representativeness, completeness, and comparability of data. Field data will be recorded to reflect the quality of sample handling and measurement procedures. Chain of custody documentation will be maintained from field sample collection through final laboratory analyses.

1.5.5.3 Quality Control

The Commonwealth laboratories conducting the radiological analyses have established internal quality control procedures and participate in performance evaluation programs to ensure accuracy and precision of analytical results. The MFDS Laboratory will use sample, measurement, and analytical procedures established in the MFDS Lab Manual (Appendix B). The RHB laboratory will use sample, measurement, and analytical procedures established in the CHFS Lab Manual (Appendix C). Data will be verified and validated before being released to the US EPA. Data will be assessed relative to the requirements of the PSVP and this document.

1.5.5.4 Measurement Quality Objectives

Measurement quality objectives (MQOs) are the acceptance criteria for specific measurements. They ensure that the data used in decision making are of acceptable quality. The parameters for MQOs include the following:



(a) Precision

The laboratory objective for precision is to equal or exceed the precision demonstrated for similar samples, and shall be within the established control limits for the methods. Precision examines the spread of the reported values about their mean. Precision will be measured with laboratory duplicates, using Relative Error Ratio (RER). The acceptance range for RER values is <3.

RER = |C1 -- C2|/(ơ1

2 + σ2

2)0.5

where, C1= Sample 1 concentration

C2= Sample 2 concentration

ơ1= Sample 1 standard deviation

ơ2= Sample 2 standard deviation

Participation in a certified radiological proficiency testing program will be required for evaluation of precision.

(b) Accuracy

The laboratory objective for accuracy is to equal or exceed the accuracy demonstrated for these analytical methods on similar samples or spiked samples, and shall be within the established control limits for the methods as published by the US EPA. Commonly, accuracy is presented as percent bias or percent recovery. Percent bias is a standardized average error; that is, the average error divided by the actual or spiked concentration converted to a percentage. Percent bias is without units, so it allows the accuracy of analytical procedures to be compared easily. Percent recovery provides the same information as percent bias. Since accuracy is often determined from spiked samples, laboratories commonly report accuracy in this form. Percent recovery is defined as:

% Recovery = R 100 S where, S = spiked concentration R = reported concentration

Given this definition it can be shown that

% bias = % recovery - 100

The certified radiological proficiency testing program will also be used for evaluation of accuracy.

For tritium, the minimum detection limit (MDL) will be no more than 10% of the 20 pCi/mL performance standard with an uncertainty of less than 50 percent.



(c) Representativeness

Representativeness is a quality characteristic that is attributable to the type and number of samples to be taken, the medium, and the analysis to be performed on the sample so as to be representative of the medium/environment (e.g., air, water, etc.) at the site of interest. Representativeness of samples will be ensured through procedures specified in the SAP (Appendix A), and the MFDS Lab Manual (Appendix B) and use of duplicate samples.

(d) Comparability

The sampling methods employed in the SAP (Appendix A), and the chain of custody procedures responsible for the transfer of the sampled items to the analytical laboratory shall be performed in a uniform manner determined by this document.

(e) Completeness

The completeness of the data reflects that all the required samples and measurements have been taken and required analysis performed so as to generate quality data.

1.6 Special Training Requirements and Certification On-site Commonwealth personnel performing tasks required by the Consent Decree are required to complete the training and medical surveillence courses outlined in Section 4 of the MFDS ICP HASP. The training includes:

40-Hour Hazardous Waste Operations and Emergency Response (HAZWOPER) Training Course, and 8-Hour Refresher Annually

Basic Radiation Safety Training Course

Site Orientation

ICP Work Plan Training

Monthly Safety Training

Special Operations Training

Briefings

Field Experience

Equipment Training Training may be obtained from outside vendors, the MFDS RSO, or the MFDS Field Operations Leader. It is the responsibility of the Field Operations Leader to setup and document required training. Training shall be documented to ensure compliance with the training requirements for each on-site employee performing Consent Decree activities. Summary reports of training shall be maintained to ensure employees are properly trained.

1.7 Documents and Records The Commonwealth will maintain a computerized database system (Microsoft® Access, TEMPO or equivalent) as an electronic repository for site monitoring data. The data will be validated within 60 days of sample analysis, and entry into the database will be performed within 30 days of validation. The Commonwealth will provide electronic database updates to the US EPA on a monthly basis. Table 1-8 provides a schedule of data submittal and monitoring reports for the ICP.



1.7.1 QA Project Plan Distribution

It is the responsibility of the Fields Operations Leader to maintain updates and conduct annual reviews of this document. It is also the responsibility of the Field Operations Leader to ensure all updated copies are singed by the personnel in Figure 1-2 and that all personnel in Table 1-1 have received an updated copy of the QAPP.

1.7.2 Field Documentation and Records

Each sample will be marked or labeled in a permanent manner suitable for the size of the sample container. Any field parameters collected and recorded will be specified in the Sampling Procedures. All samples collected will be logged in a field book with: location, sampler’s name, quantity of samples, date and time of sample collection. Additional documentation information can be found in Section 2.4 and the SAP (Appendix A)

1.7.3 Laboratory Documentation and Records

Each sample will be logged into the laboratory electronic database and a sample number will be assigned. Each sample will be listed on a completed chain of custody form. Detailed instructions for controlling samples by way of chain of custody documentation are given in Section 2.3 of this document.

1.7.4 Annual Reports

Annually, the Commonwealth will submit a report to the US EPA within 90 days of year-end, providing a summary of calendar year data collected pursuant to the PSVP, annual dose calculations and an assessment of site conditions. The findings and conclusions of the data evaluation, including a comparison of the data to background, baseline values, regulatory requirements, and the action levels will be presented in the report. This report will be provided in a US EPA approved electronic format. If the data evaluations show contaminants have reached, or are approaching the action levels, an interim report of such findings may be submitted. The necessity of this report is dependent on the significance of the findings from the results of sample recounts, additional investigative sampling results, and the nature of any trends in the release or transport of contaminants relative to the action level criteria.



Table 1-8:

Schedule of ICP Data Submittal and Monitoring Reports

REPORTING/NOTIFICATION DELIVERABLE JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Data entry reports and electronic submittal of environmental data

1,2

1,2

1,2

1,2

1,2

1,2

1,2

1,2

1,2

1,2

1,2

1,2

Sampling Events - Perennial streams, SWMF’s and Original License Boundary (Location 144) - TEDE Location 102D (event basis) - Alluvial Wells – two primary drainage representative wells (AW-7 & AW-17) - Alluvial Wells – 5 buffer zone alluvium representative wells (AW-6, AW-7, AW-12, AW-16, & AW-17)

X X

X X

X X X

X X

X X

X X X

X X

X X

X X X

X X

X X

X X X X

Monitoring Reports - Annual Monitoring Dose Evaluation Report

1,2

1. copies to: US EPA, Region IV 2. copies to: KY Superfund Branch



2.0 DATA GENERATION AND ACQUISITION

2.1 Sampling Design Environmental monitoring at the MFDS is intended to:

Demonstrate status compared to the contaminant-specific Performance Standards

Provide an “early-warning” means of detecting the transport of contaminants into the Buffer Zone

Provide an action level management tool to help understand contaminant transport and its mitigation

2.1.1 Site Historical Monitoring Assessment

An abundance of baseline information is available from IMP and FCP sampling and measurement activities performed at the site. This collection of information includes:

The inventory of radioactive and hazardous materials buried at the site that has been seen in contamination monitoring.

Tritium is the sole indicator contaminant because it is easily detected in laboratory analysis, and is the contaminant with the most potential to be transported outside the disposal area, Buffer Zone, or beyond.

The concentrations of contaminants in the groundwater of the alluvial deposits and Crab Orchard Formation within the Buffer Zone.

The concentrations of contaminants in the waters of No Name Creek, Drip Springs Creek, and Rock Lick Creek, and within the three primary drains (East, South and West).

2.1.2 General Criteria for Sampling Locations and Analyte(s)

Decisions regarding what to sample and where to sample were based on the following criteria:

Historical data (surface water samples, groundwater samples, and environmental TLDs, etc.)

Potential exposure pathways

Radionuclides of interest

Applicable dose based standards.

2.1.3 Action Levels

The action level for identified primary drinking water sources, perennial streams and alluvial wells will be the 4 mrem/yr US EPA drinking water standard. The action level for water at the former license boundary, not evaluated as primary drinking water source, will be 25 mrem/yr TEDE, based on the Layer 2 protection for the public (NRC 10 CFR 20.1301(e)).The 25 mrem/yr limit will be used to evaluate the East Drain Intermittent Stream, Location 144, and SWMFs 1-3. The 4 mrem/yr standard is the equivalent exposure from the continuous human ingestion of 20 pCi/mL of tritium, 15 pCi/L gross alpha only, or 8 pCi/L gross beta only for an entire year. The 25mrem/yr TEDE standard is the equivalent exposure from 125 pCi/mL of tritium, 90 pCi/L gross alpha only, or 50 pCi/L gross beta only under the same conditions. Action levels will be specific to sample location and will be some derivate of these standards. Action levels for specific locations are defined in Table 1-7.



2.1.4 Contamination Analysis

Laboratory analysis for tritium in surface and ground water will be conducted at the on-site MFDS laboratory, the RHB laboratory, or a contracted, certified third party laboratory. The MFDS laboratory over the next five years will develop a replacement program for gross alpha and beta analysis to transition to a new primary indicator isotope when it is determined that tritium is no longer effective as an indicator contaminant. Currently gamma spec analysis must be analyzed at the RHB laboratory or a state contracted laboratory. Because the MFDS laboratory does not participate in a proficiency testing program for air or soil samples, if soil and air tritium analysis is determined necessary by the US EPA, analysis will be conducted at the RHB laboratory or a state contracted laboratory.

2.1.5 Identification of Analytes by Media

Tritium is the most abundant and mobile radionuclide of concern at the MFDS. It will continue to be the indicator contaminant in surface water and groundwater samples as described in the ROD. As a consequence of tritium’s relatively short half-life and the passage of forty years since operations were terminated at the MFDS, the Commonwealth will begin developing a replacement gross alpha and gross beta program and establish a baseline at four existing sampling locations. Development of this program will be administered under the MFDS RML and updates reported to US EPA annually. This baseline information can be taken into considerations should conditions at the site change or tritium become an inferior indicator sooner than anticipated. Although VOCs were buried at the site, these contaminants have not been identified in significant concentrations in surface water samples, and their transport in water is not expected to exceed that of tritium. Monitoring for tritium in water will serve as reliable indicator of the movement and potential release of other contaminants. Other radiological and chemical contaminants have not been historically detected in surface waters unless tritium activities exceed 100,000 pCi/ml.

2.1.6 Sampling Locations

2.1.6.1 Surface Water

Sampling for radionuclide analysis will continue to be conducted utilizing a system of automated samplers and grab sampling to monitor No Name Creek, Rock Lick Creek, Drip Springs Creek, the east drainage channel, and Storm Water Management Features 1, 2, and 3 (Figure 1-5). The purpose of automated sampling is to collect a representative series of discrete, defined volume samples at known flow or time intervals and to place these samples into a single daily or weekly composite sample container. A grab sample is a single event, manually collected sample at a specific location in as short a period of time as possible. The sample volume will be dependent upon the intended analysis.

2.1.6.2 Perennial Streams

Access to streams within the buffer zone will be limited in perpetuity by access and deed restrictions. This action precludes members of the public from being continuously exposed to radionuclides and other contaminants within the buffer zone. In following with the concepts of ALARA, Perennial streams radionuclide activity within the buffer zone will be compared to the US EPA National Primary Drinking Water Regulation levels of 4 mrem/yr action level using the annual average derived equivalent activity of 20 pCi/mL for tritium. The screening levels will be 50% of that action level.

(a) REI location 102D

This primary surface water sampling point and compliance point is located downstream of the confluence of No Name Creek, Drip Spring Creek and Rock Lick Creek, outside the Buffer Zone Boundary, near State Route 158 (Figure 1.5). It will be sampled on a six hour interval, producing one weekly composite consisting of twenty-eight 250 mL aliquots. This sample will be collected on a weekly basis for tritium analysis. An automated sampling device will be utilized to perform the sampling. This composite sampling design has been



used at this location since 2002 and produces over 340 annual samples that translates to well over 1,000 aliquots. This provides substantial representation of the annual average tritium contamination present in the stream at this sampling location. The samples collected from this location will be the primary compliance location for the maximally exposed member of the public and is designated as the site of the REI. If the annual average activity exceeds the US EPA National Primary Drinking Water Regulation levels, the results will be input in the pathway to reference man calculations for comparison to the 4 mrem/yr limit for the maximally exposed member of the public.

Exceedance of the activity screening level (50% of 20 pCi/ml for tritium) will trigger a switch from weekly composite sampling to daily composites at this location and upstream locations (106, 103E, and 122C). Exceedance of the activity action level will trigger an evaluation of the sampling results, which may lead to an investigation to determine the contaminants, their source, the potential significance of the findings, and recommendations for further investigation or mitigation.

(b) Locations 106, 103E & 122C

No Name Creek (106), Drip Spring Creek (103E) and Rock Lick Creek (122C) (Figure 1.5) will be sampled by an automated sampling device.. These perennial stream locations will be sampled every six hours, producing one weekly composite consisting of twenty-eight 250 mL aliquots. These samples will be collected on a weekly basis for tritium analysis. Considering sampler error and frozen or dry conditions, it is anticipated that well over 1,000 aliquots will be collected annually to evaluate the annual average of tritium. This provides a substantial representation of contamination present at these sampling locations.

Exceeding the activity screening level will trigger additional grab sampling at historic locations (to be identified and approved by the US EPA) within the East, South and West Drains. Exceeding the activity action level will trigger (50% of 20 pCi/ml for tritium) an evaluation of the sampling results, which may lead to an investigation to determine the contaminants, their source, the potential significance of the findings, and recommendations for further investigation or mitigation.

(c) Location 122A

Sample location 122A is located on Rock Lick Creek, approximately 200 feet upstream from the confluence with No Name Creek, and is isolated from burial area discharge (Figure 1.5). Location 122A serves as the surface water background sampling location and will be sampled by grab methodology on a weekly basis. Based on historical data at this location, a weekly grab sample will provide satisfactory data. Over 30 years of daily data is available from this location. The historical annual average of tritium at this location is 0.05 pCi/mL. If the annual average of weekly grab sampling from this location begins to exhibit an upward trend then it will be revaluated to determine if automated weekly composite sampling is necessary to accurately determine a background level.

2.1.6.3 Intermittent Surface Water

During the IMP, the East, South and West Drains were monitored in comparison to the 25 mrem Action Level at sample locations 144, 143 and 107C, respectively. Location 144 will continue to be monitored during the ICP as described.

(a) Location 144

Sample location 144 is located at the base of the East Drain in an intermittent stream that exhibits influence from the restricted area runoff and seeps along the east hillside (Figure 1.5). Samples will be collected with an automated instrument that will collect four 250 mL aliquots and composite them into a daily sample to be collected weekly for tritium analysis. This composite sampling design has been used at this location since 2002 and produces over 325 annual samples, which translates to over 1,000 aliquots. This provides substantial representation of tritium contamination present within the drain. The action level for tritium concentrations at 144 will be an annual average of 125 pCi/mL, the derived



equivalent of the 25mrem/yr TEDE standard,. Exceedance of the tritium action level will trigger an evaluation of the sampling results, which may lead to an investigation to determine the contaminants, their source, the potential significance of the findings, and recommendations. Based on historical data trends for this location, an annual average screening interval of 80 pCi/mL has been established. Exceedance of the screening interval may increase the downstream sampling interval; trigger additional up-stream grab sampling for tritium, and other parameters as determined by the US EPA.

(b) Stormwater Management Features

Stormwater discharge is controlled and measured at the East Detention Basin, the South Drain Retention Basin, and the West Drain Retention Basin, now known as Stormwater Management Features (SWMF) 1, 2, and 3 respectively (Figure 1.5). All three locations will be equipped with a flow meter, an automated sampler, and a primary flow-measuring device (Parshall Flume). The SWMFs are not a viable drinking water source, but for ALARA purposes they will be evaluated to the 4-mrem/yr drinking water standard. Stormwater discharge at these locations will be monitored for comparison to a 4 mrem/yr Action Level and its derived tritium concentration of 20 pCi/mL on an annual average basis. A conservative annual average screening interval of 10 pCi/mL, which is 50% of the Action Level, has been established for the SWMF locations. Exceeding the screening levels will trigger additional upstream grab sampling at historic locations and an investigation to determine potential downstream impacts. Exceeding the tritium Action Level will trigger an evaluation of the sampling results, which may lead to an investigation into cap performance and contaminant origin determination. Sample volume and collection methods may change based on site conditions. This will allow for the most meaningful results to help guide future monitoring under the ICP. Any changes to sampling frequency and volume will be documented in field log books and submitted to the US EPA as part of the Annual Report. SWMF samples shall be collected based on either flow volume or elapsed time. At a minimum, weekly composite samples shall be collected that consist of daily aliquots. If flow volume sampling is utilized, it will be accomplished by an automated sampler that collects a 10 mL aliquot for every 6,000 liters of recorded flow at SWMF-1 and a 30 mL aliquot for every 3,000 liters of recorded flow at SWMF- 2 & 3. The sample will be composited into a three-gallon container for weekly collection. These sample aliquot volumes are derived from anticipated flow as defined per location in the FCP Design Basis document and their total sample volume capacity is designed to accommodate extreme rainfall events equivalent to two 100-year rain events occurring in the same sample period. If time-based sampling is selected, it will be accomplished by an automated sampler that collects a 250 mL sample every six hours and composited into a three-gallon container for weekly collection. The sample collection rates for flow volume sampling is based on SWMF Flow Data (FCP Design Basis

Document) and sample container capacity (3-gallons). The goal of flow based sampling is to capture a

representative weekly composite sample that includes both the initial flow of a rain event and good

representation of flow throughout each rain event. It is important that initial flow be captured due to the

dilution factor and to capture the impact of large erosional rains that may carry contamination in the

suspended solids. Based on calculations that include FCP Design Basis Document flow data and the

available sample container volume, the stated flow collection rates will produce representative samples.

The sample aliquot volumes were derived to ensure that if two 100-year storm events occurred within the

same sample period that the sample container would not exceed its volume. It takes a minimum sample

size of 20mL to complete tritium analysis. Any sample volume obtained below 20mL for a week will be

documented as a dry sample. Flow based sampling may be changed to time based sampling at the

Commonwealth’s discretion. A Change from flow based to time base sampling will be documented in field

log books and submitted to the US EPA as part of the Annual Report.



Flow data will be collected and maintained electronically to allow for evaluation of discharge based on the predicted flow rate conditions. Following 100-year storm events or greater in a 24 hour period, the Commonwealth is required to collect recordings and document findings. The results will be evaluated by comparing the actual outflow rates and rainfall to the predicted flow rate/rainfall table established in the outfall design from the FCP Design Basis document and summarized in Table 1.8.

Table 2-1

Predetermined Peak Outlet Outflow

Location 100 yr 24 hr Storm

Event (cfs)

SWMF-1 128.6

SWMF-2 293.73

SWMF-3 86.76

Results will be reported to the US EPA in the Annual Report. If the results exceed a tolerance of +/- 20% of the predicted rate, the US EPA will determine if this impacts the effectiveness of remediation. The discharge will continue to be monitored for the duration of the ICP. If necessary, total flow discharge data and analytical results may be used to calculate total tritium release over a specific period of time.

(c) Locations 143 and 107C

IMP Sample Locations 143 and 107C will no longer be collected on a routine basis. Their influence is captured at sampling locations SWMF-2 and SWMF-3 respectively. These locations may be used as investigative sample locations if any surface water sampling locations exceed screening levels. Additional historic sample locations exist within these drains but these two are noted due to their recent history of being routinely sampled during the BoRP. Sample location 143 is an intermittent stream located at the base of the South Drain and upstream from SWMF-2 (Figure 2-1). It receives an estimated 15% of the surface water runoff from the cap and receives surface water from the facility’s southern boundary. Sample location 107C is located near the base of the West Drain in an intermittent stream upstream from SWMF-3 (Figure 2-1). It receives an estimated 25% of the surface water runoff from the cap, surface water from the office complex, and is a steep narrow drain.



Figure 2-1: IMP Monitoring Locations 107C and 143



2.1.6.4 Groundwater

(a) Alluvial Wells

During the IRP, fourteen alluvial wells were installed at the base of the hillslopes in the creek alluvium as required by the SOW. Five of these wells were abandoned during FCP to accommodate remediation or due to poor well integrity. Two new wells, AW-16 and AW-17, were installed during FCP, creating a total of eleven alluvial wells available for sampling during the ICP. Of these 11 wells, (Figure 1-6) two wells will be sample quarterly (AW-7 & 16), and three wells will be samples annually (AW-6, 12, & 17). The remaining wells are available for investigative sampling should screening or action levels be exceeded. These five wells were selected for routine sampling based on their historical monitoring, potential for contaminant recharge, and physical location. These wells provide a continuum of coverage and data for assessment of the Site’s impact on potential drinking water. The analytical results from these five wells will be used for groundwater pathway calculations and to assess their status compared to drinking water dose target limits. It is anticipated that some of the wells will may be dry during some periods and no sample will be available. Under those conditions, the activity for dose calculation will be zero.

Tritium analysis from these wells will be monitored for comparison to a 4 mrem/yr action level using the annual average derived equivalent activity of 20 pCi/mL. The alluvial well screening level will be 50% of the action level. Exceeding the action level will trigger notification to US EPA and, at their discretion, may result in an increase of sampling: frequency, parameters and locations. Exceeding the action level may also result in analysis of sample for non-radionuclides of concerns identified in the Consent Decree. These non-radionuclides will be compared to MCLs established in 401 KAR 6:015. Exceedance of the screening level will require: notification to US EPA, confirmation sampling, and an evaluation of the up-gradient and down-gradient perennial stream samples.

2.1.7 Sample Volume and Measurements

Sample volumes were determined during the Data Quality and Measurement Quality Objective process by the analytical laboratory to ensure sufficient volume of sample is available for analyses. Tritium analysis at the MFDS lab requires a 6mL sample, it is recommended that all sample volumes be at least 20mL to allow for duplicates and to avoid pipette error. Specifics on required sample volume are discussed in Lab Manual Procedure 600 that can be found in Appendix D1B.

2.1.7.1 QC Sampling

A description of sampling and measurement procedures is also provided in the PSVP. Specific Quality Assurance/Quality Control (QA/QC) and documentation procedures applicable to sampling and measurement procedures are discussed in this section and within specific sampling procedures (Appendix D1A) and in the MFDS Lab Manual (Appendix D1B).

(a) Equipment Blanks

Equipment blanks are defined as samples that are obtained by running analyte-free water through/over sample collection equipment (bailer, pump, tubing, auger, etc.) after decontamination, and placing the rinsate in an appropriate container for analysis. The analysis results of equipment blanks will indicate if proper decontamination technique was carried out. All well sampling locations have dedicated tubing. Automated sampler bottles are decontaminated in a dishwasher and allowed to air dry thus removing any possibility for tritium contamination. Decontamination for tritium is very effective due to its inherent properties to dilute in water and become gaseous when exposed to air. Therefore, routine equipment blank sampling is not necessary for tritium monitoring at the MFDS. If sampling for other isotopes or hazardous chemicals is necessary, equipment blanks will be collected as determined necessary by the Field Operations Supervisor and the Lab Manager.



(b) Trip Blanks

Trip blanks must accompany all tritium sampling events. Trip blanks indicate contamination incurred from field handling procedures and during transport to the laboratory. A trip blank is a 30mL sample container filled with analyte-free water. Trip blanks are carried to all sampling events in the same vicinity as collected samples. All trip blanks shall be identified and labeled as TRPBLK with the date, time of preparation, and initials of the preparer. If more than one daily trip blank is used, the trip blank labeling will also identify the set of samples it was contained with.

(c) Calibration Standard Samples

Calibration standard samples are prepared with a tritium source solution of known concentration using NIST traceable sources and scintillation cocktails with the same volumes as the samples.

(d) Duplicates

Every sample collected should provide sufficient volume for duplicate analysis. Duplicate samples will be identified in the same manner as the corresponding sample. For every 10 collected samples, the laboratory will repeat the analysis for each analyte. If less than 10 samples are counted a duplicate will still be required.

(e) Split Samples

Split samples are replicate samples, divided into two portions from the same source, and subjected to the same environmental conditions and steps in the measurement process. They serve as a QC function in assessing precision in the analytical portion of the measurement system. The MFDS routinely splits samples with the CHFS. This allows for a direct comparison of the Commonwealth’s analytical results.

2.1.7.2 Sample Preservation

Tritium samples for analysis at the MFDS do not require a preservative. If sampling is conducted for analysis at the RHB lab or a third party lab, preservatives will be added based on that lab’s protocols.

2.1.7.3 Holding Time

It is standard lab practice at the MFDS to prepare samples for analysis within 7 days of collection. No specific holding times are required for tritium analysis.

2.2 Sampling Methods

The specific methods and techniques to be utilized in performing sampling and measurements are contained in the SAP (Appendix A). The SAP identifies the procedures for acquiring samples that are representative of the environmental impact from the Site. Specifics such as sample container selection, QC sampling, decontamination, holding time, calibration standard samples, etc. are also provided in SAP. The following procedures will be used to obtain samples identified in this document:

Surface water by the grab method for investigating activities only as described in procedure MFDS-

QAPP-101, Surface Water Grab Sampling, Rev. 0, attached.

Surface water by composite sampler as described in procedure MFDS-QAPP-102, Surface Water Composite Sampling, Rev. 0, attached.



Surface water by sequential sampler flow-actuated method as described in procedure MFDS-QAPP-103, Surface Water Flow-Actuated Sampling, Rev. 0, attached.

Alluvial groundwater by pump method as described in procedure MFDS-QAPP-104, Alluvial Groundwater Sampling, Rev. 0, attached.

2.3 Sample Handling and Custody A sample is considered to be physical evidence collected from a facility or the environment. An essential part is the control of that evidence gathered from the facility or environment. To accomplish this, sample identification and chain of custody procedures will be followed. Samples requiring analysis by other laboratories will also be handled in accordance with the guidelines described in this section. The history of each sample and its handling will be documented from its collection through its final disposition. A sample is considered to be in custody if it is in actual physical possession of the sampling staff, is in a vehicle which is in sight of the sampling staff, is locked or otherwise sealed so that tampering will be evident, or it is kept in a secure area, restricted to authorized personnel only.

2.4 Sample and Measurement Identification The method of identification depends on the measurement or analysis. When field measurements are made, the data should be recorded directly in logbooks, with identifying information such as station numbers, station location, date, samplers, field observations, and remarks. Examples of field measurements include flow measurements at the SWMF’s and water quality meter readings from alluvial well sampling. Field measurements are signed-off by field personnel and by the Field Operations Leader. Each sampling container will have a unique identifier. The sampling container will be identified on the chain of custody. All samples including trip blanks and splits will be identified by sample information written in permanent ink directly on the container. Additional sample identification can be found in the SAP Section 2.6 and in the SAP Implementing Procedures (Appendix A). As appropriate, the markings will consist, at a minimum, of the following:

Sample location: sample station number or description

Date and time

Name of sampling technician

Type of preservative used, if any

Media sampled

Sampling method used (grab, composite, etc.)

Requested analysis

Remarks: any pertinent observations A unique laboratory number will be assigned to the sample when the sample is logged into the laboratory, (Appendix B Procedure 100). The chain of custody form (Figure 2-2) will contain spaces for designating the sample as a grab or composite, the sample matrix, the sample location, date, and sample collector. The sample will be maintained under chain of custody procedures as prescribed in this section. If the sample is to be split in the field, the sample is divided into similar containers. Identical information for the split samples will be completed on the sample container and chain of custody form and be marked "Split". In a similar fashion, containers and chain of custody forms will be provided and marked for "Blank” or "Duplicate" samples.



2.5 Chain of Custody Procedures The samples collected as established by the PSVP shall be traceable from the time the samples are collected until data is verified, validated, and assessed for potential use in the reports specified by Table 1-8. No sample disposal will occur until these steps have been completed.

2.5.1 Field Custody Procedures

Samples will be collected as described in the SAP (Appendix A). Details of sampling, location,

time of sampling, and comments will be written in the field sampling logbook and signed by the sampler.

Field personnel will be responsible for the care and custody of the samples collected until they are properly transferred or dispatched. For samples being analyzed by the Commonwealth, a chain of custody is maintained by entry of sample identifier into the laboratory logbook.

When photographs are taken of new sampling locations as part of the documentation procedure, the name of the photographer, date, time, site location and site description will be entered sequentially in the field sample logbook. Photographic prints will be serially numbered corresponding to the field sample logbook descriptions.

The field conditions and remarks will be recorded in the field sample logbook. The Field Operations Leader will sign off on the field sample logbook.

The Field Operations Leader will determine whether proper custody procedures were followed during the field work and if the requirements of the PSVP have been met.

2.5.2 Transfer of Custody and Shipment

Samples will be accompanied by a chain of custody record (Figure 2-2). When transferring sample possession, the individuals relinquishing and receiving will sign, date, and note the time on the chain of custody. Samples being analyzed by Commonwealth laboratories will maintain chain of custody through laboratory logbooks.

Whenever samples are split or additional analyses are necessary, a separate chain of custody form (Figure 2-2) will be prepared for those samples and marked to indicate with whom the samples are being split. The person relinquishing the samples to the laboratory or agency will require the signature of a representative of the appropriate party acknowledging receipt of the samples.

Samples will be accompanied by a chain of custody Record identifying the samples. The original chain of custody will accompany the samples. The Commonwealth laboratories shall retain chain of custody records.

2.5.3 Laboratory Custody Procedures

Laboratory personnel accepting custody of samples will verify that the information matches that on the chain of custody record. A unique laboratory number is assigned to each sample, which will allow tracking of the sample throughout the sample’s analysis and retention. Laboratory personnel are responsible for the care and custody of samples from the time they are received until the sample is disposed of.

Subsequent to data assessment, the sample and the sample container will be disposed of according to Commonwealth requirements in 902 KAR Chapter 100. All identifying tags, data sheets, chain of custody forms and laboratory records will be retained as part of the permanent documentation. Additional information on Waste Management can be found in ICWP Appendix B – HASP, Sub Appendix B1 – Radiation Protection Plan.

Title: IC WP App.E: QAPP Revision Number: 0 Date: March 2018 Page 46 of 31

Figure 2-2: MFDS Chain of Custody Form

CHAIN OF CUSTODY RECORD Page ______ of _______

Sample Data Information Sheet

Maxey Flats Disposal Site

Radiation Health Branch

2597 Maxey Flat Road

100 Sower Blvd., Suite 108

Hillsboro, KY 41049

Frankfort, KY 40601

606-783-8680

502-564-8390

Collection Date Sample Name Matrix of Sample Sample Type of Sample Preservation Analysis Log #

(smear, soil,

water) Amount (Grab, Composite, Split)

Lab Use

Only

Special Instructions:

1. Collected by: Date/Time: 1. Received by:

2. Relinquished by: Date/Time: 2. Received by:

3. Relinquished by: Date/Time: 3. Received by:

Comments:

Second Page Continued:

Prepared by collector

Laboratory Supervisor:

Date:


2.6 Analytical Methods The analytical methods implemented at the Commonwealth of Kentucky laboratories will be reviewed and approved by the QA Managers prior to use in ICP activities. The procedures for both the MFDS Lab and the RHB lab appear in Appendix B and C respectively. The following items will be included in the procedures:

Medium of application (i.e., water, air)

Principle of method

Sample size requirements

Detection limits

Interferences and corrective measures

Apparatus (including instrumental parameters)

Reagents

Calibration procedures

Sample preparation (i.e., extraction, digestion)

Diagrams or tables that describe the method

Step-by-step analytical procedure

Details of calculation(s)

Quality Control requirements (i.e., blanks, spikes, duplicates)

Reporting requirements

References Measurement Quality Objectives (MQOs) have been established to evaluate the limitations and the applicability of the analytical methods. If modifications to measurements or analytical methods are determined to be necessary to meet the MQOs, additional measurements or analyses will be conducted to ensure the quality of the data. The QA Managers will evaluate the significance of the change and approve the modifications. The QA Managers will work to ensure that any modifications to the MFDS Lab Manual (Appendix B) meet the general guidelines of the established protocols and adhere to the spirit of the QA/QC established. The US EPA will be notified of modifications pertaining to Commonwealth Lab Manuals (Appendix B and C) that don’t adhere to the previous statement.

2.6.1 Field Measurements Methods

Field measurement of water quality data is required for ground water sampling to determine when formation water is present for sampling. The instrument used to collect water quality data should be the HORIBA U-50 series multiparameter water quality meter, or equivalent. The HORIBA provides the following parameters: dissolved oxygen, turbidity, conductivity, pH and temperature. A calibration file shall be maintained for the HORIBA that includes:

Name of device

Device Serial and/or identification number

Date of last calibration

Name of party performing the calibration

Calibration standard used.


Field data will be written on water resistant field books. In order to provide complete documentation of the sampling event, detailed records will be maintained by the Field Operations Leader. At a minimum, these records will include the following information:

Sample location

Sample identification

Date and time of sampling

Sampling method

Field observations of sample appearance and sample odor

Weather conditions

Any other relevant information (e.g., moisture content) Additional information for collection of water quality data is included in the SAP, Ground Water Sampling Procedure, MFDS-QAPP-104, Appendix A.

2.6.2 Field Analyses Methods

2.6.2.1 Screening

No field screening data is produced at the MFDS.

2.6.2.2 Definitive

No field definitive data is produced at the MFDS.

2.6.3 Off-Site Laboratory Analyses Methods

The analytical procedures for the RHB laboratory, as related to the MFDS, are presented in Appendix C. The Commonwealth maintains a contact for third party radionuclide and hazardous material/chemical analyses. As the contact is renewed annually, specific information on these labs is impractical to present in this document. In order for a lab to bid on this contract, they must be accredited and meet all US EPA requirements for sample analysis. Based on historical monitoring of the past 15 years, it is not anticipated that the use of a third party lab will be necessary. If third party lab services are required, the MFDS will at that time allow the US EPA to evaluate and approve use of a specific lab.

2.7 Quality Control Requirements The QA objective for measurement data is to ensure environmental monitoring data of known and acceptable quality is provided to support decisions during the ICP. Laboratory data will be used to track migration of contaminants to groundwater and surface water, monitor site conditions, and evaluate the effectiveness of the remedy. Field and laboratory measurement data will be of sufficient quality for data assessment, fact sheet documents, and Site updates to the community, if necessary. Quality control elements for analysis at the MFDS lab are presented in the MFDS Laboratory Manual (Appendix B).


2.7.1 Field Sampling Quality Control

The quality assurance objective is to ensure that the collection and handling methods established in the SAP (Appendix A) are followed during the collection of samples and measurements. Trip blanks, equipment blanks, calibration standard samples, method blanks, and laboratory duplicates will be employed to ensure the representativeness, completeness, and comparability of data. Field data will be recorded to reflect the quality of sample handling and measurement procedures. Chain of custody documentation will be maintained from field sample collection through final laboratory analyses. Annually, the EEC QA Manager or a designee will conduct an audit to assure the following:

Written procedures are available and are being followed for collection of samples.

Chain of custody requirements are being met.

Operational procedures are being followed to assure that the appropriate QC checks are being made in the field and records are maintained of these checks.

Specified equipment is available, calibrated, and in proper working order.

Training requirements are being met

Recordkeeping requirements are being met A report of this audit findings will be submitted to the US EPA in the annual report.

2.7.2 Field Measurement/Analysis Quality Control

Instruments and equipment used to gather, generate, or measure environmental data will be calibrated according to manufacturer’s specifications with sufficient frequency to ensure accuracy and reproducibility of results (section 2.9). At a minimum, monitoring equipment used in the field, will be calibrated or checked for response within 4 hours prior to use, per day. If the calibration/source response results are ±20 percent of the known standard activity, the instrument is approved for use. Calibration data will be recorded in calibration logbooks. The calibration logbooks will be reviewed and signed by a Quality Assurance Manager or designee annually.

2.7.3 Laboratory Analysis Quality Control

The MFDS laboratory has established internal QC procedures that are presented in Appendix B. The MFDS lab participates semi-annually in proficiency testing with an outside laboratory. Quality Control bi-annual audits will be performed by a QA Manager or a designee to evaluate the use of procedures, ensure calibration requirements are being met, and that data management objectives are being performed as prescribed. A report of audit findings will be submitted in the MFDS annual report to the US EPA. Discrepancies will be noted, and an assessment of the impact on the data will be performed. If corrective actions are required, they will be submitted to the US EPA in a formal report. Quality control audits for the RHB lab and third party labs will be performed as described in the operations or procedures manuals of the respective laboratories.


2.8 Instrument and Equipment Testing, Inspection, and Maintenance The objective of the Instrument/Equipment Testing, Inspection, and Maintenance program for sampling and analytical equipment is to avoid generating false environmental measurements that could lead to inappropriate response in the evaluation of the site performance.

2.8.1 Field Measurement Instruments and Equipment

(a) Water Quality Meter

Water quality data is obtained during alluvial well sampling to determine when formation water is present for sampling. This is accomplished with an HORIBA U-50 series water quality meter, or equivalent. The HORIBA requires maintenance and calibration as defined in its owner’s manual. If the HORIBA is determined to be inoperable, a replacement shall be obtained from the DEP central office located in Frankfort or rent one from a vendor. The HORIBA owner’s manual is available in the MFDS file room or it can be accessed via the internet link in Table 2-1.

(b) ISCO Flow and Sampling Equipment

Flow meters and sampling equipment associated with the SWMFs require routine maintenance and inspections. Weekly, the accuracy of the flow meter water level reading will be confirmed with a physical reading of the staff gauge. If the instrument level and staff level differ by +/- ¼”, adjust the instrument level to match the staff level. This adjustment will be noted in the sampling log book. Weekly at each SWMF, evaluate the recorded total flow for the week against the anticipated sample volume collected. Weekly at each sampling station, evaluate the collected sample volume against the anticipated collection volume. Both these evaluations requires the sampler to have an inherent familiarity with the sampler system. Sample volume at the SWMFs is directly related to flow. Sample volume at the surface water sample locations is directly related to time. For example; if there is a high flow volume for the week at the SWMF’s but a low sample volume or vice versa this indicates that an inspection of the sampler system is required. Consult the ISCO flow meter and sampler owner’s manual troubleshooting guide to conduct the investigation. Both flowmeters and samplers have a digital readout screen that provide system warnings/alerts. Consult the owner’s manuals to address these warnings/alerts. Owner’s manuals for field equipment can be found in the MFDS File Room or viewed at the internet links provided in Table 2-1: Currently, the MFDS uses the following ISCO equipment: 3700 Portable Sampler, 6712 Portable Sampler, and Signature Flow Meter. The Commonwealth is required to have at least one spare ISCO sampler and flowmeter available on site to ensure the contamination monitoring requirements of the PSVP are met.


Table 2-2: Owner’s Manual Links for Field Equipment

Equipment Internet Link

3700 Portable Sampler

http://www.teledyneisco.com/en-

us/waterandwastewater/Sampler%20Documents/Manuals/3700ZR%20Sampler%20User%20Manual.pdf

6712 Portable Sampler


us/waterandwastewater/Sampler%20Documents/Manuals/6712%20Portable%20Sampler%20User%20Manual.pdf

Signature Flow Meter


us/waterandwastewater/Flow%20Meter%20Documents/Manuals/Signature%20Flow%20Meter%20User%20Manual.pdf

HORIBA Water Quality Meter

http://www.horiba.com/fileadmin/uploads/Process-Environmental/Documents/U-50_Manual_revised_0409.pdf

http://www.teledyneisco.com/en-us/waterandwastewater/Sampler%20Documents/Manuals/3700ZR%20Sampler%20User%20Manual.pdf


http://www.teledyneisco.com/en-us/waterandwastewater/Sampler%20Documents/Manuals/6712%20Portable%20Sampler%20User%20Manual.pdf


http://www.teledyneisco.com/en-us/waterandwastewater/Flow%20Meter%20Documents/Manuals/Signature%20Flow%20Meter%20User%20Manual.pdf




2.9 Instrument and Equipment Calibration and Frequency The only field equipment requiring calibration is the HORIBA. The HORIBA is a water quality meter that analyzes for dissolved oxygen, turbidity, temperature, pH, and conductivity. It will be calibrated prior to use, per day. If the calibration/source response indicates that the concentration is ± 20 percent of the known standard concentration, the HORIBA will be approved for use. Calibration data will be recorded in Calibration logbooks. The calibration logbooks will be reviewed and signed by a Quality Assurance Manager or designee annually. In the on-site laboratory, the pipette and repipette equipment requires adjustment on a routine basis and the Perkin Elmer 2910TR (Tritium Analyzing Instrument) requires performance assessment each day prior to use. Procedures for Lab Equipment adjustment and assessment is provided in the MFDS Lab Manual (Appendix B). A manufacturer’s maintenance agreement for the Perkin Elmer 2910TR shall be maintained by the Commonwealth that includes a semi-annual inspection schedule and a 48 hour response time for analyzer malfunction. Additional details on the Perkin Elmer 2910TR operation and maintenance can be found in the MFDS Lab Manual (Appendix B), or by contacting the manufacturer.

2.9.1 Field Measurement Instruments and Equipment

An HORIBA Water Quality Meter is used to accomplish alluvial well sampling. The HORIBA shall be calibrated prior to use and maintained as directed in the owner’s manual.

2.10 Inspection and Acceptance Requirements for Supplies and Consumables

The Field Operations Leader will conduct a monthly inspection to determine if certified, laboratory grade supplies and consumables are available. This inspection will be noted in a specified field book and will be audited by a QA Manager or designee annually. A three month supply is required to accommodate any governmental purchasing guideline changes and budgetary constraints that could impact procurement.


2.10.1 Field Sampling Supplies and Consumables

It is the responsibility of the Field Operations Leader to ensure that a minimum three month supply of field sampling supplies and consumables is available on site. Table 2-2 provides a list of Field Sampling Items that shall be available at all times. Required field sampling supplies and consumables for specific sampling activities can be found in the SAP Implementing Procedures (Appendix A).

Table 2-3: Field Sampling Supplies

Latex Disposable Gloves 40mL Glass Vials

Log Books 1-Liter Cubitainers

Labels 1-Gallon Cubitainers

Pens 4-Gallon ISCO Sample Bottles

Permanent Markers Paper Towels

60mL Plastic Bottles

Distilled Water

100mL Glass Bottles 1-Liter ISCO Sample bottles

Teflon Tubing ISCO Sampler tubing

Water Quality Calibration Solutions Nitrile Disposable Gloves

2.10.2 Laboratory Analyses Supplies and Consumables

The short list of required analytical supplies is provided in Table 2-3. It is the responsibility of the Field Operations Leader to ensure a minimum three months inventory of certified laboratory grade supplies and consumables are available on site.

Table 2-4: Laboratory Supplies

Pipette Tips Repipette Tips Nitrile & Latex Gloves all

Sizes

Scintillation Cocktail Tritium Standard Solution Liquid Scintillation Vials (Plastic)


2.11 Data Acquisition Requirements The RHB lab collects and analyzes samples from over 50 locations associated with the MFDS on a routine basis for the full suite of radiological contaminants. The RHB lab uses the data from their analyses to provide them with the required information to evaluate impact of the MFDS on public health, which they summarize and report annually. The CHFS either collects or splits samples with the MFDS for all sampling locations prescribed in the PSVP. This provides an excellent source of additional verifiable data should it be needed for investigative or review purposes. Additional data the CHFS collects that is not provided is in their annual summary report, is available upon request. When photographs are taken of the sampling as part of the documentation procedure, the name of the photographer, date, time, site location, and site description will be entered sequentially in the field sample logbook. Photographic prints will be serially numbered corresponding to the field sample logbook descriptions. The MFDS maintains a historical database on the Commonwealth’s computer network that may be used to evaluate contamination trending and to create long term performance reports.

2.12 Data Management

Data generated will be used to satisfy the individual task requirements of the PSVP. Field and laboratory data will be used to determine migration of contaminants to groundwater and surface water, monitor site conditions, and evaluate the effectiveness of the remedy. The Field Operations Leader will ensure a hard copy of all data is maintained at a location that protects the data from fire, temperature, humidity, insects, and other vectors of degradation. A database (Microsoft® Excel or equivalent) of the data results and an electronic scanned copy of the full data validation record shall be maintained on the Commonwealth’s computer network. This will allow for nightly backup of the data. The Field Operations Leader is responsible for maintaining the MFDS database (Microsoft® Access, TEMPO or equivalent) as an electronic repository for Site PSVP data. The Field Operations Leader will provide electronic database updates to the US EPA, Project Coordinator, Project Manager, and the QA Managers on a monthly basis. Table 1-8 provides a schedule of data submittal and monitoring reports for the ICP. If data errors are found during the data validation process, corrections will be made and the data resubmitted for validation. If any data errors are found after validation, corrections will be made and documented. If the data was released or published it will be retracted and all parties that received the data submittal will be notified. The Field Operations Leader will also notify all personnel in the Organizational Chart (Figure 1.1).


3.0 ASSESSMENT AND OVERSIGHT

3.1 Assessments, Oversight, and Response Actions Systems audits of laboratories, field sampling, and measurement will be conducted bi-annually during the first five (5) year review cycle of the ICP. A Change Request may be submitted at the end of the first 5-year cycle to modify the audit schedule. The audits will verify that QAPP procedures are in place and used, an acceptable calibration program is in place, an organizational structure is in place and personnel responsibilities are clearly defined, that a training program for personnel is available, that a chain of custody program and records retention program are in place, and that corrective action of variances taken by laboratory and field personnel is responsive and timely. Prior to startup of any new field activities, a QA Manager or designee shall conduct an initial system audit to examine the following:

Organization and responsibilities: The QA Manager will determine whether the QA organization is operational.

The collection of samples: The QA Manager will assure that written procedures are available and are being followed.

Chain of custody program: The QA Manager will assure that the appropriate steps have been followed in the traceability of sample origin.

The implementation of the operational procedures: The QA Manager will assure that the appropriate QC checks are being made in the field and records are maintained for these checks.

The QA Manager will determine whether the laboratory, filed sampling and measurement equipment is available, calibrated, and in proper working order.

Training: The QA Manager will assure that sampling crews are adequately trained in sample collection procedures.

Audits performed by the MFDS analytical laboratories are described in the MFDS Lab Manual (Appendix B). The laboratory facilities of the Commonwealth participate regularly in proficiency testing with an outside laboratory. As stated in Section 3.2, a report of audits will be submitted in the MFDS annual report to the US EPA. Discrepancies will be noted and an assessment of the impact on the data will be performed. Corrective actions will be submitted to the US EPA in a formal report. The QA Managers will submit a report to the Program Manger identifying any system or startup failures associated with this document. The Program Manger will inform the US EPA Remedial Project Manager and together they will determine what actions are necessary to correct the issues.

3.2 Reports to Management Annually, the Commonwealth will submit a report to: the US EPA, the KY DEP, and the CHFS within 90 days of year-end providing a summary of calendar year data collected pursuant to the PSVP, annual dose calculations, and an assessment of site conditions. Every five years, the Commonwealth will participate with the US EPA to provide data in any format necessary to complete the US EPA’s Five Year Review.


4.0 DATA REVIEW AND USABILITY

4.1 Data Review, Verification, and Validation Requirements

The intent of contamination monitoring at the MFDS is to produce quality data for assessing contamination transport and derived dose during ICP. Data verification will evaluate data packages produced by the laboratory to ensure that the documentation meets the requirements established by the PSVP and this document. PSVP analytical data will be validated within 60 days of sample analysis, and entry into the MFDS database will be performed within 30 days of validation. The following should be included in the data verification package:

Sample Descriptors – matrix, identification number, analytical procedure, and other characteristics of the sample.

Aliquot Size – sample size used for analysis should be documented so it can be used when analyzing calculations.

Dates of Sample Collection, Preparation and Analysis – essential to meet the date frame for timely analysis and inclusion in the database.

Filtration and Preservation – indication of preservative used and the point at which the preservative may have been added to samples.

Tracking – used to ensure analytical results can be traced to the instrument or detector. Allows analysis of the quality control for procedures.

Traceability – ensures that standards used for analytical procedures can be traced to acceptable standards.

Chemical Separation – the yield of the procedure must be provided in order to document calculations.

Dilution and Correction Factors – each dilution factor and correction factor affecting the analytical results must be provided.

Self-Absorption – for gross alpha and beta analyses the self-absorption factors must be provided.

Counts and Count Time – each sample count time must be provided to ensure calculations can be performed during data validation.

Quality Control – all instrument quality control charts must be provided in the data package.

Data Reduction – provides the methods to convert “raw data” to information that can be used for data assessment.

Method Detection Limit – each analytical procedure must indicate the method detection limit.

Measurement Uncertainty – each result must be accompanied by the measurement uncertainty. The information in the verification process can be used by laboratory personnel or the data validator to identify anomalies that may exist within the data packages. The validation process addresses the reliability of the data. Validation allows the data be utilized to compare the data to action levels in the PSVP and to analyze long-term data trends that could potentially impact remediation performance.


The data validator evaluates the data produced with the quality objectives and other analytical requirements necessary to meet DQOs and the data requirements of the PSVP. The validation process will proceed as follows:

A review of the laboratory data package will be performed.

Weaknesses or strengths in the data package will be determined.

Each component of the validation package shall be evaluated to determine whether it meets the needs of the PSVP.

Evaluation of the data to determine the presence or absence of the analyte will be performed

Evaluation of analytical measurement uncertainty will be performed.

The acceptability of data will be determined.

Once validated, data can be entered into the MFDS database.

Data may be rejected if insufficient or incorrect information is not available to make fundamental data decisions.

If the measurement uncertainty is not provided with the data, the data shall be rejected.

If the critical level and the method detection limit is not provided, the data may be rejected.

The laboratory shall be required to either rerun the sample or calculate the uncertainty if the necessary information is available and can be documented to be associated with the analysis.

The data will also be rejected if the necessary quality control information has not been provided to support the data.

Data can also be rejected based on multiple problems with results such as chemical yield, patterns in data, or if insufficient background or calibration standards are used.

4.2 Verification and Validation Methods

4.2.1 Data Verification

All data shall be verified by the Quality Assurance Managers, Field Operations Leaders or the Project Manager as to the quality of the data prior to release for validation. The following items will be reviewed to verify the data:

Field sampling procedures are followed

Laboratory tracking numbers are used for all samples

Sample information is recorded for all samples

Field sampling logs are completed and signed

Equipment calibration and QC data is included

QC is within tolerance limits

Sample identification, laboratory tracking, raw data, data reduction calculations, QC charts, and chain of custody is included


4.2.2 Data Validation

An independent review of field measurements and laboratory documentation systems will be conducted to validate the data. This review will examine the following:

Proper sampling procedures are employed.

Documentation that the analytical results are within the MQOs.

Calibration methods of the instruments.

Routine instrument checks.

Documentation on traceability of instrument standards, samples, and data.

Documentation on analytical methodology and QC methodology.

Results of competency audits with appropriate audit materials.

The ability to limit or eliminate interference contaminants in analytical methods.

Documentation of routine maintenance activity to ensure analytical reliability.

Samples will be retained until verification and validation has been completed. Data may be verified but not validated due to uncertainties exceeding acceptable MQOs. These uncertainties may prevent data use for public health assessments, but may allow use as an indicator of the need for additional measurements or sample collection and analyses.

4.3 Reconciliation with User Requirements Verified and validated results shall be used in assessing the performance of the RA, directing ICP maintenance activities, and documenting changes in site conditions. Data trends and anomalies will be used to evaluate long and short-term potential impacts on the environment, and to determine anomalies or departures from assumptions established by baseline data. Historically, over 1,000 aliquots are used to derive the annual averages at the TEDE and REI compliance points. Single anomalies will therefore not impact the annual evaluation of exposure. An assessment of the analytical results will be performed annually to verify the data are sufficient in quality to meet their collection intent, and in quantity to describe the applicable contaminant characteristics of the Site. The results will be compared against the following on an annual schedule:

Background values for tritium in water from Rock Lick Creek, and alluvial groundwater.

25 mrem/yr TEDE at the original site boundary and SWMFs

4 mrem/yr REI surface water at 102D

20pCi/mL for perennial streams and groundwater.

Continued sampling of potential water sources may be necessary for the duration of the ICP. Should

conditions at the MFDS change significantly or issues with compliance levels develop, exposure pathways

other than waterborne may have to be considered.


5.0 REFERENCES

Carey, W. P., Lyverse, M. A., & Hupp, C. R. (1990). Hillslope Erosion at the Maxey Flats Radioactive

Waste Disposal Site, Northeastern Kentucky(Water Resources Investigation Report 89-4199).

Louisville, KY: USGS.

Commonwealth of Kentucky (1998). Maxey Flats Disposal Site Initial Remedial Phase Monitoring and

Maintenance Plan, Final Submittal. Fleming County, KY.

Commonwealth of Kentucky (2013). Maxey Flats Disposal Site FCP Work Plan. Fleming County, KY.

Ebasco Services, Inc. (1989). Maxey Flats Disposal Site Remedial Investigation Report.

Birmingham, AL.

Cumbee, G (2016). Geoscience Report on Wells. Frankfort, KY.

IT. (2000). Design Analysis Report for Remaining Work at Maxey Flats Disposal Site, Final Submittal.

Fleming County, KY.

IT. (2000). Maxey Flats Disposal Site IRP Remaining Work Final Design. Fleming County, Kentucky.

Thomas, N.O. & Jackson, Jr., N.M. Jackson (1981). Manual for Leveling at Gaging Stations in North

Carolina(OF81-1104). Louisville, KY:USGS.

Commonwealth of Kentucky (2002). MFDS Interim Maintenance Period Work Plan. Hillsboro, KY.


Intergovernmental Data Quality Task Force. (2005). Intergovernmental Data Quality Task Force

Uniform Federal Policy for Quality Assurance Project Plans Evaluating, Assessing, and

Documenting Environmental Data Collection and Use Programs Part 1: UFP-QAPP

Manual(EPA-505-B-04-900 A).

HORIBA. (2018). U-50 User’s Manual. Retrieved June 18, 2018, from

http://www.horiba.com/fileadmin/uploads/Process-Environmental/Documents/U-

50_Manual_revised_0409.pdf

Teledyne ISCO (2018). Model 3700 User’s Manual. Retrieved June 18, 2018, from


us/waterandwastewater/Sampler%20Documents/Manuals/3700ZR%20Sampler%20

User%20Manual.pdf

Teledyne ISCO (2018). Model 6712 User’s Manual. Retrieved June 18, 2018, from


us/waterandwastewater/Sampler%20Documents/Manuals/6712%20Portable%20Sa

mpler%20User%20Manual.pdf

Teledyne ISCO (2018). Signature Flow Meter User’s Manual. Retrieved June 18, 2018, from


us/waterandwastewater/Flow%20Meter%20Documents/Manuals/Signature%20Flow

%20Meter%20User%20Manual.pdf










