4>EPA
EPA/600/R-08/128 | Febraary 2009 www.epa.gov/ord
   United States
   Environmental Protection
   Agency
           Guide for Development of
           Sample Collection Plans for
           Radiochemical Analytes in
           Environmental Matrices Following
           Homeland Security Events
   Office of Research and Development
   National Homeland Security Research Center

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                                EPA/600/R-08/128 | February 2009 www.epa.gov/ord
         Guide for Development of Sample
         Collection Plans for Radiochemical
         Analytes in  Environmental Matrices
         Following Homeland Security Events
        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

        Office of Research and Development, National Homeland Security Research Center,
        Cincinnati, Ohio 45268

        Office of Radiation and Indoor Air, National Air and Radiation Environmental Laboratory,
        Montgomery, Alabama 36115

        Office of Emergency Management, National Decontamination Team,
        Erlanger, Kentucky 41018
        COMPUTER SCIENCES CORPORATION
        Alexandria, Virginia 22304-3540
Office of Research and Development
National Homeland Security Research Center

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                                                                 Disclaimer /Acknowledgements
                                      Disclaimer

The U.S. Environmental Protection Agency through its Office of Research and Development funded the
research described here under Contract Number EP-W-06-046 to Computer Sciences Corporation. It has
been subjected to the Agency's review and has been approved for publication. Note that approval does
not signify that the contents necessarily reflect the views of the Agency.
                                Acknowledgements

This guide was developed collaboratively by EPA's National Homeland Security Research Center
(NHSRC), EPA's Office of Radiation and Indoor Air (ORIA), and EPA's Office of Emergency
Management National Decontamination Team. The document team consisted of Ms. Kathy Hall
(NHSRC, project lead), Dr. John Griggs (ORIA), and Mr. Scott Hudson, CHP (NOT). Special
acknowledgment and appreciation is extended to Ms. Schatzi Fitz-James, Office of Emergency
Management, Homeland Security, Laboratory Response Center, for her support of the Radiological
Emergency Response Laboratory Network effort.

We also wish to acknowledge the external peer reviews conducted by Mr. Bob Dye, EPA Region 7; Mr.
Richard Poeton, EPA Region 10; Nidal Azzam, EPA Region 2; and NHSRC internal peer reviewer Mr.
John Drake, DCMD, whose thoughtful comments contributed greatly to the quality of the guide.
Technical Support was provided by Mr. Larry Umbaugh, Computer Sciences Corporation (CSC).
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                                                                             Table of Contents
                                  Table of Contents
ABBREVIATIONS AND ACRONYMS	V

1.0   INTRODUCTION	1

2.0   OVERVIEW OF THE SCP DEVELOPMENT PROCESS	2

  2.1    PHASE I-DATA ACQUISITION AND REQUIREMENTS DETERMINATION	3
  2.2    PHASE II - SCP DESIGN AND DEVELOPMENT	3
  2.3    PHASE III - SCP IMPLEMENTATION	3

3.0   PHASE I - SCP DATA ACQUISITION AND REQUIREMENTS DETERMINATION	4

  3.1    DATA QUALITY OBJECTIVES (DQOs) AND QUALITY ASSURANCE PROJECT PLAN (QAPP)	5
  3.2    RADIOLOGICAL AND INDUSTRIAL HEALTH AND SAFETY PLANS	5
  3.3    INITIAL SITE INFORMATION	6
  3.4    IDENTIFY REAL PROPERTY RADIOLOGICAL CONTAMINANTS	7
  3.5    IDENTIFY CONTAMINATED AREAS	7
  3.6    IDENTIFY CONTAMINATED MEDIA	8

4.0   PHASE II - SCP DESIGN AND DEVELOPMENT	9

  4.1    REVIEW OF SUCCESSFUL SAMPLING PLANS	11
  4.2    DEFINING RADIOANALYTICAL LABORATORY REQUIREMENTS FOR SCP SAMPLE ANALYSIS	11
  4.3    CLASSIFY AREAS BY CONTAMINATION POTENTIAL	12
  4.4    SELECT BACKGROUND REFERENCE AREAS	12
  4.5    IDENTIFY SURVEY UNITS	13
  4.6    DEVELOP A CONCEPTUAL CLEANUP MODEL OF THE SITE FOR SCP PLANNING	13
  4.7    SELECTION OF SAMPLING DESIGNS	13
  4.8    WRITING THE SCP - CONTENT OF MAJOR ELEMENTS	20
     4.8.1    Project Background	20
     4.8.2    Project Organization and Responsibilities	20
     4.8.3    Project Scope and Objectives	21
     4.8.4    Non-Measurement Data Acquisition	21
     4.8.5    Field Activities-Project Sample Collection Procedures	21
     4.8.6    Radiological Field Measurements and Instrumentation	22
     4.8.7    Field Operations Documentation	22
     4.8.8    Sample Packaging and Shipping Requirements	23
     4.8.9    Sampling Waste	23
     4.8.10     Project Quality Assurance (QA)	23
     4.8.11     Non-Conformance/Corrective Actions	24
     4.8.12     SCP Appendices	25
  4.9    SCP REVIEW AND APPROVAL	25
  4.10   SCP DISTRIBUTION	26

5.0   PHASE III - SCP IMPLEMENTATION	27

  5.1    PERSONNEL TRAINING	27
  5.2    FIELD SAMPLE COLLECTION	27
  5.3    PROJECT LIAISON	27
  5.4    SCP COMPLIANCE MONITORING	28
     5.4.1    Project, Field, and Laboratory Audits	28
     5.4.2    Project Activity Reports	28
  5.5    SITE DISPOSITION	29

6.0   ADDITIONAL RESOURCES	30

7.0   REFERENCES	31

APPENDIX A SAMPLE COLLECTION PLAN DESIGN ELEMENTS AND DEVELOPMENT
CHECKLIST	33


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                                                                    Abbreviations and Acronyms


                          Abbreviations and Acronyms

     CFR            Code of Federal Regulations
     COC            Chain of Custody
     D&D           Decontamination and Decommissioning
     DCGL          Derived Concentration Guideline Level
     DOE            U.S. Department of Energy
     DOT            U.S. Department of Transportation
     DQO            Data Quality Objective
     ERLN          Environmental Response Laboratory Network
     EPA            U.S. Environmental Protection Agency
     FRMAC        Federal Radiological Monitoring and Assessment Center
     HASP          Health and Safety Plan
     HSA            Historical Site Assessment
     IATA           International Air Transportation Association
     IMAT          Incident Management Assistance Team
     MARLAP       Multi-Agency Radiological Laboratory Analytical Protocols Manual
     MARS SIM      Multi-Agency Radiation Survey and Site Investigation Manual
     MDC           Minimum Detectable Concentration
     MQO           Measurement Quality Objective
     NIST           National Institute of Standards and Technology
     PAG            Protective Action Guides
     PE             Performance Evaluation
     QA             Quality Assurance
     QAPP          Quality Assurance Project Plan
     QC             Quality Control
     RPG            Radiation Protection Group
     RSP            Radiation Safety Plan
     SAM           Standardized Analytical Methods for Environmental Restoration Following
                     Homeland Security Events (U.S. EPA)
     SCP            Sample Collection Plan
     SHO            Safety and Health Officer
     SOP            Standard Operating Procedure
     SOW           Statement of Work
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                                                                           Section 1.0 - Introduction
1.0   Introduction
       The purpose of this document is to provide a framework to assist incident commanders, project
       managers, state and local authorities, contractors, and enforcement divisions in developing and
       implementing an approach for sample collection during the cleanup of an urban environment after
       a radiological homeland security event. Information in this document can be used to develop a
       systematic and integrated methodology to sample collection, which will meet data use needs and
       site disposition objectives. This document incorporates site-specific optimization processes to
       include quantitative and qualitative assessments applied at each stage of site cleanup decision
       making: from initial scoping and stakeholder outreach, to evaluation of cleanup options, to
       implementation of the chosen alternative.

       It is projected that, following initial site investigation and response, contaminated sites will be
       turned over by the U.S. Department of Energy's (DOE) Federal Radiological Monitoring and
       Assessment Center (FRMAC) to the U.S. Environmental Protection Agency (EPA) for cleanup.
       Traditional radiological site cleanup processes may not be completely followed after a homeland
       security event because of the urgency to resume use of the affected area as soon as possible.

       The elements in this document are intended to provide a general guide for preparation of
       homeland security event-specific sample collection plans  (SCPs) for the collection of
       environmental data in compliance with EPA requirements regarding quality assurance (QA),
       quality control (QC), and data quality objectives (DQOs). Additional guides may be issued to
       clarify or amend the traditional cleanup protocols. The elements can be used for  developing
       SCPs for site investigation, characterization, cleanup, final status surveys to release a site, or to
       support decision making for the final disposition of the site following a homeland security
       radiological event. It is assumed that the number of SCPs required, and the details contained
       within each, is dependent on the size and complexity of the specific event site.

       This document does not provide information and instructions that are included  in the following
       documents, which must be developed for each project/site in addition to an SCP:

       •   Quality assurance project plan
       •   Radiation safety plans and associated procedures
       •   Health and safety plan and associated procedures

       The information in this document is intended to apply only to the development of SCPs for
       cleanup of real property  sites contaminated with radioactive materials from a homeland security
       event. EPA's Standardized Analytical Methods for Environmental Restoration Following
       Homeland Security Events (SAM) should be reviewed for analytical methods to be used during
       laboratory analysis of specific radionuclides. EPA's Sample Collection Procedures for
       Radiochemical Analytes in Environmental Matrices (EPA/600/S-07/001) should be reviewed for
       information regarding sample collection procedures and equipment. If additional contamination
       is present (e.g., unexploded ordnance, chemical warfare agents, biological wastes, hazardous
       chemical waste, and/or mixed waste), additional direction will be required.  It will be necessary to
       develop an SCP that includes information on how to handle these materials.
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                                               Section 2.0 - Overview of the SCP Development Process
2.0  Overview of the SCP Development Process
       Figure 2.1 provides a flowchart of major SCP developmental elements and the general processes
       of project needs determination through development of sample collection plans and eventual site
       disposition. The general phases of this process are presented in Figure 2.1, specific SCP elements
       are described in this document for each phase. The user is encouraged to review the flowchart for
       each phase. Other elements, as determined in relevant documents listed in Section 6.0, may also
       be included in the SCP development process.

                                          Figure 2.1

                  Sample Collection Plan  (SCP) - Overview
           c in
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                     Data Quality
                   Objectives (DQOs)
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 Radiological &
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                                                  Section 2.0 - Overview of the SCP Development Process
2.1    Phase I - Data Acquisition and Requirements Determination
       Before preparing an SCP the project should assemble a core SCP design team.  Team members
       may include, but are not limited to:
       •   Risk assessors
       •   Statisticians
       •   Technical planners
       •   Health physicists
       •   Radiochemists
       •   Civil engineers
       •   Radiological engineers
       •   Health and safety specialists
       •   Construction specialists
       •   Public and media relations specialists
       •   Regulatory specialists
       •   State and local subject matter experts
       •   Legal specialists
       •   Incident commanders
       •   On-scene coordinators

       The SCP design team must review the information provided in the Phase I section (see Section
       3.0), and perform a thorough review of all appropriate documents, including any statements of
       work (SOWs), quality assurance project plans (QAPPs), DQOs, health and safety plans (HASPs),
       radiation safety plans (RSPs), or specifications regarding the impending cleanup effort and
       disposition decision.

2.2    Phase II - SCP Design and  Development
       The SCP design team gathers the important site information obtained in Phase I and prepares the
       SCP prior to any field activities.  The SCP will likely be amended or revised several times during
       cleanup.  For each SCP developed, the format and content should be consistent with this
       document, regardless of the size  of the project.  Section 4.0 describes the general format and
       content considerations for an SCP.  A good working knowledge of these elements is necessary to
       understand the type of information required and to determine if additional sources of information
       are needed.  Appendix A lists the typical elements that should appear in the SCP.  Specific
       elements that should be included will depend on the size and/or complexity of the cleanup
       project, and the SCP format should be modified as appropriate.

2.3    Phase III - SCP  Implementation
       An EPA approved and cleared SCP, from the Phase II process, must be in place before data
       collection activities commence.  All SCP activities must be performed in compliance with the
       approved/cleared SCP and should be monitored and verified throughout implementation (See
       Section 5.0).

       While data collection activities are being performed, SCP compliance is monitored by conducting
       field, desk, and laboratory audits. SCP defined QA elements (i.e., field control samples, QA
       laboratory analyses, data assessment procedures) are also monitored to ensure SCP compliance.
       QA audits of the SCP must conform to requirements set in the QAPP.

       When all of the SCP activities are completed, an evaluation is made to determine if the site
       cleanup sampling goals and objectives have been met. If the goals and objectives have not been
       met, the SCP is reevaluated by returning to Phase II.

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                                  Section 3.0 - Phase I - SCP Data Acquisition and Requirements Determination
3.0   Phase I - SCP Data Acquisition and Requirements Determination
        To prepare an SCP, it is necessary to understand all requirements included in the project DQOs,
        QAPPs, and the site-specific requirements included in the project's HASP and RSP as shown in
        Figure 3.1.  SCP developers also must consider all available existing information regarding the
        specific site and project, including data collected during the initial response phase of the event.

        SCP developers should consult with the response team to obtain information collected during the
        initial phase of the event.  As time permits, the team should review data from previous
        investigations, and/or information regarding site constraints. Before preparing an SCP,
        developers should perform a thorough review of all appropriate project documents, including any
        SOWs, QAPPs, DQOs, HASPs, RSPs, or specifications regarding the project or containing
        project planning results.

        The level of specificity outlined within these project documents may vary from outlining general
        project goals to specifying sampling and analytical requirements to meet project DQOs. Project
        documents should identify additional  applicable references that might be  required for obtaining
        background information, including (but not limited to):

        •    Engineering regulations and guidance documents
        •    Regulatory program and status reports from previous investigations
        •    Construction data
        •    Ownership/operational histories
        •    Site maps and photographs
        •    Information on regional and site geology, hydrogeology, hydrology,  topography, ecology,
            climatology, demographics
        •    Current and future land use
                                            Figure 3.1
          Phase I - SCP Data Acquisition & Requirements Determination
  Data Quality Objectives
       (DQOs)
 Quality Assurance Project
     Plan (QAPP)
Radiological Safety Plans
        &
 Health and Safety Plans
                                   To Phase II
                                   SCP Design
                                 and Development
Initial Site Information
                                                                                Ground Zero Location
                                                                              Preliminary Site Assessment
                                                                                 Site Inspections
                                                                               Event Cleanup Actions
                              Engineering Evaluations
                                                                                  Cost Analysis
                                                                             Historic Site Assessments and
                                                                                  Investigations
                                                                               Initial Corrective Actsons
                                                                            Identify Radiological Contaminants
                                                                              Identify Contaminated Areas
                                                      Identify Contaminated Media
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                                 Section 3.0 - Phase I - SCP Data Acquisition and Requirements Determination


3.1    Data Quality Objectives (DQOs) and Quality Assurance Project Plan (QAPP)
       According to EPA policy, systematic planning must be used to develop acceptance or
       performance criteria for collection, evaluation, or use of environmental data. Systematic planning
       identifies the expected outcome of the project, technical goals, cost and schedule, and the
       acceptance criteria for the final result, which must be documented in a QAPP. As defined in the
       Code of Federal Regulations at 40 CFR 300.430, the QAPP describes policy, organization, and
       functional activities, as well as the DQOs and measures necessary to achieve adequate data.  The
       QAPP is a plan that provides a process for obtaining data of sufficient quality and quantity to
       satisfy data needs.

       The development of a QAPP is separate from the  SCP, but is essential in defining project DQOs
       and activities needed to ensure that project quality criteria are met. A site-specific QAPP is
       usually developed in parallel with the development of an  SCP. Information pertaining to the
       preparation of a project-specific QAPP can be found in EPA QA/G-5, Guidance for Quality
       Assurance Project Plans, December 2002. Project managers and planners should also review
       information regarding the DQO process provided in Guidance for Systematic Planning Using the
       Data Quality Objectives Process, EPA QA/G-4, EPA/240/B-06/001, February 2006;  and Multi-
       Agency Radiation Survey and Site Investigation Manual, NUREG-1575, Rev. 1; EPA 402-R-97-
       016, Rev.  1; DOE/EH-0624, Rev. 1; August 2000 (MARSSIM).

       Specific QAPP DQO elements related to collection of environmental data include:

       •   Measurement quality objectives (MQO)
       •   Cleanup goals, cleanup options, and establishment of derived concentration guideline levels
           (DCGLs).  [NOTE: MARSSIM should be consulted to gain a thorough knowledge of
           DCGLs and how they are interconnected to the SCP and the DQOs of the QAPP.]
       •   Survey units identification
       •   Data assessment including data quality indicators for  precision, bias, completeness,
           representativeness, reproducibility, comparability, sensitivity, and statistical confidence
       •   Data verification
       •   Data validation

3.2    Radiological and Industrial Health and Safety Plans
       Safety is a primary consideration in any sampling event, and is a critical consideration during
       development of an SCP.  Personnel safety requirements and considerations for a particular site
       may extend beyond radiological concerns, and may include physical hazards and chemicals that
       are toxic, corrosive, emit harmful or explosive vapors, or  are incompatible when mixed.  The SCP
       must be consistent with all radiation and industrial safety  requirements and procedures associated
       with a site. The SCP also must include or reference site-specific personnel safety and protection
       plans for radiation and industrial health/safety.

       Radiation  protection requirements included in the site RSP are developed and implemented by the
       site radiation protection group (RPG), which is responsible for:

       •   Developing and implementing a RSP and radiation work plans for individuals working at the
           site
       •   Taking measurements of the radiation levels of all sampling sites and associated activities
       •   Dictating the radiation protection requirements for entering and working in a radioactively
           contaminated sampling area
       •   Stopping any activity to protect personnel from overexposure to radiation or from radioactive
           material contamination

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                                  Section 3.0 - Phase I - SCP Data Acquisition and Requirements Determination
       Industrial safety requirements included in the site HASP are developed and instituted by a
       designated safety individual (e.g., safety and health officer, SHO), who is responsible for:

       •   Developing and implementing a HASP and safety work plans
       •   Assessing all site activities for potential safety concerns
       •   Ensuring that personnel are informed as to the potential hazards in a sampling area and
           dictating the requirements for safely working at the site
       •   Stopping any job or activity to protect personnel from a dangerous situation

3.3    Initial Site Information
       When FRMAC turns a site over to the EPA for cleanup, FRMAC typically will provide detailed
       response-stage investigation data for review and use in planning the site cleanup. In general, the
       information will detail how the  investigation was conducted, identify contamination boundaries
       and grid systems, and detail contamination gradients. This information is critical for designing an
       appropriate and successful SCP that is consistent with the site investigation. The detailed
       information provided by FRMAC should include:

       •   Location of ground zero
       •   Preliminary site assessment information and data
       •   Site inspections
       •   Event cleanup actions
       •   Historical site assessments and investigations
       •   Any initial corrective cleanup actions performed to secure and control the effected site
       •   Identification of radiological contaminants, contaminated areas, and contaminated media
       •   Meteorological data

       In addition to the information typically provided by FRMAC, but that is also important in
       designing a SCP includes information and data generated during engineering evaluations and cost
       analyses.

       If detailed response data/information is not available when the site is turned over to the EPA, as
       might be the case following a homeland security incident, the information provided in this
       document will enable the planning team to develop an SCP for site investigation and
       characterization, site cleanup, final status surveys, and site disposition. A historical site
       assessment (HSA) or operational history, if applicable, can also be performed to identify areas of
       environmental concern or liability from historical or current use of radiological substances (see
       MARSSIM Chapter 3). Information tracking these uses should be collected, and includes:

               Existing Radiation Data Prior to the Homeland Security Contamination Event -
               Review of applicable documents and records to determine if any information is available,
               via public records, regarding potential  pre-existing radiological contamination.

               Interviews - Interviews with current owner(s), building management companies,
               manager(s) or other responsible parties, local government officials, and residents to
               obtain as much information as possible regarding the site and  any operations and
               activities that occurred on it. Included in this inquiry would be past and present
               environmental practices, improvements or alterations,  site operations, and plans for future
               use.
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                                 Section 3.0 - Phase I - SCP Data Acquisition and Requirements Determination


               Site Reconnaissance - A site visit or inspection to observe current uses (and evidence of
               past uses, whenever possible), including those likely to involve the use, treatment,
               storage, disposal, or generation of radioactive materials.

               Evaluation of Data - A written report to document initial investigation phase findings,
               observations, and recommendations, including suspected or identified areas of
               radiological concern or liability and what sampling and analyses activities were
               conducted to verify the suspected areas of contamination. This report should demonstrate
               that inquiries were sufficient to ascertain site ownership and uses prior to the event, and
               to minimize any future liability in the event that radiological contamination is found after
               cleanup or the detection threshold is lowered after the site is turn over for cleanup.

3.4     Identify Real Property Radiological Contaminants
        Once potential areas  of concern or contamination are identified and evaluated, an SCP strategy is
        developed so that sufficient data can be obtained to allow a designated individual or group to
        conclude that the contaminant(s) of concern:

        •   Is present at levels above the cleanup goals and cleanup is necessary, or
        •   Is present at levels below the cleanup goals and no further action is required, or
        •   Is not present above specified detection limits and no further action is required.

        If contamination is present at levels above the cleanup goals risk-based release limits, the SCP
        should ensure that sufficient data are generated to characterize the extent of contamination.

3.5     Identify Contaminated Areas
        Prior to cleanup following initial response to a homeland security event, affected and unaffected
        real property areas will need to be assessed to identify the extent of contamination.  Sample
        collection and analysis will be required to assess the type, degree and extent of contamination.
        This assessment, as defined by FRMAC1, is the evaluation and interpretation of environmental
        radiological data obtained during or following a radiological emergency. The primary products
        of the FRMAC assessment include  interpretation of the post-event radiological situation in terms
        of the Protective Action Guides (PAGs).

        Assessment of the area for cleanup  actions will rely on initial post-event measurements and
        model predictions. Initial field measurements from the Incident Management Assistance Team
        (IMAT) first responders and FRMAC teams will be used in SCP development effort to identify
        the areas of contamination.  This information includes:

        •   Field survey measurements
        •   Aerial radiological surveys
        •   Laboratory analyses of various samples, such as soil, air, water, vegetation, and foods
        •   Meteorological information
        •   Models (plume dispersion area, deposition rates, and re-suspension probabilities)

        It should be noted that the initial assessment models and cleanup goals might be enhanced and/or
        changed after the results of detailed radiological characterization are gathered.

        Prior to cleanup actions, information garnered from FRMAC assessments are coupled with data
        obtained from historic information  (local public, corporate, and governmental information).  This
1 FRMAC Assessment Manual Methods, Volume 1, SAND2003-1071P
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                                  Section 3.0 - Phase I - SCP Data Acquisition and Requirements Determination


       information is used to identify areas where contamination could have spread or areas that may
       affect the actions for cleanup of the area.  Examples of historic information to examine include:

       •   Infrastructure data (water, cable, electric, and sewer systems, underground transport or other
           types of pipe chases or transport facilities)
       •   Geological and geographical data (water table information, soil composition, bedrock strata)
       •   Documentation of facilities, businesses, or dwellings where radioactive materials used,
           stored, or disposed of prior to the radiological emergency (radioisotopes used by medical
           professionals, radiological sources used by industries, contaminated backfill material, etc.)
       •   Records, such as news articles or local emergency responder reports, that indicate  spills,
           discharges, or other unusual occurrences that could have resulted in the additional  spread of
           contamination.  (These should include spills of solvents or other materials that may influence
           transport mechanisms in ground water and soil.)

       Areas immediately  surrounding, or adjacent to, the affected area are included in the identification
       of contaminated areas because of the potential for inadvertent spread of contamination from
       airborne re-suspension, meteorological conditions, wildlife movements, etc. (See MARSSIM
       Chapter 3.)

3.6    Identify Contaminated Media
       The next step in evaluating the data gathered is to identify potentially contaminated media.
       Identification of media that have the potential to contain, or that do not contain residual
       contamination, is used for preliminary classification and for planning subsequent SCP  sampling
       activities.  MARSSIM Section 3.3.6 provides guidelines on evaluating the likelihood for release
       of radioactivity into the following environmental media: surface soil, subsurface soil, sediment,
       surface water, ground water, air, and buildings.  The evaluation will result in a finding of either
       "Suspected Contamination" or "No Suspected Contamination," which may be based on analytical
       data,  professional judgment, or a combination of the two.
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                                                        Section 4.0 - Phase II - SCP Design and Development
4.0  Phase II - SCP Design and Development
        The information and documents gathered and generated during Phase I are used to design and
        develop the project SCP as shown in Figure 4.1.  SCPs are designed to layout and describe
        project requirements for conducting and completing all field sampling activities, corresponding
        data assessment activities, and reporting requirements.  Elements that are included in an SCP are
        listed in Appendix A and described in detail in this section. Specific elements that should be
        included will depend on the size and/or complexity of the cleanup project, and the SCP format
        should be modified as appropriate. The  SCP is prepared and approved prior to initiation of any
        field activities and is expected to be amended or revised several times during cleanup.
      From Phase 1
   SCP Data Acquisition
          &
      Requirements	
      Determination
      No
                  SCP
                 Design &
               Development
                  SCP
                 Writing
                  SCP
                 Review
            Figure 4.1

Phase II - SCP Design and Development
               To Phase III
            SCP Implementation
             Review Checklist
-^^ SCP ^^^^
^^ Approved? ^^^
\ Yes
SCP
Distribution
i
>









Regulatory Authorities
State & Local Authorities
Stakeholders
Incident Commanders/Project Managers
Project Laboratories
Contractors

                                                                             Analytical Laboratory Requirements
                                             Classify Areas by Contamination
                                                    Potential
                                           Select Background Reference Areas
                                                                                 Identify Survey Units
                                                                             Develop Conceptual Cleanup Model
                                             Selection of Sampling Designs
                                                                                  Project Background
                                                                            Project Organization & Responsibilities
                                              Project Scope & Objectives
                                                                             Non-Measurement Data Acquisition
                                                                             Field Activities - Sample Collection
                                                                              Radiological Field Measurements
                                                                              Field Operations Documentation
                                                                               Sample Packaging & Shipping
                                                                                   Sampling Waste
                                                                                Project Quality Assurance
                                                                             Non-Conformance/Corrective Actions
                                                                                  SCP Appendices
        Prior to initiation of SCP design, the decision maker(s) and sample collection planning team
        should review the QAPP and corresponding DQOs, from Phase I, to identify the data needs and
        purpose for sample collection(s), including:

        •   Sample collection locations and frequencies
        •   Types of samples to be collected or measurements to be performed
        •   Target radionuclide(s)
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                                                    Section 4.0 - Phase II - SCP Design and Development


       •   Potential interfering radionuclides and chemical contaminants
       •   Radiological field measurements and instrumentation to support sample collection
       •   DCGL for each radionuclide of interest
       •   MQOs for each radionuclide (e.g., required method uncertainty, required Minimum
           Detectable Concentration (MDC))
       •   Analytical or screening methods that will be used in the field and laboratory to assay samples
       •   Analytical bias and precision (e.g., quantitative or qualitative)
       •   Number of samples to be collected
       •   Type and frequency of field QC samples to be collected
       •   Amount of material to be collected for each sample
       •   Sample tracking requirements
       •   Sample preservation, filtration, and shipping requirements
       •   Additional standard operating procedures (SOPs) to be followed or developed
       •   Cost of the methods being used (cost per analysis as well as total cost)
       •   Where possible, the use of surrogate measurements should be considered to expedite the field
           sampling activities and reduce analytical costs.
       •   Site-specific background (from background reference areas) for the radionuclide(s) of interest
       •   Turnaround time required for sample results to maintain project schedules
       •   Analytical measurement documentation requirements

       For projects that encompass several sub-sites or involve a long-term effort, it may be beneficial to
       generate a comprehensive SCP that includes addendums to cover all aspects of sampling and
       analytical requirements.  These addendums to the SCP must clearly identify the DQOs that are
       specific to a given  sub-site(s), applicable matrices, site-specific sampling and analysis
       requirements, and any deviations from the comprehensive SCP.  Information addressed in the
       comprehensive SCP may be referenced in the SCP addendums. When this approach is used, all
       addendum references to the comprehensive SCP must be verified by the project technical
       planning team during the document review process.  Preparatory phase inspections (field audits)
       must ensure that all appropriate plans (comprehensive and addendum SCPs) are available on site,
       and that field personnel are familiar with procedures included in both.

       A separate  SCP may be developed for the final status survey. Final status surveys are performed
       after cleanup is complete to demonstrate that residual radioactivity levels satisfy criteria for site
       disposition. These surveys provide data to demonstrate that radiological parameters do not
       exceed the  established DCGLs and that DQOs have been met. Final status survey SCPs are
       designed based on  these objectives and the known or anticipated radiological conditions at the
       site. The SCP must include an appropriate number and location of measurement and sampling
       points to demonstrate compliance with the release criterion. Planning for a final status survey
       SCP should include early discussions with the appropriate agencies concerning logistics for
       confirmatory surveys and sampling.  Confirmatory activities are usually limited in scope to
       include checking conditions at selected locations, comparing findings with those of the final
       status survey, and performing independent statistical evaluations of the data developed from the
       final status survey. An independent verification survey may be performed to provide data to
       substantiate results of the final status survey.  Independent evaluations of final site conditions are
       more extensive than the confirmatory activity listed above, and involve validation of the cleanup
       final status survey  procedures, results, and documentation. The independent verification survey is
       not a replacement or supplement to the final status survey, but it serves to validate the final status
       survey prior to releasing the effected lands/facilities for public use.
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4.1    Review of Successful Sampling Plans
       When preparing an SCP, the design should match the needs of a given project with the resources
       available. Project needs generally consist of the cleanup objectives and tolerable limits of
       uncertainty. Project resources may include personnel, time, and equipment. The goal of the SCP
       should be to acquire and use all of the information available so that the data collected meet the
       needs of the data user (i.e., decision maker).

       The following is a list of some site-specific sampling plans that have been used successfully in
       support of site disposition. These sampling plans range from complex site characterization plans
       to smaller sub-site project plans.

       •   Rocky Flats Environmental Technology Site, The D&D Characterization Protocol, MAN-
           007-DDCP, July 2002, can be downloaded at:
           http://rockyflats.apps.em.doe.gov/references/027-D&D%20Char%20Protocol-Reduced.pdf

       •   NASA Plum Brook Reactor Facility, Characterization Plan, MW-PL-02-004, September
           2002, can be downloaded at:  http://www.lerc.nasa. gov/WWW/pbrf/documents-
           records/char_plan/characterization_plan MW-PL-02-004.pdf

       •   105+ Basin Sediment Disposition Phase Two Sampling and Analysis Plan - Bechtel Hanford,
           Inc., BHI-00984, Rev 0, March 1997, can be downloaded at:
           http://www.osti.gov/energycitations/servlets/purl/16071-NoYaFIn/webviewable/16071.pdf

4.2    Defining Radioanalytical Laboratory Requirements for SCP Sample Analysis
       Early consideration of analytical capability is essential to the success of the SCP. Prior to
       defining radioanalytical laboratory requirements, SCP designers should review the Multi-Agency
       Radiological Laboratory Analytical Protocols Manual, NUREG-1576; EPA 402-B-04-001A;
       July 2004 (MARLAP), Volume 1, Chapters 5 and 7, for a detailed discussion on obtaining
       laboratory services.  The methods listed in SAM should be reviewed to aid  in discussions with the
       laboratory.  The radioanalytical laboratory(s) that will perform the analyses should be selected
       early in the planning process, so that they may be consulted regarding the analytical methods to
       be used and to ensure sampling activities will address the analytical needs.  Designers and
       planners should focus on choosing a laboratory that is a member of the Environmental Response
       Laboratory Network (ERLN).  Designers must  select the methods that will be used to analyze
       samples, and design the SCP to meet the analytical needs of those methods.

       SCP designers should also consider the use of mobile laboratories to provide on-site analytical
       capability and minimize off-site sample transportation.  The SCP must identify:

       •   ERLN member laboratories
       •   Communications protocols between the project management, field personnel, and laboratory
           personnel
       •   Chain-of-custody requirements
       •   Numbers of samples each the laboratory(s) are expect to receive
       •   Project requirements for analytical  result turnaround times
       •   SAM approved analytical procedures that the laboratory will follow
       •   Corrective action processes for suspect analytical data
       •   Documentation, reporting, and project deliverables requirements

       Procurement of laboratory services usually requires a SOW describing the analytical services
       needed. Careful preparation of the SOW is essential to ensuring the laboratory performs the

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                                                     Section 4.0 - Phase II - SCP Design and Development


       required services in a technically competent and timely manner (consult MARLAP, Volume 1,
       Chapters 5 and 7, for expanded details).  SOWs must be reviewed by personnel familiar with
       radioanalytical laboratory operations. For complicated sites requiring a large number of analyses,
       it is recommended that a portion of this evaluation take the form of an audit. For smaller sites or
       facilities, the decision maker(s) may decide that a review of the laboratory's qualifications is
       sufficient.  There are eight criteria that should be reviewed during this evaluation:

       1.  The laboratory should possess appropriate well-documented procedures, instrumentation, and
           trained personnel to perform the analyses required to address the DQOs (e.g., radionuclide(s)
           of interest and target detection limits).
       2.  The laboratory should be experienced in performing the same or similar analyses.
       3.  The laboratory should have satisfactory performance evaluation results from formal
           monitoring or accreditation programs, and should be able to provide a summary of QA audits
           and proof of participation in inter-laboratory cross-check programs. Equipment calibrations
           should be performed using National Institute of Standards and Technology (NIST) traceable
           reference radionuclide standards whenever possible.
       4.  The laboratory should have adequate capacity to perform all analyses within the desired
           timeframe to meet project required turnaround times.
       5.  The laboratory possesses a radioactive materials handling license or permit for the samples to
           be analyzed. SCPs for large projects may indicate that more than one  analytical laboratory is
           necessary to meet the SCP objectives.
       6.  The laboratory should provide an internal quality control review of all generated data. The
           reviewers must be independent of the data generators.
       7.  The laboratory should have an active and fully documented QA program in place, and the QA
           program comply with the project DQOs.
       8.  The laboratory should have adequate protocols for method performance documentation and
           sample security.

4.3    Classify Areas by Contamination Potential
       After a radiological homeland security event, areas of the event site will have differing potential
       for contamination and, accordingly, will not need the same level of sampling to demonstrate
       compliance with established cleanup goals.  The sampling process will be  more efficient if the
       SCP is designed so that areas with higher potential for contamination (based in part on results of
       the Phase I assessment) receive a higher degree of sampling.

       Site classification is a critical step in designing the SCP. The working hypothesis of MARSSIM
       is that all impacted areas that are being evaluated for release have a reasonable potential for
       radioactive contamination above the DCGL.  This initial assumption means that all areas are
       initially considered to be Class 1 areas2 unless some basis for reclassification as non-impacted,
       Class 3, or Class 2 is provided.

       Areas that have no reasonable potential for residual  contamination may not need any  level of
       sampling, and may be designated as non-impacted areas. These areas have no radiological impact
       from the homeland security event and are typically identified during Phase I. Background
       reference areas are normally selected from these non-impacted areas.

4.4    Select Background Reference Areas
       The SCP should clearly identify background reference areas. Typically, these are non-impacted
       areas, and should have physical, chemical, geological, radiological, and biological characteristics
  As defined by MARSSIM
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                                                    Section 4.0 - Phase II - SCP Design and Development


       that are similar to the site being evaluated. In some situations, a reference area may be associated
       with the survey unit being evaluated, but cannot be contaminated by the homeland security event.
       Generally, reference areas should not be part of the survey unit being evaluated.  (See MARSSIM
       Chapter 4.)

4.5    Identify Survey Units
       Each survey unit is a physical area consisting of structures or land areas of specified size and
       shape for which a separate decision will be made as to whether or not that area exceeds the
       release criterion. This decision is made as a result of the final status survey, and the survey unit is
       the primary entity for demonstrating compliance with the release criterion. The SCP must clearly
       define each survey unit in the site. (See MARSSIM  Chapter 4.)

       To facilitate sample collection design and ensure that the numbers of sampling points for a
       specific site are relatively uniformly distributed among areas of similar contamination potential,
       the site  is divided into survey units that share a common history or other characteristics, or are
       naturally distinguishable from other portions of the site. A survey unit should not include  areas
       that have different contamination classifications; however, depending on the size of the survey
       units, it may be advantageous to combine dissimilar  areas  into one survey unit to conform  to dose
       models  and minimize sampling densities.  (See NUREG-1505  Chapter 12.)

4.6    Develop a Conceptual Cleanup Model of the  Site for SCP Planning
       A site model serves as the basis for defining sample  collection needs during development of the
       SCP to support site cleanup goals. Project planners should gather and analyze available
       information to develop a conceptual site model that shows locations of known contamination,
       areas of suspected contamination, types and concentrations of radionuclides in impacted areas,
       potentially contaminated media, and locations of potential reference (background) areas. The
       diagram should include the general  layout of the affected area including schools, public parks,
       business centers, transportation infrastructure, water treatment facilities, lakes, streams, drainage
       and sewer systems, buildings, and roads.

4.7    Selection of Sampling Designs
       The main goal in the development of the SCP is to collect samples that are representative of the
       site conditions. An accurate assessment of contamination can minimize the number of samples
       required to achieve cleanup DQOs.  Using the conceptual cleanup model, crucial pathways and
       media requiring assessment are identified for possible sampling. Sampling strategies can be
       grouped into either statistical or non-statistical methods. To ensure that samples are as
       representative as possible, statistics are often used to design an appropriate sampling strategy and
       to provide a sound basis for supporting project decisions.  In selecting the sampling design for the
       project, use an environmental statistician is recommended to ensure the sampling design provides
       the data needed to support project decisions.

       EPA's Guidance on Choosing a Sampling Design for Environmental Data Collection for Use in
       Developing a Quality Assurance Project Plan (EPA  QA/G-5S, EPA/240/R-02/005) is a tool-box
       of statistical designs for sample collection that can be consulted during development of the SCP.
       An SCP may contain some or all of the designs. However, it is important that the design(s)
       selected meet the objectives of the QAPP and can support the DQOs and DCGLs of the project.
       Sample collection designs can be based on, but not limited to:

       Judgmental or Bias Sampling - In judgmental or bias sampling, selection of sampling units
       (i.e., the amount and location and/or timing of sample collection) is based on knowledge of the

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                                                    Section 4.0 - Phase II - SCP Design and Development
       feature or condition under investigation and on professional judgment. This type of sampling,
       based on professional judgment, differs from statistical scientific theory probability-based
       sampling. Therefore, conclusions are limited and depend entirely on the validity and accuracy of
       professional judgment. Expert judgment may also be used in conjunction with other sampling
       designs to produce effective sampling for defensible decisions.

       Simple Random Sampling - In simple random sampling, particular sampling units (e.g.,
       locations and/or times) are selected using random numbers, and all possible selections of a given
       number of units are equally likely. For example, a simple random sample of a set of drums can
       be taken by numbering all the drums and randomly selecting numbers or by sampling an area
       using pairs of random coordinates. This method is easy to understand, and the equations  for
       determining sample population size are relatively straightforward. Simple random sampling is
       most useful when the population of interest is homogeneous (e.g., no major patterns of
       contamination or hot spots are expected). Advantages of this design include:

       -   Provides statistically unbiased estimates of the mean, proportions, and variability
       -   Relatively easy to understand and implement
       -   Sample size calculations and data analysis are straightforward

       An example is shown in Figure 4.2.

                                           Figure 4.2
                                   Simple Random Sampling
                             (from EPA QA/G-5S, EPA/240/R-02/005)
       Stratified Sampling - In stratified sampling, the target population is separated into non-
       overlapping strata, or subpopulations that are known or thought to be more homogeneous
       (relative to the environmental medium or the contaminant), so that there tends to be less variation
       among sampling units. Strata may be chosen on the basis of spatial or temporal proximity, or on
       the basis of preexisting information or professional judgment. This design is useful when the
       target population is heterogeneous and the area can be subdivided based on expected
       contamination levels. Advantages of this sampling design are that it has potential for achieving
       greater precision in estimates of the mean and variance, and that it allows computation of reliable
       estimates for population subgroups of special interest. Greater precision can be obtained if the
       measurement of interest is strongly correlated with the variable used to make the strata.  An
       example is shown in Figure 4.3.
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                                                     Section 4.0 - Phase II - SCP Design and Development
                                           Figure 4.3
                                       Stratified Sampling
                             (from EPA QA/G-5S, EPA/240/R-02/005)
                                                                Radius = 500 m
                                                                       Direction of
                                                                        Prevailing
                                                                          Wind
       Systematic and Grid Sampling - In systematic and grid sampling, samples are taken at
       regularly spaced intervals over space or time.  An initial location and/or time is chosen at random.
       The remaining sampling locations are defined so that all locations are at regular intervals over an
       area (grid) or time (systematic). Examples of systematic grids include square, rectangular,
       triangular, or radial.  In random systematic sampling, an initial sampling location (or time) is
       chosen at random and the remaining sampling sites are specified so that they are located
       according to a regular pattern (e.g., at the points identified by the intersection of each line in one
       of the grids). Systematic and grid sampling is used to search for hot spots and to infer means,
       percentiles, or other parameters. It is also useful for estimating spatial patterns or trends over
       time. This design provides a practical and easy method for designating sample locations and
       ensures uniform coverage of a site, unit, or process. An example is shown in Figure 4.4.
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                                                     Section 4.0 - Phase II - SCP Design and Development
                                           Figure 4.4
                                   Systematic/Grid Sampling
                             (from EPA QA/G-5S, EPA/240/R-02/005)
                 Systematic Grid Sampling - Square Grid     Systematic Grid Sampling - Triangular Grids
       Ranked Set Sampling - In ranked set sampling, m sets (each of size r) of field locations are
       identified using simple random selection. The locations are ranked independently within each set
       using professional judgment or inexpensive, fast, or surrogate measurements. One sampling unit
       from each set is selected (based on the observed ranks) for subsequent measurement using a more
       accurate and reliable (hence, more expensive) method for the contaminant of interest.  Relative to
       simple random sampling, this design results in more representative samples and so leads to more
       precise estimates of the population parameters.

       Ranked set sampling is useful when the cost of locating and ranking locations in the field is low
       compared to laboratory measurements.  It is also appropriate when an inexpensive auxiliary
       variable  (based on expert knowledge or measurement) is available to rank population units with
       respect to the variable of interest.  To use this design effectively, it is important that the ranking
       method and analytical method are strongly correlated.

       Adaptive Cluster Sampling - In adaptive cluster sampling, initial measurements are made of
       randomly selected primary sampling units using simple random sampling. Whenever a sampling
       unit is found to show a characteristic of interest, additional sampling units adjacent to the original
       unit are selected and measurements are made. Several  additional rounds of sampling and analysis
       may be needed.  Adaptive cluster sampling also tracks  selection probabilities for later phases of
       sampling so that an unbiased estimate of the population mean can be calculated.  An example
       application of adaptive cluster sampling is delineating the borders of a plume of contamination.  It
       is useful for estimating or searching for rare characteristics in  a population, and is appropriate for
       inexpensive, rapid measurements. It enables delineating the boundaries of hot spots, while also
       using all data collected with appropriate weighting to give unbiased estimates of the population
       mean. An example is shown in Figure 4.5.
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                                                    Section 4.0 - Phase II - SCP Design and Development
                                           Figure 4.5
                                   Adaptive Cluster Sampling
                             (from EPA QA/G-5S, EPA/240/R-02/005)
          Population Gricl vvith Sh,>:!^':i Areas of
          Intermit cincl Initial Simple Random Su
       Fio.il Acbptiv* Cluster Sampling Results
       X = Sampling unit
       Composite Sampling - In composite sampling, volumes of material from several selected
       sampling units are physically combined and mixed to form a single homogeneous sample.
       Compositing can be very cost effective because it reduces the number of radiochemical analyses
       needed. It is most cost effective when analytical  costs are large relative to sampling costs; it
       demands,  however, that there are no safety hazards or potential biases (e.g., increased radiological
       dose rates or radioanalyte cross contamination) associated with the compositing process.
       Compositing is often used in conjunction with other sampling designs when the goal is to
       estimate the population mean and when information on spatial or temporal variability is not
       needed. It can also be used to estimate the prevalence of a rare trait. An example is shown in
       Figure 4.6.
                                          Figure 4.6
                                      Composite Sampling
                             (from EPA QA/G-5S, EPA/240/R-02/005)
                                  O          0
                                        Aliquots to be anal* zed
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                                                   Section 4.0 - Phase II - SCP Design and Development
       Table 4-1 provides a comparison of advantages and disadvantages for each of the sampling
       designs listed above.

                           Table 4-1 Comparison of Sampling Designs
Sampling Design

Judgmental or Bias
Sampling




Simple Random
Sampling



Stratified Sampling



Systematic and Grid
Sampling








Ranked Set Sampling





Adaptive Cluster
Sampling





Composite Sampling


Statistical or Non-
Statistical

Non-Statistical




Statistical



Statistical



Statistical








Statistical





Statistical





Statistical


Application
An individual subjectively
selects sampling
locations that appear to
be representative of
average conditions.


Representative sampling
locations are chosen
using the theory of
random chance
probabilities.


Site is divided into several
sampling areas (strata)
based on background or
site survey information;
each stratum is evaluated
using a separate random
sampling strategy.


Most common statistical
strategy; involves
collecting samples at
predetermined, regular
intervals within a grid
pattern.



In ranked set sampling,
sets of field locations are
identified using simple
random sampling. The
locations are ranked
independently within each
set using professional
judgment or inexpensive,
fast, or surrogate
measurements.

Sampling designs in
which the procedure for
selecting sites or units to
be included in the sample
may depend upon values
of the variable of interest
observed during the
survey.

A composite sample is
made from a number of
discrete samples which
from a body of material
and combined into a
single sample with the
intention that this single
sample is representative
of the components of that
body of material.
Advantage

Good for
homogeneous, well-
defined sites


Good for sites where
background
information is not
available and no
visible signs of
contamination are
present.

Good for large sites
characterized by a
number of soil types,
topographic features,
past/present uses, or
manufacturing/storage
areas.
Best strategy for
minimizing bias and
providing complete
site coverage. Can be
used effectively at
sites where no
background
information exists.
Ensures that samples
will not be taken too
close together.

More efficient than
simple random
sampling. Ranked set
sampling is useful
when the cost of
locating and ranking
locations in the field is
low compared to
laboratory
measurements.

Takes advantage of
population
characteristics so as
to obtain more precise
population values for a
given sample size.




Analytical cost
savings.


Disadvantage
Not usually recommended.
Conclusions are limited and
depend entirely on the validity
and accuracy of professional
judgment.


May not be cost-effective for
samples located too close
together. Does not take into
account spatial variability of
media.


Often more cost-effective than
random sampling. More
difficult to implement in the
field and analyze results. Does
not take into account spatial
variability of media.



Does not take into account
spatial variability of media.








Does not take into account
spatial variability of media.





Coefficients of variation for the
adaptive sampling may be
rather large compared to other
designs.



Limitations include aspects of
false negatives or positives
and loss of information
regarding any relationships
between radionuclides in
individual samples.


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                                                   Section 4.0 - Phase II - SCP Design and Development
       Listed below are several commercially available software tools that can be used to aid designers
       in the development of SCPs.
       NOTE: Mention of company names, trade names, or commercial products in this document does
       not constitute endorsement or recommendation for use.
       •   COMPASS software was designed to facilitate the use of MARSSIM and to guide the user
           into making informed decisions in designing final status surveys. COMPASS also simplifies
           the application of statistical tests by performing the calculations and providing prospective
           power curves that help determine what level of confidence the user is willing to accept for a
           particular number of measurements or samples in a survey unit. After performing the final
           status survey, COMPASS assesses the data for comparison to the cleanup goals.  COMPASS
           is available for download at http://orise.orau.gov/ieav/survey-projects/marssim.htmtfcompass

       •   COMPLY is a computerized screening tool for evaluating radiation exposure from
           atmospheric releases of radionuclides.  The tool may be used for demonstrating compliance
           with some EPA and Nuclear Regulatory Commission regulations. COMPLY is available for
           download at http://www.epa.gov/radiation/assessment/comply.html

       •   Cumulative Probability Plot can be used to plot empirical data on cumulative probability
           distribution graphs. The software computes parametric statistics and a "test statistic" based
           on "sampling by variables."  It is useful for visual presentation of characterization and final
           status surveys. Cumulative Probability Plot is available for download at
           http://www.radprocalculator.com/Probabilitv.aspx

       •   Elipgrid-PC Hot Spot Probability Calculations is used for design and analysis of sampling
           grids for locating elliptical targets (e.g., contamination hot spots).  It computes the probability
           of success in locating targets based on the assumed size, shape, and orientation of the targets,
           and on the specified grid spacing.  It can also be used to compute a grid spacing from a
           specified success probability, compute cost information associated with specified sampling
           grids, determine the size of the smallest hot spot detected given a particular grid, and create
           graphs of the results. ELIPGRID-PC is available for download at
           http://dqo.pnl.gov/software/elipgrid.htm

       •   GENII-NESHAPS provides a set of software for calculating  radiation dose and risk from
           radionuclides released to the environment.  The GENII-NESHAPS Edition is specifically
           designed to help site managers plan and improve compliance with 40 CFR 61, subparts H and
           I. GENII-NESHAPS is available for download at
           http://www.epa.gov/radiation/assessment/genii.html

       •   MARSSIMPower2000 implements the final status survey designs described in the
           MARSSIM manual.  MARSSIMPower2000 is available for download at
           http://cvg.homestead.com/marssimpower2000.html

       •   RESRAD is a DOE-developed code used for calculation of dose from all pathways from
           radioactively contaminated sites.  Developed by Argonne National Laboratory, RESRAD
           codes are available for download at http://web.ead.anl.gov/resrad/home2/

       •   Spatial Analysis and Decision Assistance (SADA) is University of Tennessee developed
           and incorporates tools from environmental assessment fields.  These tools include integrated

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                                                     Section 4.0 - Phase II - SCP Design and Development


           modules for visualization, geospatial analysis, statistical analysis, human health risk
           assessment, ecological risk assessment, cost/benefit analysis, sampling design, and decision
           analysis. SAD A is available for download at http: //www .tiem .utk. edu/~sada/index. shtml

       •   Visual Sample Plan provides statistical solutions to sampling design (how many samples to
           take and where to take them) and provides mathematical and statistical algorithms.  Visual
           Sample Plan is available for download at http: //dqo .pnl. gov/vsp/

4.8    Writing the SCP -  Content of  Major Elements
       When all of the appropriate site information is gathered, the SCP designers take the information
       and assemble the SCP.  Appendix  A provides a checklist of elements that may be used as a
       template for writing a site-specific SCP.  The specific elements that would be appropriate to
       include in an SCP will depend on  site conditions (e.g., the extent and type of the contamination,
       site size, project needs, and DQOs).

    4.8.1   Project Background
               With the information gathered during Phase I, including response information turned
               over by FRMAC, the SCP should provide both a site history, including descriptions of
               the use of the site, permits,  and the use of chemicals and radioisotopes and radiological
               event information.  The historical and response data from any investigation and event
               sampling efforts should be identified and summarized. An assessment of the quality of
               the data should be included, as well as a discussion of any problems encountered during
               initial site assessment and event response.  The SCP should include a description and a
               map of the location, size, and important physical features of the affected area, such as
               schools, public parks, business centers, transportation infrastructure, water treatment
               facilities, lakes, streams,  drainage and sewer systems, buildings, and roads.

               This section of the SCP should also describe the initial investigation radiological issues
               and the project's planned approach toward resolution.

    4.8.2   Project Organization and Responsibilities
               This element of the SCP  identifies key field personnel or organizations responsible for
               each field activity during the clean up and remediation.  A chart showing project
               organization and lines of authority  should be included. The chart should identify QC
               management organizations  and identify their appropriate independent reporting chain
               outside project management.  This  section of the SCP should describe the
               responsibilities of all project field personnel, including subcontractor roles and their key
               points of contact, sampling personnel, and liaison personnel between field, laboratory,
               and QC managers.

               This section of the SCP should also identify organizations responsible for:

               •   Project planning
               •   Project coordination
               •    Sample collection
               •   Disposal of sampling waste
               •    Sample custody

               This section should also identify any special training requirements and/or personnel
               certifications necessary to perform the project work.


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    4.8.3   Project Scope and Objectives
               The SCP must describe specific project objectives of the sampling effort.  It should
               identify the planned project activities, QA procedures to be implemented to support
               project activities, relevant regulatory standards, and the project schedule.  The intended
               use of data should be stated and should satisfy the intended uses of the data for meeting
               identified regulatory requirements and project specific clean up criteria. An outline
               should be included of the project schedule to include project plan review periods,
               fieldwork, sample analysis, data management and validation, and project report writing.

    4.8.4   Non-Measurement Data Acquisition
               The SCP should describe data needed from non-measurement sources, such as
               databases, literature, handbooks, and local authorities. Information of this type may be
               needed to support assessment of:

               •   Data supporting modeling activities
               •   Public transportation infrastructure
               •   Street and highway uses
               •   Land uses (residential, recreational, agriculture, etc.)
               •   Meteorological data
               •   Hydrogeological data (local or regional aquifers)
               •   Geological data (site bedrock formations, soil series)
               •   Well surveys
               •   Local relevant or significant habitats
               •   Endangered species

    4.8.5   Field Activities - Project Sample Collection Procedures
               The SCP should provide detailed site-specific instructions and requirements that are to
               be used in conjunction with the sample collection procedures described in EPA's Sample
               Collection Procedures for Radiochemical Analytes in Environmental Matrices
               (EPA/600/S-07/001, December 2006). The design team should refer to these sample
               collection procedures for detailed information on how the samples required under the
               SCP are to be collected. The SCP must provide details to describe the field activities to
               be performed, including but not limited to, information regarding:

               •   Sampling and field data-gathering procedures and methods to be used to collect
                   environmental matrix specific field measurements and samples for:
                   -  Soil and sediment
                   -  Aqueous and liquid-phase
                   -  Ground water/drinking water
                   -  Air
                   -  Surfaces
                   -  Building materials
               •   Collection of geophysical data
               •   Drilling or borings
               •   Installation of ground water monitoring wells
               •   Sample sizes required, for each matrix, to meet DQOs and MQOs
               •   Number of samples to be collected for each sampling location
               •   Sample container types and sizes
               •   QC requirements (e.g., field control QC samples)
               •   Specific sample collection equipment to be used

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                                                    Section 4.0 - Phase II - SCP Design and Development
                •   Considerations for sample filtration in the field (if required)
                •   Sample preservation requirements
                •   In situ field measurements (if any)

    4.8.6   Radiological Field Measurements and Instrumentation
                Many site cleanup projects will include on-site screening for detection and/or
                measurement of contamination.  This screening can assist with project planning and
                reduce the burden of sample collection and analyses.  Site RSP requirements for the
                sampling efforts to be performed should be identified, along with the support function
                interface between the RPG and the sample collection personnel. A listing of site-
                specific matrices, the expected radionuclides present in the matrices, and the appropriate
                instrumentation and measurement techniques to be used for each matrix should be
                detailed.

    4.8.7   Field Operations Documentation
                The SCP should identify requirements regarding the records that will be used to
                document all field operations, and should also identify the records and schedule for
                those which require periodic submittal.  The  SCP also should include proposed
                documentation forms. Corrections to documentation entries must be defined in the SCP
                according to the requirements of the QAPP and corrective action procedures. Field
                operations documents may include but are not limited to:

                •   Daily QC reports
                •   Field logbooks
                •   Field work forms
                •   Boring logs
                •   Well installation and development forms
                •   Photographic records
                •   Field analytical records

                This section should also address the sample documentation records, such as:

                •   Sample numbering system
                •   Sample labels and tags
                •   Field sampling logs
                •   Chain-of-custody forms and custody seals
                •   Lab notification documentation forms

                Sample custody requirements should be defined for:

                •   Field sample collection
                •   Sample transfer to the laboratory(s)
                •   Laboratory custody control

                The SCP should also define project records custody requirements for originals of field
                documentation and laboratory reports. It should define records management practices
                for but not limited to:

                •   SOPs
                •   SOP review documentation and record retention requirements

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                                                    Section 4.0 - Phase II - SCP Design and Development
               •   Corrective action reports
               •   Shipment manifesting and bills of lading
               •   Waste profile forms
               •   Test logs
               •   Drum logs, etc.

    4.8.8   Sample Packaging  and Shipping Requirements
               The SCP should  include a discussion of sample packaging and shipping requirements in
               accordance with  appropriate federal and state regulations (e.g., Department of
               Transportation [DOT] regulations found at 49 CFR 171-178; International Air
               Transportation Association [IATA] regulations). It should identify:

               •   Appropriate  laboratory(s)
               •   Laboratory(s) addresses and points  of contact
               •   Sample submittal schedule
               •   Mode of sample transportation (e.g., overnight courier)
               •   Manifesting  requirements for the shipment.

               It is recommended that the receiving laboratories also document the condition of field
               samples upon receipt at the laboratory.  This enables verification of correct sample
               volumes, sample preservation, chain-of-custody completeness and accuracy, and overall
               packaging techniques.

               Sample packaging and shipping procedures described in Module I, Section 7.0, of
               EPA's Sample Collection Procedures for Radiochemical Analytes in Environmental
               Matrices (EPA/600/S-07/001, December 2006) should also be reviewed before
               completing this section  of the SCP.

    4.8.9   Sampling Waste
               The SCP should  describe procedures that will be used for collecting, labeling, storing,
               and disposing of the sampling waste. The SCP should detail procedures for assessing
               corresponding sample results or sampling the waste to determine whether it is
               hazardous. The SCP should address how the sample results will be evaluated to
               determine disposal options for the sampling waste. Disposal actions must be conducted
               with the concurrence of appropriate project technical personnel and management.

    4.8.10 Project Quality Assurance (QA)
               The SCP must include QA/QC elements that are consistent with the QAPP and are
               applied throughout the project to ensure proper execution of the SCP and  appropriate
               data generation.  The project assessment activities should be discussed as  they pertain to
               the QA objectives identified in the QAPP.  In general, the SCP should provide
               specifications for QA activities by defining in detail:

               •   Project schedules
               •   Proper technical review/approval of project documents
               •   Radiochemical DQOs and MQOs identified in the QAPP, and their respective data
                   quality indicators
               •   QA/QC protocols necessary to achieve the DQOs and MQOs
               •   Analytical methods and measurements
               •   Evaluation of laboratories

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                                                    Section 4.0 - Phase II - SCP Design and Development
                •   QA samples and sample handling procedures/verification
                •   QA sample analysis
                •   Use of single- and double-blind performance evaluation (PE) samples
                •   Equipment calibration and maintenance documentation
                •   SCP QA implementation protocols
                •   Establishing key field personnel experience requirements
                •   Level of decision making empowered to key field personnel
                •   Communication protocols between the field and project stakeholders
                •   Data assessment procedures for the evaluation and the identification of any data
                   limitations, including data review, validation, and reporting
                •   Generation of required quality reports
                •   Sampling requirements to support the final status survey

                EPA or EPA contract audit personnel should conduct a variety of audits (field,
                laboratory, office) to identify procedures that could cause problems with sampling and
                analytical results. The audits  should be scheduled as early as possible, and should cover
                project activities from initial investigation to post closure monitoring to include but not
                be limited to:

                •   Sample collection from all media (i.e., air, ground water, surface water, soil,
                   sediment, and waste)
                •   Placement of sampling devices
                •   Decontamination of equipment or activities that could cause cross-contamination
                •   Post sample collection activities (packaging/shipping)
                •   Laboratory activities
                •   Data reporting,  including  electronic media
                •   Chain-of-custody procedures and documentation
                •   Field logs
                •   Well installation and development (if deemed necessary based on the event)

    4.8.11  Non-Conformance/Corrective Actions
                The SCP must address notification and corrective actions that should be followed by
                field and laboratory personnel if there are deviations from the SCP or problems with
                samples upon receipt at the laboratory. Typical problems or deviations include, but are
                not limited to:

                •   Improperly preserved samples
                •   Improper chain-of-custody documentation
                •   Broken sample  containers or questionable sample integrity
                •   Sample relocation
                •   Insufficient sample amount

                Corrective action procedures must address:

                •   Corrective actions required if field and/or analytical procedures are found to deviate
                   from the requirements in the SCP
                •   Re-sampling with additional analysis of new samples
                •   Reanalysis of existing field or QC samples
                •   Proper data qualification
                •   Corrective action protocols necessary in the event of deficiency or failure

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                                                   Section 4.0 - Phase II - SCP Design and Development
               •   Notification processes
               •   Contingencies

               The SCP must state that significant changes to or deviations from the approved SCP will
               not be made without the written approval of EPA project management.

    4.8.12 SCP Appendices
               The SCP appendices should include, but not limited to, the following items:

               •   References
               •   List of abbreviations and acronyms
               •   Standard project forms to be used
                   -  Chain-of-custody forms
                   -  Sample labels
                   -  Shipping manifest
                   -  Audit forms
                   -  Non-conformance reporting forms
                   -  QA report forms
               •   Summary tables
                   -  Data quality objectives summary
                   -  Site cleanup objectives
                   -  Proposed monitoring well information
                   -  Sample container preservation and holding time requirements
                   -  Names and addresses of owners of property near the site
                   -  Sample container types and quantities
                   -  Summary of sample matrices and locations
                   -  Summary of number of samples and analyses
                   -  Listing of approved analytical laboratories and contact information
               •   List of figures
                   -  Project organization
                   -  Sampling schedule
                   -  Proposed on-site and off-site sampling locations
                   -  Proposed monitoring well locations and construction

4.9    SCP Review and Approval
       The SCP should be reviewed to determine whether it will provide data that satisfy regulatory
       requirements, data use needs and DQOs, and whether it is compatible with all site constraints. As
       a guide, reviewers should use a checklist that contains general  information that typically should
       be included in an SCP. Review checklists can be prepared by  reviewing Appendix A and
       identifying project specific variations.
       NOTE: Due to the complexity that each site-specific SCP may require, a detailed checklist is
       beyond the scope of this document.
       Once an SCP has been approved, appropriate personnel sign the signature page.  Personnel
       signing the SCP are determined on a project-specific basis. It is recommended that the incident
       commander/project manager sign the title page of the SCP, and that the technical manager sign
       the title page of the associated QAPP.  Deviations from the approved SCP must receive written
       approval.  In addition, there may be significant changes in the project that necessitate appending
       or modifying the SCP. Similar procedures of review and approval for those modified sections are
       necessary prior to execution of the modifications.

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                                                     Section 4.0 - Phase II - SCP Design and Development
4.10    SCP Distribution
        Once approved, the final SCP and/or its approved modifications must be distributed to all
        appropriate parties, including project and technical managers, primary and QA laboratory(s),
        appropriate regulatory authorities, stake holders, and subcontractors (i.e., drilling or sampling
        firms, data validation firms, etc.).
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                                                              Section 5.0 - Phase III - SCP Implementation
5.0   Phase III - SCP Implementation
        An approved SCP must be in place before implementing the SCP activities. Figure 5.1 outlines
        the SCP implementation elements.

                                               Figure 5.1
                            Phase III - SCP Implementation
               From Phase II
          SCP Design and Development
                       Yes
                                            Incident Commanders &
                                              Project: Managers
   Contractors
                                          Analytical Laboratories
                                                                      Sample Analysis
                                               SCP Compliance Monitoring
                                           Project, Field, and Laboratory Audits
                                            Field & Laboratory QC Samples
                                              Data Review & Validation
                                                 Records Review
                                            Quality Assurance & Data Reports
                                              Non-Con formance Reports
                                              Corrective Actions Reports
                                                                                   Project Liaison
                                            Project Sampling and Analysis
                                             Sample Collection & Radiological
                                                   Surveys
                                                            Sampling Progress Reports
                                                            Sample Shipment Reports
                                                               Waste Reports
5.1     Personnel Training
        Prior to implementation of the SCP, project personnel must be adequately trained for their
        specific duties and possess a full understanding of all aspects of the SCP. Training must include
        safety and health requirements and practices as defined in the HASP and RSP.

5.2     Field Sample Collection
        Prior to performing sample collection, sampling personnel should ensure that proper field
        equipment is available and in good condition, and sample collection and handling procedures
        (including sample preservation) are performed in accordance with the SCP and following
        specifications provided in EPA's Sample Collection Procedures for Radiochemical Analytes in
        Environmental Matrices, EPA/600/S-07/001, December 2006).

5.3     Project Liaison
        A liaison between project management, field, and laboratory personnel should be identified to
        ensure smooth transition of all samples from the field to the laboratory or laboratories. Liaison
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                                                           Section 5.0 - Phase III - SCP Implementation


       duties also may include implementation of proper sample documentation, packaging, and
       shipping procedures.

5.4    SCP Compliance Monitoring
       Before data collection activities are implemented, an approved SCP must be in place and
       execution must be performed in compliance with the approved SCP.  There are several QA
       elements that may be applied to the project to ensure proper SCP compliance. These include, but
       are not limited to:

       •   Field and laboratory audits
       •   Field and laboratory quality control samples
       •   Equipment calibration and maintenance documentation
       •   QA sample handling verification
       •   QA sample analysis using of single- and double-blind performance evaluation samples
       •   Data review and/or data validation
       •   Electronic media audits
       •   Generation of QA reports and data quality assessment reports

    5.4.1   Project, Field, and Laboratory Audits
                During implementation of the SCP, field activity audits should be performed for any
                phase of field work, from initial investigation and data collection, to post closure
                monitoring. Field audits should be scheduled as early in the activity as possible to
                identify procedures that could cause problems with the sampling and analytical results.
                This oversight is necessary to ensure that approved procedures, as specified in the SCP,
                are used. Field audits include monitoring critical activities such as well installation and
                development (if deemed necessary based on the event), placement of other sampling
                devices (e.g., composite), decontamination of equipment or activities that could cause
                cross-contamination, sample collection from all media (i.e., air, ground water, surface
                water, soil, sediment, and waste), and post sample collection activities (packaging/
                shipping).  Laboratory audits must also be performed to ensure that procedures for
                proper communication, proper documentation, and awareness of project DQOs are in
                place and that these procedures are in compliance with the analytical SOW.

    5.4.2   Project Activity Reports
                While data collection activities are being performed, the sampling team should
                communicate daily with appropriate project personnel regarding project status by
                submitting at least, but not limited to, the following:

                •  Field sampling progress  reports in relationship to project schedules including field
                   work forms, boring logs, well installation and development forms, photographic
                   records, field analytical records
                •  Sample shipment reports
                •  Waste accumulation reports
                •  Other project required field reports

                Project quality assurance monitoring of data collection activities must include all of the
                applicable QA/QC requirements identified  in the SCP and the QA group  should
                communicate daily with appropriate project personnel regarding project status by
                submitting at least, but not limited to, the following:
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                                                           Section 5.0 - Phase III - SCP Implementation
                •   Field and laboratory DQO and MQO evaluation reports
                •   QA samples and sample handling procedures/verification reports
                •   QA sample analysis reports
                •   Non-conformance reports
                •   Corrective action reports

5.5    Site Disposition
       For most sites, following review of data results generated during one or more surveys, a
       disposition decision is based on a demonstration of compliance with site cleanup goals. When
       survey results are used to support a decision, the decision maker(s) needs to ensure that the data
       will support that decision with satisfactory confidence. Actions must be taken to manage the
       uncertainty in the survey results, so that sound, defensible decisions may be made. These actions
       include design and implementation of proper survey and sampling plans to control known causes
       of uncertainty, proper application of QC procedures to detect and control significant sources of
       error, and careful  analysis of uncertainty before the data are used to support decision making.

       If the decision maker(s) determine that the cleanup goals have not been met to satisfy the site
       QAPP due to a sample collection issue, then the SCP will be re-optimized through reevaluation
       and redesigned. Additional sampling and analysis may be required to satisfy compliance
       demonstration and site disposition.
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                                                                Section 6.0 - Additional Resources
6.0  Additional Resources
     In addition to the information provided in this document, the following documents are
     recommended as resources for generating an SCP that clearly identifies project goals, associated
     data needs, and application of QA elements based upon the QAPP project goals designed to reach
     site release:


       •  Multi-Agency Radiological Laboratory Analytical Protocols Manual, NUREG-1576; EPA
          402-B-04-001A; July 2004 (MARLAP)
       •  Multi-Agency Radiation Survey and Site Investigation Manual, NUREG-1575, Rev. 1; EPA
          402-R-97-016, Rev. 1; DOE/EH-0624, Rev. 1; August 2000 (MARSSIM)
       •  Guidance for Developing Quality Systems for Environmental Programs, EPA QA/G-1,
          EPA/240/R-02/008, November 2002
       •  Guidance  on Assessing Quality Systems, EPA QA/G-3, EPA/240/R-03/002, March 2003
       •  Guidance  on  Systemic Planning Using the Data Quality Objectives Process, EPA QA/G-4,
          EPA/240/B-06/001, February 2006
       •  Guidance for Quality Assurance Project Plans, EPA QA/G-5, EPA/240/R-02/009, December
          2002
       •  Guidance  on Choosing a Sampling Design for Environmental Data Collection for Use in
          Developing a Quality Assurance Project Plan, EPA QA/G-5 S, EPA/240/R-02/005,
          December 2002
       •  Guidance  on Technical Audits and Related Assessments for Environmental Data Operations,
          EPA QA/G-7, EPA/600/R-99/080, January 2000
       •  Guidance  on Environmental Data Verification and Data Validation, EPA QA/G-8,
          EPA/240/R-02/004, November 2002
       •  Sample Collection Procedures for Radiochemical Analytes in Environmental Matrices,
          EPA/600/S-07/001, December 2006
       •  EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, EPA/240/B-01/003,
          March 2001
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                                                                        Section 7.0 - References
7.0  References


       U.S. Army Corps of Engineers, Requirements for the Preparation of Sampling and Analysis
       Plans, EM 200-1-3, February 2001.


       U.S. Department of Energy, Decommissioning Handbook (DOE/EM-0383), January 2000.

       U.S. Department of Energy, Statistical and Cost-Benefit Enhancements for the DQO Process for
       Characterization Decisions (DOE/EM-0316), September 12, 1996.


       U.S. Department of Homeland Security, Federal Emergency Management Agency, Planning
       Guidance for Protection and Recovery Following Radiological Dispersal Device (ROD) and
       Improvised Nuclear Device (IND) Incidents, FRDoc E8-17645, Federal Register: (Volume 73,
       Number 149) [Page 45029-45048], August 1, 2008.


       U.S. Environmental Protection Agency, Guidance for Developing Quality Systems for
       Environmental Programs, EPA QA/G-1, EPA/240/R-02/008, November 2002.


       U.S. Environmental Protection Agency, Guidance on Assessing Quality Systems, EPA QA/G-3,
       EPA/240/R-03/002, March 2003.


       U.S. Environmental Protection Agency, Guidance on Systemic Planning Using the Data Quality
       Objectives Process, EPA QA/G-4, EPA/240/B-06/001, February 2006.

       U.S. Environmental Protection Agency, Guidance for Quality Assurance Project Plans, EPA
       QA/G-5, EPA/240/R-02/009, December 2002.

       U.S. Environmental Protection Agency, Guidance on Choosing a Sampling Design for
       Environmental Data Collection for Use in Developing a Quality Assurance Project Plan, EPA
       QA/G-5S, EPA/240/R-02/005, December 2002.


       U.S. Environmental Protection Agency, Guidance on Technical Audits and Related Assessments
       for Environmental Data Operations, EPA QA/G-7, EPA/600/R-99/080, January 2000.

       U.S. Environmental Protection Agency, Guidance on Environmental Data Verification and Data
       Validation, EPA QA/G-8, EPA/240/R-02/004, November 2002.

       U.S. Environmental Protection Agency, Data Quality Assessment: A Reviewers Guide, EPA
       QA/G-9R, EPA/240/B-06/002, February 2006.

       U.S. Environmental Protection Agency, Data Quality Assessment: Statistical Methods for
       Practitioners, EPA QA/G-9S, EPA/240/B-06/003, February 2006.

       U.S. Environmental Protection Agency, Guidance on Quality Assurance for Environmental

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                                                                         Section 7.0 - References
       Technology Design, Construction, and Operation, EPA QA/G-11, EPA/240/B-05/001, January
       2005.

       U.S. Environmental Protection Agency, EPA Requirements for Quality Assurance Project Plans,
       EPA QA/R-5, EPA/240/B-01/003, March 2001.

       U.S. Environmental Protection Agency, Sample Collection Procedures for Radiochemical
       Analytes in Environmental Matrices, EPA/600/S-07/001, December 2006.

       U.S. Nuclear Regulatory Commission, A Nonparametric Statistical Methodology for the Design
       and Analysis of Final Status Decommissioning Surveys, NUREG-1505, June 1998.


       U.S. Nuclear Regulatory Commission, Multi-Agency Radiation Survey and Site Investigation
       Manual, NUREG-1575, Rev. 1; EPA 402-R-97-016, Rev. 1; DOE/EH-0624, Rev. 1; August
       2000.

       U.S. Nuclear Regulatory Commission, Multi-Agency Radiation Survey and Assessment of
       Materials and Equipment (Draft Report for Comment), NUREG-1575, Supp. 1; EPA 402-R-06-
       002; DOE/EH-707, December 2006.

       U.S. Nuclear Regulatory Commission, Multi-Agency Radiological Laboratory Analytical
       Protocols Manual, NUREG-1576 EPA 402-B-04-001A, July 2004.

       U.S. Nuclear Regulatory Commission, Manual for Conducting Radiological Surveys in Support
       of License Termination (NUREG/CR-5849), Draft Report for Comment, June 1992.
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                                                                                 Appendix A
                                      Appendix A
                       Sample Collection Plan Design Elements
                               and Development Checklist

     Title Page
     Approval Page
     Table of Contents

    1.0   Proj ect Background
         1.1 Site History and Contaminants
         1.2 Summary of Site Data Prior to Homeland Security Event
         1.3 Site-Specific Definition of Problems (including a description of homeland security event)
         1.4 FRMAC Event Response Data

    2.0   Project Organization and Responsibilities

    3.0   Project Scope and Objectives
         3.1 Task Description
         3.2 Applicable Regulations/Standards/Risk Based Cleanup Goals
         3.3 Project Schedule

    4.0   Nonmeasurement Data Acquisition

    5.0   Field Activities

         5.1 Ground Water
            5.1.1 Rationale/Design
                  5.1.1.1 Monitoring Well Location and Installation (if deemed necessary based on the
                  event)
                    . 1.2 Sample Collection and Field and Laboratory Analysis
                    .1.3 Upgradient, QA/QC, and Blank Samples and Frequency
            5.1.2 Monitoring Well Installation (if deemed necessary based on the event)
                 5. .2.1 Drilling Methods and Equipment
                 5. .2.2 Materials
                 5. .2.3 Installation
                 5. .2.4 Documentation
                 5. .2.5 Well Decommission/Abandonment
                 5. .2.6 Water Level Measurement
            5.1.3 Aquifer Testing
            5.1.4 Field Measurement Procedures and Criteria
            5.1.5 Sampling Methods for Ground Water - General
            5.1.6 Sample Handling Methods for Ground Water - Filtration
            5.1.7 Sample Containers and Preservation Techniques
            5.1.8 Field Quality Control Sampling Procedures
            5.1.9 Decontamination Procedures

         5.2 Subsurface Soil
            5.2.1 Rationale/Design
                 5.2.1.1 Soil and Rock Boring Locations
                 5.2.1.2 Discrete/Composite Soil Sampling Requirement

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                                                                                     Appendix A


                  5.2.1.3 Sample Collection and Field and Laboratory Analysis
                  5.2.1.4 Background, QA/QC, and Blank Samples and Frequency

             5.2.2 Field Procedures
                  5.2.2.1 Drilling Methods
                  5.2.2.2 Boring Logs
                  5.2.2.3 Field Measurement Procedures and Criteria
                  5.2.2.4 Sampling for Radiochemical Analyses
                  5.2.2.5 Sample Containers and Preservation Techniques
                  5.2.2.6 Field Quality Control Sampling Procedures
                  5.2.2.7 Decontamination Procedures

         5.3 Surface Soil and Sediment
             5.3.1 Rationale/Design
                  5.3.1.1 Surface  Soil Sample Locations
                  5.3.1.2 Sediment Sample Locations from On-site and/or Off-site Drainage Channels
                  5.3.1.3 Sediment Sample Locations from Ponds, Lakes, and Lagoons
                  5.3.1.4 Discrete/Composite Soil and/or Sediment Sampling Requirements
                  5.3.1.5 Sample Collection and Field and Laboratory Analysis
                  5.3.1.6 Upgradient, QA/QC, and Blank Samples and Frequency
             5.3.2 Field Procedures
                  5.3.2.1 Sampling Methods for Surface Soil/Dry Sediment
                  5.3.2.2 Sampling Methods for Underwater Sediments from Ponds, Lakes, and
                         Lagoons
                  5.3.2.3 Field Measurement Procedures and Criteria
                  5.3.2.5 Sampling for Radiochemical Analyses
                  5.3.2.6 Sample Containers and Preservation Techniques
                  5.3.2.7 Field QC Sampling Procedures
                  5.3.2.8 Decontamination Procedures

         5.4 Surface Water
             5.4.1 Rationale/Design
                  5.4.1.1 Surface Water Sample Locations
                  5.4.1.2 Sample Collection and Field and Laboratory Analysis
                  5.4.1.3 Upgradient, QA/QC, and Blank Samples and Frequency
             5.4.2 Field Procedures
                  5.4.2.1 Sampling Methods for Surface Water - General
                  5.4.2.2 Sample Handling Methods for Surface Water - Filtration
                  5.4.2.3 Field Measurement Procedures and Criteria
                  5.4.2 A Sample Containers and Preservation Techniques
                  5.4.2.5 Field Quality Control Sampling Procedures
                  5.4.2.6 Decontamination Procedures

         5.5 Other Matrices

             5.5.1 Rationale/Design
                  5.5.1.1 Sample Locations
                  5.5.1.2 Discrete/Composite Sampling Requirements
                  5.5.1.3 Sample Collection and Field and Laboratory Analysis
                  5.5.1.4 Background/Upgradient, QA/QC, and Blank Samples and Frequency

             5.5.2 Field Procedures

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                                                                                    Appendix A
                  5.5.2.1 Sampling Methods
                  5.5.2.2 Field Measurement Procedures and Criteria
                  5.5.2.3 Sample Containers and Preservation Techniques
                  5.5.2.4 Field Quality Control Sampling Procedures
                  5.5.2.5 Decontamination Procedures

    6.0   Radiological Field Measurements and Instrumentation to Support Sample Collection

    7.0   Field Operations Documentation
         7.1 Daily Quality Control Reports (QCR)
         7.2 Field Logbook and/or Sample Field Sheets
         7.3 Photographic Records
         7.4 Sample Documentation
            7.4.1 Sample Numbering System
            7.4.2 Sample Labels and/or Tags
            7.4.3 Chain-of-Custody Records
         7.5 Field Analytical Records
         7.6 Documentation Procedures/Data Management and Retention

    8.0   Sample Packaging and Shipping Requirements

    9.0   Sampling Wastes

    10.0  Project Quality Assurance

    11.0  Non-Conformance/Corrective Actions
    Appendices
    References
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