United States
Environmental Protection
Agency
Office of Radiation and Indoor Air
National Air and Radiation
Environmental Laboratory
EPA 402-R-10-002
June 2010
www.epa.gov/narel
Guide for Laboratories -
Identification, Preparation, and
Implementation of Core
Operations for Radiological
or Nuclear Incident Response
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EPA 402-R-10-002
www.epa.gov
June 2010
Revision 0
Guide for Laboratories Identification,
Preparation, and Implementation of Core
Operations for Radiological or Nuclear
Incident Response
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Radiation and Indoor Air
National Air and Radiation Environmental Laboratory
Montgomery, AL 36115
Recycled/Recyclable
FrmM 'Mft soy/tanoia hk on paper
eonlains at ioaM 50"i recycled fibt-r
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
This report was prepared for the National Air and Radiation Environmental Laboratory of the Office of
Radiation and Indoor Air, United States Environmental Protection Agency. It was prepared by
Environmental Management Support, Inc., of Silver Spring, Maryland, under contracts 68-W-03-038, work
assignment 35, and EP-07-037, work assignments B-33 and 1-33, all managed by David Carman.
Mention of trade names or specific applications does not imply endorsement or acceptance by EPA.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
PREFACE
The need to ensure an adequate laboratory infrastructure to support response and recovery
actions following a major radiological or nuclear incident has been recognized by a number of
federal agencies. The Integrated Consortium of Laboratory Networks (ICLN), created in 2005 by
10 federal agencies,1 consists of existing and emerging laboratory networks across the Federal
Government. ICLN is designed to provide a national infrastructure with a coordinated and opera-
tional system of laboratory networks that will provide timely, high quality, and interpretable
results for early detection and effective consequence management of acts of terrorism and other
events requiring an integrated laboratory response. It also designates responsible federal agencies
(RFAs) to provide laboratory support across response phases for chemical, biological, and
radiological agents. To meet its RFA responsibilities, EPA established the Environmental
Response Laboratory Network (ERLN) to address chemical, biological, and radiological threats
during nationally significant incidents (www.epa.gov/erln/). EPA is the RFA for monitoring,
surveillance, and remediation of radiological agents. EPA will share responsibility for overall
incident response with the U.S. Department of Energy (DOE).
This document is one of several initiatives by EPA's Office of Radiation and Indoor Air
designed to provide guidance to radioanalytical laboratories that will support EPA's response
and recovery actions following a radiological or nuclear incident. This guide examines those core
operations of federal, state, and commercial radioanalytical laboratories that will be challenged
when responding to a radiological incident. Suddenly, a laboratory will be faced with large
numbers of radioactive samples collected following a radiological or nuclear incident, such as or
a radiological dispersal device (RDD) ("dirty bomb") or the detonation of an improvised nuclear
device (IND). These samples will be contaminated with varying levels of radionuclides, and will
represent multiple matrices (such as building materials and various types of air filters, as well as
more typical environmental matrices). Advance planning by national and regional response
teams, as well as by radiological laboratories, will be critical to ensure uninterrupted throughput
of large numbers of radioactive samples and the rapid turnaround of results that meet required
data quality objectives associated with the protection of human health and the environment.
EPA's responsibilities, as outlined in the National Response Framework Nuclear/Radiological
Incident Annex, include response and recovery actions to detect and identify radioactive
substances and to coordinate federal radiological monitoring and assessment activities.
Detailed guidance on recommended radioanalytical practices can be found in the Multi-Agency
Radiological Laboratory Analytical Protocols Manual (MARLAP), which provides detailed
radioanalytical guidance for project planners, managers, and radioanalytical personnel based on
project-specific requirements. MARLAP is available at www.epa.gov/radiation/marlap/index.
html. Familiarity with Chapters 2 and 3 of MARLAP will be of significant benefit to users of this
guide.
This document is one in a planned series designed to present radioanalytical laboratory person-
nel, Incident Commanders (and their designees), and other field response personnel with key
1 Departments of Agriculture, Commerce, Defense, Energy, Health and Human Services, Homeland Security,
Interior, Justice, and State, and the U.S. Environmental Protection Agency.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
laboratory operational considerations and likely radioanalytical requirements, decision paths, and
default data quality and measurement quality objectives for analysis of samples taken after a
radiological or nuclear incident, including incidents caused by a terrorist attack. Documents
currently completed or in preparation include:
Radiological Laboratory Sample Analysis Guide for Incidents of National Significance -
Radionuclides in Water (EPA 402-R-07-007, January 2008)
Radiological Laboratory Sample Analysis Guide for Incidents of National Significance -
Radionuclides in Air (EPA 402-R-09-007, June 2009)
Radiological Laboratory Sample Screening Analysis Guide for Incidents of National
Significance (EPA 402-R-09-008, June 2009)
Method Validation Guide for Qualifying Methods Used by Radiological Laboratories
Participating in Incident Response Activities (EPA 402-R-09-006, June 2009)
Guide for Laboratories Identification, Preparation, and Implementation of Core
Operations for Radiological or Nuclear Incident Response (EPA 402-R-10-002, June 2010)
A Performance-Based Approach to the Use of Swipe Samples in Response to a Radiological
or Nuclear Incident (in preparation)
Guide for Radiological Laboratories for the Control of Radioactive Contamination and
Radiation Exposure (in preparation)
Radiological Laboratory Sample Analysis Guide for Radiological or Nuclear Incidents -
Radionuclides in Soil (in preparation)
Comments on this document, or suggestions for future editions, should be addressed to:
Dr. John Griggs
U.S. Environmental Protection Agency
Office of Radiation and Indoor Air
National Air and Radiation Environmental Laboratory
540 South Morris Avenue
Montgomery, AL 36115-2601
(334) 270-3450
Griggs.John@epa.gov
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
ACKNOWLEDGMENTS
This guide was developed by the National Air and Radiation Environmental Laboratory
(NAREL) of EPA's Office of Radiation and Indoor Air (ORIA). Dr. John Griggs was the project
lead for this document. Several individuals provided valuable support and input to this document
throughout its development. We wish to acknowledge the external peer reviews conducted by
Mr. Sherrod Maxwell, Dr. Daniel Montgomery, Dr. J. Stanley Morton and Dr. Shiyamalie
Ruberu, whose thoughtful comments contributed greatly to the understanding and quality of the
document. Several excerpts from the Washington State Department of Health Incident Response
Plan are included in the appendices, for which we thank Dr. Elaine Rhodes, Director of
Environmental Laboratory Sciences, and his staff. Numerous other individuals both inside and
outside of EPA provided peer review of this document, and their suggestions contributed greatly
to the quality and consistency of the final document. Technical support was provided by Dr. N.
Jay Bassin, Dr. Anna Berne, Mr. David Burns, Dr. Carl V. Gogolak, Dr. Robert Litman, Dr.
David E. McCurdy, and Mr. Robert Shannon of Environmental Management Support, Inc.
in
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Table of Contents
Preface i
Acknowledgments iii
Acronyms, Abbreviations, Units, and Symbols vi
Radiometric and General Unit Conversions viii
1. Introduction 1
2. Development of the Laboratory Incident Response Plan 3
2.1 Introduction 3
2.2 Template for Creating a Laboratory Incident Response Plan 3
2.2.1 General Considerations 4
2.2.2 Staffing and Job Descriptions 4
2.2.3 Development of a Quality Assurance Project Plan 5
2.2.4 Incident Response Sample Handling 5
2.2.5 Incident Response Sample Processing 6
2.2.6 Changes to the Laboratory Radiation Controls Program and Implementation
Strategies 8
2.2.7 Enhancements to the Laboratory Quality System 9
2.2.8 Assessing and Managing Resources 9
2.2.9 Appendices 10
2.3 Additional Comments on Creating the Laboratory Incident Response Plan 10
3. Enhancements to the Radiological Controls Program for Incident Response 12
3.1 Introduction 12
3.2 Radioactive Materials License Issues 13
3.3 Selecting the Type of Processing Configuration for the Laboratory 13
4. Changes to the Laboratory Quality System 16
4.1 Introduction 16
4.2 The Laboratory Quality Manual 17
4.3 The Quality Assurance Project Plan for Incident Response 17
4.3.1 Incident Response Training 18
4.3.2 Review of Chain-of-Custody Information 19
4.3.3 Expedited Corrective Action Procedures 19
4.3.4 Method Validation Requirements 19
4.3.5 Proficiency Testing Programs 20
4.3.6 Availability of a Reliable Source of the Target Radionuclide 20
4.4 Data Quality Objectives, Analytical Action Levels, Measurement Quality Objectives, and
Analytical Decision Levels 20
4.4.1 Data Quality Objectives 20
4.4.2 Analytical Action Levels 21
4.4.3 Measurement Quality Objectives 21
4.4.4 Analytical Decision Levels 22
4.5 Quality Control 23
4.5.1 Incident-Specific Acceptance Criteria 23
4.5.2 Sample-Related Quality Control 23
IV
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
4.5.3 Instrument-Related Quality Control 26
4.5.4 Tracking and Trending Quality Control Charts 26
5. Identifying Needs and Optimizing Resources for Incident Response 28
5.1 Introduction 28
5.2 Documenting Capabilities and Estimating Capacity for Incident Response at the
Laboratory 28
5.3 Increasing Laboratory Capacity Without Adding Instrumentation 29
5.4 Adding (Non-Radioanalytical) Equipment During Incident Response 30
5.5 Supplies 31
5.6 Major Radioanalytical Instrumentation 32
5.6.1 Alpha Spectrometers 32
5.6.2 High-Purity Germanium Gamma Spectrometers 35
5.6.3 Low-Background Gas Flow Proportional Counters 36
5.6.4 Liquid Scintillation Counters 37
5.7 Managing Supplies for Incident Response 38
5.8 Reagents, Resins, Carriers, and Standards for Incident Response 39
6. Miscellaneous Laboratory Incident Response Preparation Issues 40
7. References 42
Appendix A: Excerpts From an Actual Laboratory Incident Response Plan 44
Al.Initial Laboratory Preparation 44
Example Al.l Sample Receiving Station 44
Example A1.2 Sample Preparation Room 45
A2.Contamination Control Oversight 46
A.2.1 Survey Team 46
A.2.2 Area Wipe Sampling -A Procedure 47
A3. Supplies and Equipment Checklists 48
A4. Incident Response Procedures 49
Appendix B: Laboratory Capacity-Limiting Factor Analysis 52
Tables
Table 1 - Typical Examples of Major and Minor Non-Radioanalytical Equipment 30
Table 2 - Availability of Radioanalytical Instrumentation Following a Nuclear or Radiological
Incident 33
Table Bl -Example Laboratory Factor Analysis 53
v
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
ACRONYMS, ABBREVIATIONS, UNITS, AND SYMBOLS
(Excluding chemical symbols and formulas)
a alpha particle
a probability of a Type I decision error
AAL analytical action level
ADC analog-digital converter
ADL analytical decision level
AIM acquisition interface module
P beta particle
ft probability of a Type II decision error
Bq becquerel (1 dps)
CFR Code of Federal Regulations
Ci curie
CoC chain-of-custody
d day
DL discrimination limit
DOE United States Department of Energy
DOT United States Department of Transportation
dpm disintegration per minute
dps disintegration per second
DQO data quality objective
EDD electronic data deliverable
EPA United States Environmental Protection Agency
ERC Emergency Response Center
ERLN Environmental Response Laboratory Network
y gamma ray
g gram
GC/MS gas chromatograph/mass spectrometer
GM Geiger-Muller detector
GPC gas-proportional counting/counter
Gy gray
h hour
HPGe high-purity germanium [detector]
HVAC heating, ventilation, air conditioning [system]
ICLN Integrated Consortium of Laboratory Networks
ICP/AES inductively coupled plasma/atomic emission spectroscopy
IND improvised nuclear device (i.e., a nuclear bomb)
IRP Incident Response Plan
ISO International Organization for Standardization
k coverage factor
L liter
LCS laboratory control sample
LSC liquid scintillation counting/counter
jiCi microcurie (1CT6 Ci)
m meter
VI
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
MAPEP Mixed Analyte Performance Evaluation Program
MARLAP Multi-Agency Radiological Laboratory Analytical Protocols Manual
MCA multichannel analyzer
MCB multichannel buffer
mg milligram (1CT3 g)
min minute
MQO measurement quality obj ective
MS matrix spike
Nal(Tl) thallium-activated sodium iodide detector
nCi nanocurie (1CT9 Ci)
NELAC National Environmental Laboratory Accreditation Conference
NIM nuclear instrument module
NRC United States Nuclear Regulatory Commission
PAG protective action guide
pCi picocurie (1CT12 Ci)
PHA pulse-height analyzer
PIPSฎ passivated implanted planar silicon [detector]
PT proficiency testing
QA quality assurance
QC quality control
QAPP Quality Assurance Proj ect Plan
rad radiation absorbed dose
RCA Radiological Control Area
RCRA Resource Conservation and Recovery Act
ROD radiological dispersal device (i.e., "dirty bomb")
rem roentgen equivalent: man
RFA responsible federal agency
RSO Radiation Safety Officer
s second
SOP standard operating procedure
Sv sievert
TAT turnaround time
TNI The NELAC Institute
TSCA Toxic Substances Control Act
MMR required method uncertainty
y year
vn
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
RADIOMETRIC AND GENERAL UNIT CONVERSIONS
To Convert
years (y)
disintegrations per
second (dps)
Bq
Bq/kg
Bq/m3
Bq/m3
microcuries per
milliliter ((iCi/mL)
disintegrations per
minute (dpm)
cubic feet (ft3)
gallons (gal)
gray (Gy)
roentgen equivalent
man (rem)
To
seconds (s)
minutes (min)
hours (h)
days (d)
becquerels (Bq)
picocuries (pCi)
pCi/g
pCi/L
Bq/L
pCi/L
(iCi
pCi
cubic meters (m3)
liters (L)
rad
sievert (Sv)
Multiply by
3.16xl07
5.26xl05
8.77xl03
3.65xl02
1
27.0
2.70xl(T2
2.70xlO~2
1(T3
109
4.50xlO~7
4.50X10"1
2.83 xl(T2
3.78
102
io-2
To Convert
s
min
h
d
Bq
pCi
pCi/g
pCi/L
Bq/L
pCi/L
pCi
(iCi
m3
L
rad
Sv
To
y
dps
Bq
Bq/kg
Bq/m3
Bq/m3
(iCi/mL
dpm
ft3
gal
Gy
rem
Multiply by
3.17xl(T8
1.90xl(T6
1.14x10^
2.74xl(T3
1
3.70xl(T2
37.0
37.0
IO3
io-9
2.22
2.22xl06
35.3
0.264
io-2
IO2
NOTE: Traditional units are used throughout this document instead of the International System of
Units (SI). Conversion to SI units will be aided by the unit conversions in this table.
Vlll
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
1. INTRODUCTION
In the event of a radiological or nuclear incident, radiological laboratories will be called upon to
perform analyses that will present significant challenges due to the large number of samples
across a wide variety of matrices, the radionuclides potentially present, requested turnaround
times, and, perhaps most of all, the range of activity levels present or expected. In order to
produce defensible data of appropriate quality and meet demands for significantly faster TATs
and higher throughput, a laboratory needs to be prepared to deal with issues that it may not face
under normal circumstances. The purpose of this guide is to provide an overview of core
operational considerations and the changes that should be considered so that a laboratory will be
better prepared to transition and adjust to incident- response conditions. It cannot be emphasized
enough that such planning is essential for proper and continued operations of the laboratory, for
the protection of human health and the environment, and to help ensure the production of data
that meet required data quality objectives (DQOs) and measurement quality objectives (MQOs)
applicable to an actual response.
Accepting samples taken during a radiological incident response2 will impact a laboratory in a
number of ways. The radiological and analytical effects of varied and elevated levels of
radioactivity associated with these samples have to be addressed. There is also the need for
greater flexibility in the quality assurance/quality control (QA/QC) process to assure that the data
produced are of appropriate quality. And last, but not least, there will be an increased demand for
materials and resources needed by the laboratory to function over a period of time.
The first step in preparing for a radiological or nuclear incident is to develop a Laboratory
Incident Response Plan. Chapter 2 of this guide introduces key elements of a Laboratory Incident
Response Plan by providing a template for such a plan. The template includes elements such as
staffing and additional training considerations; changes to sample handling and processing;
changes to the laboratory Radiation Controls Program, including the Radiation Protection
Program; enhancements to the laboratory's Quality System; and other changes that need to be
anticipated as a laboratory plans and prepares for a response. Chapters 3, 4, and 5 discuss parts of
the template in more detail. Appendix A provides excerpts from an actual Laboratory Incident
Response Plan that show how modifications to selected laboratory operations can be made.
Chapter 3 addresses some of the issues related to the potential increase in radioactivity and
radiation levels as a result of a surge in the number of samples received by a laboratory during an
incident response. The necessity for effective controls to manage radiological exposures and
radioanalytical contamination is brought into focus. This is done by suggesting enhancements to
the existing laboratory Radiation Protection Program designed to minimize the effects of
increased radioactivity and radiation levels on laboratory facilities, personnel, and data quality.
2 Throughout this guide, "incident response" includes the three phases as defined by EPA:
Early (or Emergency) Phase: The initial reaction to the emergency and can last for a few hours or up to a few
days.
Intermediate Phase: This phase initiates when the immediate emergency situation is under control and reliable
environmental measurements are available for use as the basis of additional protective actions. This phase may
overlap the other two phases and can last from weeks to months.
Late (or Recovery) Phase: This phase begins when recovery actions begin. Recovery actions are designed to
reduce radiation levels in the environment to levels acceptable for unrestricted use.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Efficient and safe use of available space is also addressed, by reviewing changes that a
laboratory might plan to make to the existing sample and work flow before accepting samples
from the incident to continue working safely and produce results quickly. A more detailed
discussion of measures that can be taken to minimize or prevent radiological and radioanalytical
contamination can be found in Guide for Radiological Laboratories for the Control of
Radioactive Contamination and Radiation Exposure (in preparation).
Chapter 4 offers guidance on how to determine the most important factors contributing to the
quality of data reported during incident response and what enhancements to the existing
laboratory Quality System might be advisable to assure that quality of data needed by the
Incident Commander (or the designee)3 is sufficient for the intended purpose. This analysis
focuses on the effects on the quality of data resulting from the increased volume and activity
concentration of the samples that will be received. The discussion in Chapter 4 highlights a range
of other practical and operational issues that must be addressed if the laboratory is to optimize
throughput and TATs for analyses and at the same time provide assurance that the data produced
are of sufficient quality to support the decisions of the response.
Chapter 5 offers guidance on how to evaluate productivity issues related to available and needed
resources. Developing a realistic estimate of the number of samples that can be processed in a
specific amount of time requires laboratories to carefully examine their work processes so that
they can identify limitations and barriers that may prevent them from successfully satisfying the
demands and expectations that will be placed upon them. Appendix B offers a simplified
example of how to evaluate a laboratory's capacity. The evaluation is meant to identify a
laboratory's capacity to analyze samples that could arrive tomorrow (or next week) without
much time to make significant changes to operations. It also is designed to identify areas where
relatively minor changes might be possible to increase a laboratory's capacity in a targeted area.
It should be noted that the example assumes that all of the sample workload results from
response to the incident. This simplifies the capacity evaluation, but laboratories should consider
what portion of their total capacity will actually need to be reserved for routine work.
Chapter 6 offers a list of additional concerns and issues that a laboratory might have to address
when planning for a response to a radiological or nuclear incident. This list should not be
considered all-inclusive or complete, but rather it should be viewed as a starting point in the
process of evaluating the impact on current laboratory practices and activities of accepting
samples during a radiological incident response.
3 Throughout this guide, the use of "Incident Commander" refers to the person or that person's designated
representative.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
2. DEVELOPMENT OF THE LABORATORY INCIDENT RESPONSE PLAN
2.1 Introduction
In the event of a radiological or nuclear incident, laboratories may receive and process
radioactive materials with a greater range of activities, including higher activity than is the case
during routine operations. Materials with varied and elevated activities may be encountered as
samples, standards and tracers required for analyses, sample test sources,4 quality control (QC)
samples, and waste produced during some analyses. It should also be expected that the number
of samples that need to be processed, analyzed, and stored may significantly exceed those during
routine operations, and a number of a laboratory's functions, processes, and programs may be
affected. Development of a Laboratory Incident Response Plan provides an opportunity for
examining those laboratory functions that will be impacted by a response to a radiological or
nuclear incident, and for considering solutions to the issues that are anticipated.
In this chapter, key elements of a Laboratory Incident Response Plan are introduced by providing
a template for such a plan. The template includes elements such as staffing and additional
training considerations; changes to sample handling and processing; changes to the laboratory
Radiation Controls Program, including the Radiation Protection Program; enhancements to the
laboratory's Quality System; and other changes that need to be anticipated as a laboratory plans
and prepares for a response to a radiological or nuclear incident. This template, discussed next,
can be used to identify the steps necessary for a laboratory to transition into the incident response
mode that supports the needs of the event in a quick, safe, and efficient manner.
2.2 Template for Creating a Laboratory Incident Response Plan
The process of creating a Laboratory Incident Response Plan focuses on examining a labora-
tory's current practices and procedures and identifying changes that will have to be implemented
when incident-response conditions are in effect. The template below is basically a list of factors
that most likely will be impacted by the increased flow of samples with potentially higher
activities of known/unknown radionuclides. This list is used to create a plan specific to the
laboratory, which addresses only those factors that will be changed when preparing for incident
response. For some of the factors listed, examples of typical considerations are included. In
addition, Appendix A includes examples taken from an actual Incident Response Plan, to
illustrate how one laboratory approached the level of detail in the plan that was required for its
successful implementation.
There are steps that a laboratory might implement before a response in order to ensure that
periodic task requirements do not interfere with the incident response efforts. Changing the
laboratory's Quality Manual to specify performance-based recalibration requirements in lieu of
schedule-driven (e.g., annual) requirements may minimize the risk that analytical operations will
be interrupted during an incident response for routine calibrations. There is often no regulatory
4 A "sample test source" is a sample, sample aliquant, or final product of a chemical or a physical process prepared
for the purpose of activity determination (ASTM D7282). It is also considered to be the final form in a geometry that
will be counted by a radiation detector.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
driver for schedule-driven requirements beyond those stated in the laboratory's Quality Manual -
a factor that is generally in control of the laboratory. Key quality standards, such as ANSI
N42.23, ASTM D7282, and the TNI Standard, do not require recalibration as long as long as QC
check control charts indicate acceptable performance. In those cases where there is an external
requirement for periodic recalibration, it might be useful to establish a staggered timeline for
recalibration of affected instruments so that only a portion of the total instruments of that type is
taken out of service at a time. This practice would have an added benefit during routine
operations of formalizing the schedule for periodic tasks, which may prevent unintended outages
due to unanticipated problems with materials or other logistical considerations.
2.2.1 General Considerations
This section describes those high-level administrative functions of the organization that would be
impacted by the laboratory's response to a radiological or nuclear incident, and identifies the
changes that would need to take place as the laboratory transitions from normal to incident
response conditions. It could address:
Discussion of chain-of-command during incident response;
Issues related to security and chain-of-custody; and
Overview of the operational phases of the response, such as notification, preparation,
shift scheduling, emergency work schedule, and return to normal operations.
2.2.2 Staffing and Job Descriptions
This section should identify the augmented or altered responsibilities appropriate to the incident
response as well as any job functions that may be temporarily suspended. It should be noted that
the incident response could extend over a period of months or even longer, and the planned
changes need to take that into account. For example, the consequences of suspending some
functions have to be evaluated and a time frame provided regarding how long such a suspension
can last before significantly impacting the laboratory. Any additional functions and responsibili-
ties also have to be evaluated in terms of their impact on working schedules so that work
proceeds at a sustainable pace and degradation of performance due to overwork, fatigue, or
induced stress is minimized. The elements considered in this section may include:
Additional job functions created because of incident response conditions (such as
incident response coordinator)
Additional job functions added to support tasks that must be performed with increased
frequency (e.g., frequency of radiological surveys)
Changes to job assignments based on sample prioritization and resulting changes to the
workload
Changes to analysts and supervisor schedules to cover all shifts, and temporarily relieve
them of any ancillary functions not related to the incident response
Identification of all job functions to ensure that staffing is adequate to cover them
Identification of areas where job overlap (one person wearing many hats) may leave
essential functions uncovered or without sufficient coverage to satisfy QC requirements
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
2.2.3 Development of a Quality Assurance Project Plan
The ongoing steps that a laboratory should take to ensure preparedness in the event of a
radiological or nuclear incident should be included in a Quality Assurance Project Plan (QAPP)5,
or other planning document, whose focus would be only those elements of the Laboratory
Quality Manual that are relevant to the incident response activities.
This QAPP should carefully define the anticipated quality requirements for incident-related
activities and should delineate whether each requirement is supplemental to, or in lieu of, the
requirements stated in the Laboratory Quality Manual. Because this QAPP is written in anticipa-
tion of a radiological or nuclear incident, it should be generic enough and flexible enough to be
easily and quickly adapted to conditions specific to the incident response. Other guides in this
series (see Preface) can be used as a source of default values for analytical action levels, required
method uncertainty, etc., appropriate to incident response and necessary for the development of a
QAPP. Additional discussion of the elements that should be considered in developing an incident
response QAPP can be found in Section 4.3.
2.2.4 Incident Response Sample Handling
Each stage of processing an incident response sample is described in terms of changes made to
the routine operations of the laboratory because of the nature of the sample. In each case,
preparation, lists of additional supplies and equipment, and changes to working conditions
should be considered. Concerns related to sample handling may include:
Sample Receipt and Tracking (Sample Control)
o Information that may be available prior to samples arriving at the laboratory
o Information that might be provided in advance of, or delivered along with, the sample
shipment, for example:
Radiation level based on field survey, color-coded to reflect processing priority, if
not stated differently by the Incident Commander
Results of any surveys of the sample container
Specifics regarding sample matrix, such as type, quantity, location, and date of
collection
Requested analyses
o Special requirements for chain-of-custody documentation
o Current sample login procedure adequate for accepting samples from unexpected
sources. For example, a laboratory routinely may be set up only for current clients,
and the computerized login procedures may not be adequate for an incident response
client.
o Plan in place for cataloging and storing samples for quick retrieval if needed for re-
analysis
Sample Screening (in preparation for sample prioritization)
o Equipment calibration - current and suitable for sample geometries to be received
o Established objectives for sample receipt and associated screening
5 Guidance on developing a Quality Assurance Project Plan can be found in EPA QA/G-5 (2002) and other quality
documents (www.epa.gov/qualitv/qa docs.htmT).
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Time per sample for screening so that projections for processing can be easily
estimated
Type of radiation screening to be performed and potential radiological/non-
radiological interferences that may be present
Additional documentation required for both the laboratory and the client
Defined measurement quality objectives (MQOs) for each screening analysis
Additional considerations for opening sample containers, storage of samples, and
disposal of waste transport containers
Protective packaging to be used for sample containers and samples after screening
Additional information regarding radiological incident response sample screening can be found
in Radiological Laboratory Sample Screening Analysis Guide for Incidents of National Signifi-
cance (EPA 2009c).
2.2.5 Incident Response Sample Processing
Depending on how a laboratory is set up to process routine samples, sample processing
procedures will also have to be examined and adapted to analyze samples with potentially varied
or increased levels of radioactivity. The issues that should be considered include:
Sample Prioritization
o Is there a process for sample prioritization?6
o How is the sample prioritization communicated to staff?
Temporary Storage and Shielding
o Location of the temporary storage and shielding for higher-activity samples
o Access control to the temporary storage locations
o Radiation monitoring of the temporary storage locations
Sample Preparation
o Location of preparation areas for incident response samples
o Alternate sample preparation procedures for higher-activity samples (e.g., use of
smaller aliquants, addition of tracers with higher-activity concentration)
o Additional contamination control measures applied to these samples
o Changes to the types and levels of appropriate QC samples included with each batch:
Laboratory control samples to reflect sample activity levels different from those
the laboratory handles routinely
Adjusting the level of the matrix spikes to prevent matrix spike failure due to high
sample activity vs. low spike level (see discussion in section 4.5.2)
Increasing the frequency of duplicates to reflect the complexity of subsampling
for samples such as urban matrices that can contain brick-, concrete-, or asphalt-
particulates.
Analytical Separations
6 If there is no other information available, a default sample prioritization scheme can be based on sample flow
process discussed in Radiological Laboratory Sample Analysis Guide for Incidents of National Significance -
Radionuclides in Water (EPA 2008) and Radiological Laboratory Sample Analysis Guide for Incidents of National
Significance - Radionuclides in Air (EPA 2009b).
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
o Has the laboratory implemented and validated rapid methods to be used in incident
response?
o Location of areas in the laboratory for performing analytical separations for samples
with potentially higher activity levels
o Additional requirements for screening sample test sources before submitting for
counting
Sample Test Source Counting
o Increased frequency of instrument background checks
o Action levels for sample test source activity that will trigger a special (nonscheduled)
instrument contamination check or background subtraction count
o Changes in counting times necessary to meet the MQOs, as the anticipated activity
levels change depending on the actual phase of the incident response. Counting times
might be reduced for samples with elevated activity, but may need to be increased for
samples with activities lower than routine, in order to meet the required MQOs (listed
here as an element to be considered, but it could be addressed in the relevant
analytical standard operating procedure for incident response).
Calculations and Recordkeeping
o Are the calculations performed in accordance with the incident response method?
o Do the reported values have the correct units?
o Has the laboratory provided the necessary documentation of sample chain-of-custody
within the laboratory?
o Are the analytical protocols consistent with the incident requirements?
o Are spreadsheets with appropriate calculations developed to facilitate sample
prioritization after sample screening is completed?
Data Review and Validation
o Defining responsibilities for additional data review, if required
o Establishing criteria/checklists to address incident response specific concerns such as
looking for interferences not normally encountered (concerns arising from having
high-activity levels in samples, presence of fresh fission products that are normally
not present in samples; e.g., 140Ba interfering with radiostrontium analysis or 210Po
interfering with determination of uranium isotopes via alpha spectrometry)
o Ensuring that sample preparation/splitting is correctly documented and that approp-
riate factors are applied in calculations
o Making sure that the data review requirements completed by the laboratory are as
expected
Results Reporting
o Non-routine reporting formats or units
o Boilerplate narratives in place
o Software in place to facilitate reporting
o Electronic data deliverable (EDD) production defined
o Expected turnaround times and were these turnaround times met
Feedback to and from the Incident Commander
o Means of communication with the Incident Commander and identification of person-
nel directly responsible for responding to or implementing any requests from the
Incident Commander
Waste Management
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
o What are the issues regarding waste generation and management that the laboratory
will face as a result of an increased influx of samples or when higher-activity samples
are processed? For example:
How will the laboratory address labeling and placement of additional waste
containers for radioactive materials?
Will it be necessary to have a radioactive waste storage area outside of the
building confines as a temporary storage area until shipment can be arranged?
How will the facility screen normal wastes to ensure that no contaminated
materials are inadvertently released?
Will the laboratory be prepared to dispose of waste that might contain other
regulated constituents (e.g., Resource Conservation and Recovery Act [RCRA] or
Toxic Substances Control Act [TSCA]) whose presence may result in creating
mixed wastes?
Is the laboratory prepared to address potential radiation exposure risks resulting
from elevated levels of radioactivity in wastes?
o How can these issues be addressed, and what specific provisions have been made by
the laboratory in advance of a radiological or nuclear incident?7
For additional information on analyzing samples received during an incident response, see
Radiological Laboratory Sample Analysis Guide for Incidents of National Significance
Radionuclides in Water (EPA 2008), Radiological Laboratory Sample Analysis Guide for
Incidents of National Significance Radionuclides in Air (EPA 2009b), and Method Validation
Guide for Qualifying Methods Used by Radioanalytical Laboratories Participating in Incident
Response Activities (EPA 2009a).
2.2.6 Changes to the Laboratory Radiation Controls Program and Implementation
Strategies
The presence of samples and other materials with potentially elevated levels of activity may
increase the risk of occupational radiation exposure, impact the quality of data by increasing
instrument backgrounds and the risk of cross-contamination among samples and instruments, and
become a potential source of contamination. The impact of these effects on laboratory operations
and personnel safety can be minimized by developing:
A new section of the laboratory's Radiological Controls Program documentation8 that
addresses issues of laboratory personnel exposed to increased radiation levels arising
from a sudden influx of higher-activity samples;
A program for minimizing radiological contamination (i.e., general contamination of the
laboratory at levels that pose radiological health and safety concerns); and
A program for minimizing, detecting, and controlling radioanalytical contamination in
the laboratory, i.e., uncontrolled spread of radioactivity that leads to sample cross-
7 See a more detailed discussion in Chapter 6.
8 This documentation may have many different names depending on the type of facility, such as "radiation safety
manual," "radiation protection plan," or "radiological controls plan." All of these encompass the hazards of working
with ionizing radiation and radioactive materials. This document uses the term "Radiological Controls Program."
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
contamination or otherwise negatively impacts radiochemical analysis, so that the data
produced are defensible and of appropriate quality.
The existing Radiological Controls Program is generally designed to address routine operations
of the laboratory. Changes chosen for increased protection of laboratory personnel and the public
as a result of the presence of higher-activity samples should be identified in this section of the
Laboratory Incident Response Plan. These changes will depend on the measures already in place,
the activity level that the laboratory is able to accept, and the number of additional samples that
the laboratory is able to process. A much more detailed discussion of the radiological and
radioanalytical controls that might be appropriate is found in the Guide for Radiological
Laboratories for the Control of Radioactive Contamination and Radiation Exposure (in
preparation). A few examples include:
Identify locations of step-off pads and frisking stations.
Identify areas of restricted access due to either dose or contamination.
Adjust receiving protocols to account for inspection and screening of sample shipments
as they arrive.
Manage amount of material in process and storage areas to minimize dose.
Use dosimetry by all personnel and publicly post the administrative dose limits.
Post the requirements for personal protective equipment.
Identify new areas inside the laboratory that will be surveyed and sampled for surface
contamination.
Add dose and contamination monitoring locations outside the laboratory.
Include procedures or references for facility and personnel decontamination.
2.2.7 Enhancements to the Laboratory Quality System
This section of the Laboratory Incident Response Plan should list and include a brief description
of all the incident response procedures and other related analytical procedures. It could also
become the area where the laboratory describes experiences with implementing these procedures
(i.e., lessons learned). Documenting these experiences may prevent repeating some mistakes, and
may serve as a starting point for future investigations or discussions of improvements. While the
actual narratives, notes, annotations, and comments need not be included in the Laboratory
Incident Response Plan, their location should be identified clearly for future reference. Another
element of this section might be a crosswalk comparing routine procedures with incident
response procedures to identify the critical differences between them. For example, the same
method may be used for sample preparation and chemical separation, and only the sample
counting time is changed; this would not require additional training of the analyst. Chapter 4
provides additional details.
2.2.8 Assessing and Managing Resources
Complete response to a major radiological or nuclear incident may last as long as a yearor
even longeras the initial efforts to assess the extent and the level of contamination will
transition to assessing the remediation and cleanup efforts. Accepting additional samples will
result in a significant strain on a laboratory's resources, and not anticipating and preventing
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
shortages of staff and of materials may result in a complete halt of analytical activities, thus
jeopardizing a successful recovery from a radiological or nuclear incident. This section of the
Laboratory Incident Response Plan might include the results of the initial assessment of the
laboratory's capability and capacity, with a list of options available to remedy the issues
identified in the assessments (an example of such an assessment is provided in Appendix B). For
example, a procedure might be implemented during incident response to monitor the level of
existing supplies more frequently so that shortages of critical materials are anticipated and
prevented. A list (including names, telephone numbers, etc.) of vendors that have agreed to stock
specific supplies and make them available preferentially could also be included here. Chapter 5
provides additional details.
2.2.9 Appendices
Supporting information should be included here. Examples include:
Floor plans indicating changes to be made under incident response conditions, such as
posting doorways for limited access to minimize movement of samples
Placement of additional thermoluminescence dosimeters in work areas to monitor
worker exposure
Examples of all additional forms to be used during incident response operation, such as
recording results of additional surveys
Tables of exposure limits, waste disposal limits, and acceptable levels of radioactivity
and radiation (specific to the laboratory)
List of contacts, including vendors, regulatory agencies, and laboratory management;
after-hours and emergency numbers should be listed as well, if available.
2.3 Additional Comments on Creating the Laboratory Incident Response Plan
Additional measures implemented during an incident response may require new or expanded
administrative, radiological protection, and radioanalytical procedures. These procedures should
be developed and tested. All staff responsible for the execution of these procedures should be
trained accordingly. If the laboratory needs to develop an approach to certain tasks (e.g., site-
specific changes to sample receipt to allow for additional screening and sample segregation, or
selection of the laboratory space for processing of high-level samples), it may be helpful to
involve appropriate staff, including corporate, government, or other stakeholders, as soon as
possible in the process.
A laboratory could begin by conducting a table-top exercise to review an existing procedure,
brainstorm proposed changes, and update, retest, and validate the procedure until it addresses the
specific concern. Once it appears that a good procedure has been developed, a drill may be
conducted to test a manageably small part of the procedure. For example, a drill could focus on
processes prior to sample arrival, including who has to be notified and how, who needs to be
waiting in the sample receipt area, what equipment will be required for screening, and who
documents pre-receipt information. An independent observer should be present to monitor the
progress of the drill and provide subsequent feedback. Because the same staff will be involved in
both the procedure development and its testing and implementation, their active involvement
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
assures management that the new, revised, or augmented procedures are appropriate to the task
and reflect the needs and operations of the laboratory.
As the process of developing laboratory-specific approaches to incident response continues,
testing small, individual components during drills should be followed by exercises that combine
several small components. This could be accomplished by conducting a simulated incident
response exercise that demonstrates how quickly staff members are able to reorganize the labora-
tory into low- and high-level activity zones, how well they know their roles and responsibilities,
and how quickly they can fully integrate into the incident response mode. Such comprehensive
simulated response exercises should be conducted periodically to provide feedback on the
adequacy of the existing procedures, level of staff preparedness, and identification of areas that
need improvement. These exercises involve everyone in developing improved procedures and
corrections to the existing plan.
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3. ENHANCEMENTS TO THE RADIOLOGICAL CONTROLS PROGRAM FOR
INCIDENT RESPONSE
3.1 Introduction
Every radiological laboratory with a radioactive materials license must implement a Radiation
Protection Program that controls and minimizes radiation exposure.9 The primary purpose of the
Radiation Protection Program is to protect laboratory personnel and the public from the effects of
radiation resulting from laboratory activities. This guide assumes that such a program is in place
and is designed to address issues related to the routine operations of the laboratory.
In the event of a significant radiological or nuclear incident, however, it is likely that many
radiological laboratories will be called upon to perform sample analyses in support of the various
response efforts taking place, and that the radioactivity concentrations in these samples may be
well in excess of those to which the laboratory is routinely accustomed. The numbers of samples
and the overall quantity of sample material are also likely to be significantly increased. In
addition, the increased radioactivity levels
in the standards and tracers required for
analysis, waste produced during analyses,
sample test sources, and quality control
(QC) samples all will contribute to the
increased radioactivity and radiation levels
in the laboratory.
Radiological and Radioanalytical Contamination:
This guide refers to both radiological and radioanalytical
contamination.
The general term radiological contamination refers to the
radioactive contamination of the laboratory facilities or
personnel. In some cases, radiological contamination may
occur at levels that pose a radiological health and safety
concern.
The term radioanalytical contamination refers to contam-
ination of the sample material, instrumentation, or labora-
tory facilities that leads to sample cross-contamination or
otherwise negatively impacts radiochemical analyses.
While the laboratory's surveillance and control measures
for personnel protection and for the prevention of radio-
analytical contamination may frequently overlap, the
goals are sufficiently different that they will be discussed
separately in this guide whenever the distinction becomes
important.
Elevated activities in the laboratory may
increase the risk of occupational radiation
exposure, may impact the quality of data by
increasing instrument backgrounds and the
possibility of cross-contamination among
samples, and may become a potential source
of laboratory and environmental contamina-
tion. The laboratory should make advance
preparations for receiving and handling the
samples in order to minimize radiation
exposure and radioactive contamination.
These advance preparations should be clearly outlined in the Radiation Protection Program and
in relevant standard operating procedures (SOPs). The advance preparations for a radiological or
nuclear incident should include an assessment of the configuration of the laboratory, the
resources available for the incident response, and the sample handling and contamination control
procedures to be implemented during the incident response. In addition, the laboratory staff
should be adequately trained to implement these measures efficiently and effectively during an
incident. These preparations, the Radiation Protection Program, the laboratory SOPs, and the
necessary training collectively comprise an effective Radiological Controls Program.
9 10 CFR 835.101(for DOE facilities) and 10 CFR 20.1101 (Subpart B and 10 CFR 20 Subparts C (1201-1208) and
D (1301 and 1302) or equivalent Agreement State regulations.
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An effective Radiation Controls Program should minimize the effects of increased radioactivity
and radiation levels on laboratory facilities, personnel, and data quality. This may be accomp-
lished through the development of procedures and practices to:
Control the radioactive materials being handled in the laboratory. This includes the
accurate assessment (screening) of the nature of the material and the establishment of
well defined and effective procedures for the physical handling of the material and the
movement of the material through the laboratory.
Actively monitor radiological and radioanalytical contamination and personnel exposure
and establish quantitative limits for surface contamination of laboratory benches and
work areas, as well as detectors.
Address the decontamination and shielding of the laboratory personnel, facilities, and
equipment when the established quantitative limits are exceeded.
As with all other aspects of the laboratory's incident response activities, a Radiation Controls
Program should anticipate the unique challenges associated with various incident scenarios and
allow for rapid assessment of, and adjustments to, changing laboratory conditions.
To this end, the laboratory should assign personnel to perform incident response functions within
the laboratory for monitoring of contamination and radiation, overview of sectoring the
laboratory for high- and low-activity samples, cleanup following a spill or identified contamina-
ted area, and disposal of the radioactive wastes from samples and the analytical process.
Examples of some of these functions with some procedural excerpts are shown in Appendix A.
3.2 Radioactive Materials License Issues
Current Nuclear Regulatory Commission (NRC, or Agreement States) Radioactive Materials
License requirements should be evaluated in terms of the laboratory's ability to accept and
analyze samples with higher-than-normal activity levels or to add new radionuclides.
Availability of provisions to increase the inventory limits, if necessary, for incident response
should be examined. It should be remembered however, that changes in license may impact other
aspects of laboratory operations, such as storage of materials and samples, and may require
increased controls (e.g., internal dosimetry, increased contamination monitoring).
3.3 Selecting the Type of Processing Configuration for the Laboratory
Efficient and safe use of available space becomes critical when an influx of samples with
potentially elevated activities is anticipated. Any changes that a laboratory plans to make to the
existing sample and work flow to continue working safely and produce results quickly and of
known quality should be planned in advance and be an integral part of the Radiation Controls
Program.
There are several possible approaches for managing the flow of material with varying levels of
radioactivity, including:
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
(a) The use of separate processing facilities for high- and low-level samples;
(b) Isolating high- and low-level sample processing areas in the same facility; and
(c) The use of a single low-level processing area.
The suggestions offered below may be used as a starting point for any changes that an existing
laboratory is considering, and should be a part of any new facility planning effort. The actual
approach selected by the laboratory will depend on factors such as resources available, the
projected intensity of the response effort, and other functions that the laboratory is required to
perform.
These suggestions may be considered to be three distinct, "ideal" solutions to a very complex
problem. (The discussion below offers only an overview of the topic. Additional information is
presented in the Guide for Radiological Laboratories for the Control of Radioactive Contamina-
tion and Radiation Exposure, in preparation). The specific plan that a laboratory develops may
have elements from all three, but in every case, the underlying principle always will be to
maintain the separation between high- and low-activity samples. Establishing and maintaining
this separation, combined with adding appropriate contamination controls, will assure both the
health and safety of the laboratory personnel and the public, and will protect the integrity of the
samples and the quality of the analytical results.
Separate processing facilities for high- and low-level samples. The segregation process ideally
should occur even before the sample receipt area is reached (i.e., in the field), with high- and
low-level samples arriving in separate shipments, or at least in separate shipping containers.
Each facility would have its own receipt and screening area, followed by transfer of the samples
to a separate high- or low-level processing facility. This is clearly the most resource-intensive
solution to the problem, but it affords the greatest degree of separation of high- and low-activity
samples. However, implementation of such an approach is probably possible only when a new
facility is being designed. For existing laboratories, depending on their size, physical setup, and
resources, two other possible alternatives are suggested below.
Isolate high- and low-level processing areas in the same facility. One common sample receipt
area can be used for screening and subsequent segregation of samples according to their assessed
activity levels. Samples are segregated, prepared, and counted in permanently established high-
and low-level processing areas, or in suitable areas that are temporarily assigned for processing
high- or low-level samples. The area for high-level samples should be self-contained, equipped
with balances, hoods, labware, hotplates, standards, and instrumentationwhatever is required
to support work at higher activity levels.
Additional concerns about contamination and cross-contamination, and the impact of radiation
on work areas and radioanalytical instrumentation, should drive the design and use of such areas.
Issues such as control of access, capability of the air handling system for minimizing air flow
between the high- and low-level processing areas, and control of the movement of materials to
eliminate the possibility of cross-contamination should be considered.
A laboratory may already have separate facilities for high- and low-activity samples, or may be
able to establish a high-level area in the existing space, taking into consideration issues discussed
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here. Until incident response work is required, these areas can be used for routine measurements,
with standard laboratory controls. However, returning to normal use after high-level samples
have been processed requires additional measures to determine and eliminate contamination
from the area. These measures and their impact on the routine operations of the laboratory should
be considered and defined in the laboratory's Laboratory Incident Response Plan.
Use one low-level processing facility. This option entails having a single dedicated sample
receipt screening area to screen and digest each sample, followed by appropriate dilution to
produce a solution with activity low enough to be handled in the routine low-level processing
area without undue risk of cross-contamination. This is clearly the least expensive option, as far
as facility costs are concerned. It is generally the best option for facilities that concentrate on
low-activity work and are not able to support a dedicated high-level sample processing facility.
This option would require the augmentation of an existing sample receiving process to allow for
screening and subsequent sample dilution to reduce the levels of activity in the aliquant
processed in the laboratory itself. The screening and sample preparation and dilution sample-
flow design should include measures to minimize the laboratory personnel's exposure to
radiation, and measures to minimize the potential of cross-contamination, since this is the only
time when samples with disparate levels of radioactivity are present in the same area. For soil
samples, laboratories accustomed to handling only low-level samples may use grinding
equipment that may not be appropriate for higher-level samples; therefore, equipment should be
available for samples suspected of having elevated levels. This also would require additional
dedicated screening instrumentation, such as liquid scintillation counters (LSC) or gas-
proportional counters (GPC), and perhaps even a high-purity germanium detector (HPGe), all of
which might become contaminated if an incident of national significance took place. (See
Radiological Laboratory Sample Screening Analysis Guide for Incidents of National
Significance [EPA2009c].)
However, this approach is not always effective. Some types of samples, such as soils, cannot be
easily subdivided without extensive treatment. Occasionally, radionuclides such as 238Pu may
need to be determined at very low levels in samples that contain higher levels of other
radionuclides (e.g., natural uranium or 137Cs). A separate screening and high-level sample
processing area may still be required in these cases.
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4. CHANGES TO THE LABORATORY QUALITY SYSTEM
4.1 Introduction
Laboratory data should be produced under a Quality System (EPA offers guidance on Quality
System documents at www.epa.gov/qualitv/qa docs.html). A Quality System is a structured and
documented management framework that describes the policies, objectives, principles, organiza-
tional authority, responsibilities, accountability, and implementation plan of an organization for
ensuring quality in its work processes, products (items), and services. The purpose of having a
Quality System is to provide the client with data of known and documented quality with which to
demonstrate regulatory compliance and for other decisionmaking purposes. This system includes
a process by which appropriate analytical methods are selected, their capability is evaluated, and
their performance is documented. The Quality System is documented in the laboratory's Quality
Manual.
Quality Assurance (QA) refers to an integrated system of management activities involving
planning, implementation, assessment, reporting, and quality improvement to ensure that a
process, item, or service is of the type and quality needed and expected. It can be thought of as
an overall plan and set of processes, including policies, procedures, guidance documents, training
programs, procurement specifications, and other laboratory activities and measurements that
support the overall quality of the analytical data, and ensure that the needs and expectations of
the end-user of the data are fulfilled (MARLAP 2004).
Quality Control (QC) is the overall system of technical activities whose purpose is to measure
and control the quality of a process or service so that it meets the needs of the users or
performance objectives. It can also be viewed as a subset of quality assurance and is meant to
include those aspects of the Quality System program that evaluate specific measurement data,
and other output parameters, against defined objectives that are derived in such a way as to
ensure that the data meet the requirements of the intended user (MARLAP 2004).
The purpose of this section of the guide is to introduce aspects of QA and QC that may be
specific to the laboratory's response to an incident. These aspects of QA and QC supplement the
established laboratory Quality System, and no part of this document is intended to supersede
established procedures, activities, and practices.
This guide assumes that prior to its participation in the response to a radiological or nuclear
incident, each laboratory will have undergone accreditation or approval by a nationally
recognized program such as EPA's Drinking Water Certification Program, The NELAC Institute
(TNI), or ISO 17025 accreditation, and thus will have the minimum elements of a Quality
System in place. This chapter of the guide addresses those aspects of QA/QC that are specific to
incident response that may not be included in the laboratory's normal QA plan. The QA elements
that need to be reviewed and augmented for incident response include, but are not limited to:
A Laboratory Quality Manual that provides overall guidance and procedures for all QA
and QC activities (see Section 4.2), including prescribed processes for addressing data
quality and other laboratory events that do not meet the established acceptance criteria.
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A QAPP for incident response that at minimum (see Section 4.3) considers additional
training relevant to radiological or nuclear incident response, anticipated changes to
chain-of-custody requirements, expedited corrective actions, appropriate level of method
validation of procedures for higher-level samples, and participation in proficiency testing
(PT) programs with PT samples similar to those anticipated in the response (see Section
4.3.5).
Establishing objective and defensible criteria for analytical measurement performance
criteria, and ensuring that incident response MQOs are met (see Section 4.4).
Identifying the types of QC samples that need to be re-evaluated in terms of their
frequency and acceptance criteria as a result of the laboratory's analyses of samples with
elevated levels of activity (see Section 4.5).
A project involving a radiological or nuclear incident should begin with the laboratory's existing
QA and QC requirements, and should address how those functions would change and how the
changes are to be implemented. For example, the staffing and approach for data review and its
frequency might change from weekly to daily, and the QC charts would have different ranges for
the laboratory control samples (LCSs; see Section 4.5.2). These are usually qualitative
requirements. QC parameters may be narrowly defined, based on the acceptability of a single
measurement or the adherence to a particular procedure.
4.2 The Laboratory Quality Manual
A laboratory's Quality Manual documents the management policies, objectives, principles,
organizational structure and authority, responsibilities, and accountability of a laboratory to
ensure the quality of its product and its utility to the user. This guide assumes that the laboratory
has a manual that clearly addresses quality assurance as it is applied to all testing and analytical
services on behalf of customers or accrediting organizations for its routine operations, and that
the laboratory's management has ensured that it is being implemented appropriately. The manual
should specify the management and technical requirements that demonstrate that the laboratory
operates a Quality System, is technically competent, and is able to generate valid results.
Requirements for a Quality System, and subsequent contents of a Quality Manual depend on the
standard used, such as The NELAC Institute (TNI) standard or ISO 17025. These standards
define elements of a Quality System that a laboratory might operate under to meet its obligations
or accreditation requirements (if applicable).
However, typically the Quality Manual does not address specific QA and QC measures as they
relate to the laboratory's participation in the response to an incident (or any other event-specific
project). These additional or supplementing measures, including appropriate QC acceptance
criteria, corrective actions, or other elements of the laboratory's Quality System that need to be
adjusted to meet the anticipated requirements of the response project, should be identified in the
QAPP for incident response. The elements of the QAPP for incident response that are considered
important to producing defensible and timely results are discussed next.
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4.3 The Quality Assurance Project Plan for Incident Response
The ongoing steps that a laboratory should take to ensure preparedness in the event of an incident
should be included in a QAPP for incident response,10 or other planning document, whose focus
would be only those elements of the laboratory Quality Manual that are relevant to the incident
response activities. This QAPP should define the anticipated quality requirements for incident-
related activities and should carefully delineate whether each requirement is supplemental to or
substitutes for the requirements stated in the Quality Manual. These additional requirements
should include:
Ongoing cross-training to maintain versatility and technical competence among the
existing staff.
Periodic exercises or drills to evaluate the laboratory's ability to perform anticipated non-
routine functions on short notice.
Periodic review and re-evaluation of a preliminary Laboratory Incident Response Plan
that outlines the steps to be taken once an incident has occurred and after more specific
information is available.
Responsibilities of personnel during implementation of incident response activities.
Procedures for transitioning from routine to incident response operations.
Implementation of a graded approach to method validation that would facilitate rapid
validation of methods that have been modified for response to a radiological or nuclear
incident.11
MQOs applicable to an incident response.12
Analytical procedures to be used.
Requirements for periodic retraining.
Requirements for other quality-related tasks, such as instrument background frequency.
An example of a project-specific requirement is to perform method blank analyses, such as air
particulate filters (see Section 4.5.2), which are likely to be supplemental to the standard batch-
and instrument-QC requirements contained in the laboratory's Quality Manual. At the same time,
the acceptance criteria for the incident-related batch or instrument QC may supersede the criteria
defined in the Quality Manual.
4.3.1 Incident Response Training
To the extent possible, personnel should be trained on what information would be needed to
respond adequately to a radiological or nuclear incident. At a minimum, this might include
gathering available information about identities of radionuclides that are likely to be present, the
levels of radioactivity expected, physical and chemical properties of the incident-specific
radionuclides, and anticipated action levels. Incident-specific MQOs, hazards that may be
10 Guidance on developing a Quality Assurance Project Plan can be found in EPA QA/G-5 (2002).
11 See Method Validation Guide for Qualifying Methods Used by Radiological Laboratories Participating in
Incident Response Activities (EPA 2009a) for details.
12 Default MQOs for water and air matrices may be found in Radiological Laboratory Sample Analysis Guide for
Incidents of National Significance - Radionuclides in Water (EPA 2008) and Radiological Laboratory Sample
Analysis Guide for Incidents of National Significance - Radionuclides in Air (EPA 2009b), respectively.
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present, and appropriate safety measures should be established and addressed in the training as
well.
Laboratory personnel should receive training on the various methods to be employed and should
demonstrate proficiency in those methods for which they will be responsible. This should be
planned and completed as part of an incident response preparedness program.
In addition, staff should be adequately aware of the Incident Command System anticipated for an
event, including planning for continuous communications with the Incident Commander,
depending upon the phase of the incident.
4.3.2 Review of Chain-of-Custody Information
While it is unlikely that an environmental radioanalytical laboratory will be involved in the
handling of forensic samples for attribution or prosecution purposes, there may still be special
chain-of-custody (CoC) requirements for the project. The laboratory should incorporate these
requirements into the QAPP.
In addition, large-scale projects may involve many laboratories with different capabilities, and
the incident site may contain many distinct zones with highly disparate levels of radioactivity.
Careful attention to field CoC protocols, if possible, combined with good communication
between the laboratory and the Incident Commander about the expected delivery of samples,
may help in the early identification of shipping errors and other handling issues that could
compromise the samples or possibly even contaminate the laboratory.
4.3.3 Expedited Corrective Action Procedures
The QAPP should clearly identify procedures and personnel in the laboratory that will address
any necessary corrective action in a timely and effective manner. Lines of communication both
within the laboratory and with the Incident Commander should be identified and staffed with
technically knowledgeable personnel who have the authority to make decisions regarding the
data quality and to help formulate corrective action plans, when necessary.
4.3.4 Method Validation Requirements
The QAPP should clearly define the requirements for the validation of newly developed or newly
introduced methods in the laboratory that will be used in incident response. It is likely that many
routine radioanalytical procedures may be appropriate for incident response. However, the
laboratory should validate any of these procedures for use in similar matrices, with varying or
higher activities or interference levels. In the absence of specific requirements, the companion
guide, Method Validation Guide for Qualifying Methods Used by Radiological Laboratories
Participating in Incident Response Activities (EPA 2009a) provides detailed guidance on the
validation of methods introduced under these circumstances. Key issues, such as uncertainty,
method specificity, ruggedness, precision, and bias and detection capability should be addressed.
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4.3.5 Proficiency Testing Programs
A laboratory preparing to respond to a radiological incident should participate in regular PT
studies that have radionuclides, activity levels, and matrices such as water, air paniculate, soils,
building materials, and swipes that are relevant to a radiological dispersal device (RDD)
incident.13 These PT studies can be used to examine specific components of a laboratory's
incident-response capabilities, such as turnaround time, suitability of reporting format,
contamination control procedures, and analysis of higher-activity samples, to determine the
laboratory's capability to respond to an incident of national significance. However, aside from
existing PT programs such as DOE's Mixed Analyte Performance Evaluation Program
(MAPEP), it is unlikely that appropriate external PT programs will be available prior to, or
immediately after, a radiological or nuclear incident. "Appropriate" in this case means that the
PT samples are of a similar matrix, with comparable radionuclides and activity levels, as the
samples received from the incident. The laboratory may need to assess the availability of PT
samples periodically and may consider developing internal PT samples before an event occurs.
In any case, using these PT samples routinely allows for initial and ongoing training on all
incident response procedures which then become an integral part of the laboratory's operations.
4.3.6 Availability of a Reliable Source of the Target Radionuclide
In developing methods and performing the analyses for the response to an incident, the
radionuclide of concern in the incident may not be readily available for method development,
instrument calibration, or batch QC purposes. The laboratory should develop clear guidelines for
the use of surrogate radionuclides for method development and quality control, and share these
with the Incident Commander for his/her approval. The type of radiation and its emission energy,
the chemical behavior, and the physical properties of the surrogate should be carefully
considered to assure that they are representative of the radionuclide(s) of concern.
4.4 Data Quality Objectives, Analytical Action Levels, Measurement Quality
Objectives, and Analytical Decision Levels
DQOs and MQOs can be established using the guidance found in MARLAP and should include
an analytical action level (AAL), discrimination limit (DL), gray region, null hypothesis,
analytical decision level (ADL), and required method uncertainty MMR at the AAL. It is
anticipated that the Incident Commander will provide the laboratory with appropriate DQOs and
MQOs. In their absence, default values for DQOs and a procedure for calculating related MQOs
are contained in Appendix VI of the Radiological Laboratory Sample Analysis Guide for Inci-
dents of National Significance -Radionuclides in Water (EPA 2008).
4.4.1 Data Quality Objectives
The DQO process may be applied to all programs or studies involving the collection of
environmental data with objectives that cover decisionmaking activities. When the goal of a
study is to support decisionmaking, the DQO process applies systematic planning and statistical
13 See Radiological Laboratory Sample Analysis Guide for Incidents of National Significance Radionuclides in
Water (EPA 2008) for an example of a list of radionuclides that might be present in an RDD.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
hypothesis testing methodology to decide between the alternative actions. DQOs can be
developed using the guidance in EPA QA/G-4 (2006).
Laboratory personnel should be familiar with the source or basis for the DQOs, and should have
a working knowledge of a directed planning process (MARLAP 2004, Chapter 2) to ensure that
any data generated support the decisionmaking process and are within the scope of capabilities of
the laboratory.
4.4.2 Analytical Action Levels
An essential part of the DQO process is the specification of a decision rule. This rule, which may
be qualitative or quantitative, will contain alternative actions to be taken, depending on whether
the analytical measurement result is above or below an AAL. The decision that will be made is
expressed in a hypothesis test. The null hypothesis is defined by initially assuming the result is
either above or below the AAL. Because analytical data always have some uncertainty associated
with them, a decision error may be made, e.g., rejecting the null hypothesis when it is true (a
Type I error), or failing to reject the null hypothesis when it is false (a Type II error).
The DQO process will result in a desired limit on the probability of making decision errors. The
limit for the probability of making a Type I error (denoted a) is generally specified at the AAL.
The probability of making a Type II error (denoted /?) is specified at a DL. The DL is a
concentration for which the null hypothesis is false, and where it is important to distinguish that
concentration from the AAL.
The AAL and DL together bound a gray region in which decision error probabilities are not
controlled as tightly as outside of it. The width of the gray region is A = AAL - DL .
4.4.3 Measurement Quality Objectives
Measurement quality objectives specify the analytical data requirements by which a measure-
ment can be assessed to meet the objectives of the project. MQOs generally are quantitative data
requirements that evaluate the quality of the measurement against the criteria for which decisions
are made using those data.
MARLAP considers the MMR at the AAL to be a fundamental MQO. For decisions about whether
a single sample exceeds the AAL, it can be calculated as UMR <
,14 Details and
refinements for this are given in MARLAP Appendix C or Appendix VI of either Radiological
14 zl_a and Zi_p are the respective quantiles of the standard normal distribution function. Values of zl_a (or z^) for
some commonly used values of a (or /?), taken from tables of the cumulative normal distribution (EPA 2009b), are:
a or/?
0.001
0.01
0.025
0.05
ZLatorzuj)
3.090
2.326
1.960
1.645
a or/?
0.10
0.20
0.30
0.50
ZLatorzuj)
1.282
0.842
0.524
0.000
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Laboratory Sample Analysis Guide for Incidents of National Significance - Radionuclides in
Water (EPA 2008) or Radiological Laboratory Sample Analysis Guide for Incidents of National
Significance -Radionuclides in Air (EPA 2009b).
In order to implement the use of the required method uncertainty, the laboratory must have in
place an acceptable method for estimating the combined standard uncertainty of each result.
MARLAP recommends the method put forth in the Guide to the Expression of Uncertainty in
Measurement (ISO 1995). No measurement should ever be reported without an associated
uncertainty and its coverage factor, k. Simply reporting "counting uncertainty" is incomplete,
and for high-activity samples, may result in significantly underestimating the combined standard
uncertainty.
4.4.4 Analytical Decision Levels
The AAL is the dividing point that determines a choice between alternative actions. The need to
make informed defensible decisions about whether an AAL has been exceeded, with acceptable
limits on the probability of a decision error, will drive the quality of the measurements of the
parameter being measured.
To limit the probability of a Type I decision error, the measurement result is compared to an
ADL.
If the null hypothesis is that the sample exceeds the AAL, the ADL is calculated as AAL -
Va WMR, where MMR is the required method uncertainty at the AAL.15 Only measurement results
less than the ADL will result in rejecting the null hypothesis that the true concentration is greater
than the AAL.16
As an example, let us look at a situation during sample screening, where it may be very
important to correctly identify samples that exceed the AAL. Sending a low-level sample to a
high-level section of the laboratory is less of a practical problem for the laboratory than risking
contamination by processing a high-level sample in a low-level section of the laboratory. In this
case, the null hypothesis is that the sample exceeds the AAL, to protect better against the Type I
error of incorrectly deciding that the sample is below the AAL when it actually is above the
AAL. However, we would like to be sure that if a sample is really below the AAL, it is also
correctly identified in order to avoid a Type II error of incorrectly deciding that the sample is
above the AAL when it actually is below. For this example, the discrimination level DL is
chosen as DL = 0.5AAL.
Suppose the AAL is 1 nCi/L activity in the sample. Then the DL is 0.5 nCi/L, and A = (AAL-
DL) = 1.0 - 0.5 = 0.5. The probability of making a Type I error is set at a = 5% and the
15 See MARLAP (2004), Chapter 3, for how to determine the M for a project.
16 Usually the null hypothesis that the sample exceeds the AAL is chosen. However, there may be cases where the
null hypothesis is that the sample does not exceed the AAL, for which the ADL becomes AAL + zl_a um, and only
measurement results greater than the ADL will result in rejecting the null hypothesis that the true concentration is
less than the AAL.
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probability of making a Type II error is set at /? = 10%. Notice that the probability of making a
Type I error is smaller than the one for a Type II error, and this reflects the statement made in the
previous paragraph about the greater risk associated with the incorrect decision that the sample is
below the AAL. Consequently, to minimize that risk, a small (5%) value is chosen for the
acceptable Type I error rate, and a larger (10%) value for the acceptable Type II error rate of
incorrectly deciding that the sample is above AAL.
From section 4.4.4, we limit the required method uncertainty to u^ < - = 0.5
nCi/L/(1.645 + 1.282) = 0.17 AAL = 0.17 nCi/L. From Section 4.4, the ADL = AAL - z^_
1.0 - (1.645) (0.17 nCi/L) = 0.72 nCi/L. Only measurement results less than the ADL will result
in rejecting the null hypothesis that the true concentration is greater than the AAL.
4.5 Quality Control
The basic types of QC samples prepared during the response to a radiological or nuclear incident
should be defined explicitly in the QAPP, or may follow the laboratory's default QC practices. In
most cases, the types of QC samples will include blank samples, LCSs (i.e., fortified blanks), and
duplicate samples. These QC types are not unique to an incident and are not addressed
specifically in this guide, except for the issues of event-specific acceptance criteria and the
special case of media used to collect samples, such as air filters and swipes.
4.5.1 Incident-Specific Acceptance Criteria
During routine laboratory operations, QC acceptance criteria are frequently used in the form of
control limits, which are derived statistically from historical data and which provide expected
limits for the performance of a method, based on past performance.
During the response to a nuclear or radiological incident, however, the Incident Commander
should specify acceptance criteria (MQOs) appropriate for the DQOs of the project. Using
concepts and equations found in MARLAP (Chapters 7 and 18 and Appendices B and C) and the
required method uncertainty WMR as the primary MQO, specific criteria can be derived.
The acceptance criteria that will change most significantly are those for the matrix spike (MS)
and the LCSs. These specific issues are discussed in Section 4.5.2. The laboratory should ensure
that the event-specific acceptance criteria are applied only to incident-related samples, and that
other samples unrelated to the incident are not evaluated against the incident-specific acceptance
criteria.
4.5.2 Sample-Related Quality Control
The frequency and acceptance criteria for sample QC may be different for an incident response
than for normal operations. Processing of samples that have activity elevated above samples
normally encountered will present contamination control issues for samples, reagents, sample
processing equipment, and sampling collection media (such as filters and charcoal cartridges).
For example, the frequency of routine blank sample analysis may need to be increased to reflect
different activity levels, and the need to monitor and minimize the impact of cross-contamination
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
on the results. Two types of laboratory blank samples, as defined in MARLAP (Glossary and
Section 18.4.1), should be distinguished:
Reagent blank- Consists of the analytical reagent(s) in the procedure (without the target
analyte or sample matrix), introduced into the analytical procedure at the appropriate
points and carried through all subsequent steps to determine the contribution of the
reagents and of the involved analytical steps.
Method blank - A sample assumed to be essentially target analyte-free that is carried
through the radiochemical preparation, analysis, mounting, and measurement process in
the same manner as a routine sample of a given matrix.
A reagent blank is a commonly used quality control sample used to evaluate absolute bias (i.e.,
positive or negative bias to the analytical measurement that results from reagents or other sources
of bias intrinsic to the method). Typically, one reagent blank is included in every batch.
However, an additional blank might be added when, due to the large quantities of reagents used
during incident response, more than one lot of chemicals or reagents is needed to complete
processing of samples in a batch.
Examples of method blanks would include clean, unused paniculate air filters, or a portion of
clean quartz sand of similar quantity to that of the sample aliquant. Where possible, use of
method blanks as batch quality control samples is the most ideal situation since method blanks
most closely match the actual matrix of the samples under analysis. Use of method blanks,
however, may complicate the QC evaluation of the blank since they may contain naturally
occurring radionuclides of interest. For example, natural uranium is commonly present in readily
measurable concentrations in glass fiber filters and in quartz sand which would interfere with
uranium or gross alpha/beta analyses. In such cases, it may be preferable to rely on a reagent
blank as a batch quality control blank. If the use of a method blank is deemed important, each lot
of material to be used as a surrogate (blank) matrix should be characterized for the radionuclides
of interest prior to its initial use and the data generated from the initial characterization used to
establish acceptance criteria for evaluating the acceptability of batch method blanks.
It also may be of interest to the project to obtain an accurate measurement of the background
activity of analytes of interest in sample collection media (e.g., glass fiber filters). The QAPP for
incident response should address periodic re-evaluation of interfering native constituents each
time the lot or manufacturer of sampling media changes. Similarly, it is suggested that a field
blank (or "trip blank") be analyzed as a sample to evaluate contamination that might result from
sample acquisition in the field and subsequent transport to the laboratory.
Two other routine quality control samples, as defined in MARLAP, that are used include:
Laboratory control sample - A standard material of known composition or an artificial
sample (created by fortification of a clean material similar in nature to the sample), which is
prepared and analyzed in the same manner as the sample. In an ideal situation, the result of
an analysis of the laboratory control sample should be equivalent to (give 100 percent of) the
target analyte concentration or activity known to be present in the fortified sample or
standard material. The result normally is expressed as percent recovery.
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Matrix spike - An aliquant of a sample prepared by adding a known quantity of target
analytes to a specified amount of matrix and subjected to the entire analytical procedure to
establish if the method or procedure is appropriate for the analysis of the particular matrix.
Both of these will need to have the activity increased to be commensurate with the activity of the
samples being analyzed. As an example, a laboratory normally adds 10 pCi of 90Sr to its matrix
spike for water samples. If the expected concentration of 90Sr is 300 pCi/L, the amount of spike
added needs to be increased so that the measured value associated with the matrix spike is not
obscured by the actual sample activity measurement uncertainty. In this example, a 5%
uncertainty in the 300-pCi/L sample activity is 15 pCi/L. This is greater than the amount of the
routine spike of 10 pCi/L, and any conclusions based on the results of the analysis of this matrix
spike will be meaningless.
The LCS and MS will need to have increased activity so that they can reflect the method's
capability to accurately determine higher concentrations of the radionuclide. Many methods rely
on chemical separations that use techniques such as microprecipitation, ion exchange, or solvent
extraction. Increased quantities of the radionuclide being processed by the analysis may
compromise the quality of the sample test source needed for an adequate spectrum, or exceed the
capacity of the technique or method to carry the radionuclide through the analysis.
Another routine quality control sample is the duplicate. From MARLAP:
Duplicates - Two equal-sized samples of the material being analyzed, prepared, and
analyzed separately as part of the same batch, used in the laboratory to measure the overall
precision of the sample measurement process, beginning with laboratory sub-sampling of the
field sample.
This sample is very important from the perspective that the method is reproducible on a sample
of the same exact matrix, that it is a measure of the adequacy of the estimation of the combined
standard uncertainty, and that laboratory sub-sampling has not compromised obtaining a
representative portion of the sample for analysis. Given the variability and complexity of
incident-response matrices, effective subsampling may be more of a challenge than when routine
samples are being processed. If there is a concern regarding the potential lack of reproducibility
because of a difficult matrix, it might be advisable to increase the frequency of duplicates,
followed by immediate review of the results, so that any detected problems can be addressed
promptly.
There are additional considerations when preparing LCSs in certain situations. Very often the
methods that have been developed and routinely used in a laboratory focus on the analysis of the
single radionuclide and may not have been validated when other radionuclides that are orders of
magnitude higher in concentration are present. Thus, a LCS may need to contain not only the
radionuclide of interest, but also another radionuclide expected to have a much higher concentra-
tion in the samples and also known to be an interferent in the separation and counting of the
radionuclide of interest.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Quality control charts that reflect the project-related acceptance criteria will need to be
established. This may be achieved by using the MQO for the required method uncertainty, MMR.
Specific equations identifying acceptance criteria (based on that required method uncertainty) for
duplicate, blanks, laboratory control, and matrix spike samples are also found in MARLAP.
4.5.3 Instrument-Related Quality Control
Many laboratories count instrument backgrounds for a much longer period of time than the
associated samples. During the response to a radiological or nuclear incident, it may be possible
to shorten background count times as long as they are still longer than the longest count time for
samples counted on that detector. This should not affect data quality because some of the
samples will have significantly higher count rates than the background for the radionuclides of
interest. Reducing background count times will create additional instrument capacity for the
counting of samples while ensuring that data quality is not compromised. On a routine basis, a
longer background count should be performed on each instrument to monitor the detector for
low-level contamination. However, the frequency with which this is done will be very low
compared to the short-term checks. It actually may be advisable to increase the frequency of the
short-term checks to monitor for possible contamination resulting from counting higher-activity
samples. These quality checks for the instruments may also be put into separate control charts
since the acceptance criteria for an out of specification result may end up being different when
analysis is performed on much higher-activity samples.
Finally, it may be useful to check an instrument for gross contamination by swiping sections of
the counting chamber and counting the swipes on a complementary detection instrument. For
example, a swipe of the inside of a gamma spectrometry cave may be taken and analyzed for
gross alpha and beta by gas proportional counting to identify the presence of non-gamma
emitting (or low-energy emitting) radionuclides that could pose contamination and cross-
contamination concerns. If such checks are to be conducted, however, it is very important that
long background checks and background subtraction counts be measured before and after the
swipes are taken. This is because swiping the chamber could add, remove, or redistribute
contamination and prevent contamination from being identified as having compromised the
sample counts, or even change the activity in a background subtraction count.
4.5.4 Tracking and Trending Quality Control Charts
In general, the approach to evaluating quality control charts during an incident response needs to
differ from routine operations with several changes that reflect changes to the analytical process
as a result of the incident response. It may be necessary to establish quality control charts for
methods not routinely used, or to reflect modification made to methods, and different activity
levels being processed, or to address project-related acceptance criteria. For example, if an
incident-specific method is used that varies from routine sample analysis, a separate control chart
is needed to allow performance of that method to be assessed apart from routine sample work.
Similarly, if the activity level of spiked control samples such as the LCS or MS may vary from
that of routine operation, it is important to set up separate control charts because performance at
those activity levels may vary from routine. Similarly, if a tolerance chart is used to track a
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
method against project-specific acceptance criteria, a specific control chart will be needed for
this purpose.
The frequency of analyzing control samples probably also will increase during incident response.
This is especially the case with blanks which need to be run at increased frequency due to an
increased risk of cross-contamination that accompanies running samples of higher activity than
normal. Similarly, the general approach to instrument QC checks may vary, and background
checks may need to be run more frequently because of increased concerns about cross-
contamination from samples of higher activity than normal. Finally, batches of samples may be
run at significantly higher frequencies than normal, and the frequency of trending of the charts
should be increased accordingly to ensure that bias and trends are promptly identified and
corrective actions taken in a timely manner.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
5. IDENTIFYING NEEDS AND OPTIMIZING RESOURCES FOR INCIDENT
RESPONSE
5.1 Introduction
Because a radiological or nuclear incident will occur without warning, advance planning is vital.
Large numbers of samples and as-quick-as-possible turnaround times will be the rule. The
increased levels of throughput will likely continue at unprecedented levels for many months, or
even longer. Planning to rapidly transition from normal operations to incident response
operations will help ensure that laboratories are ready to provide optimal support for an incident
response. Because such planning generally focuses on maximizing laboratory efficiency, such
planning often will also benefit the laboratory's routine operations.
Delays in obtaining critical items, such as tracers, standards, or columns, may also be responsible
for temporary or longer-term disruption of production. Critical physical resources also include
longer-term, more expensive items such as radioanalytical instrumentation and major laboratory
equipment, as well as smaller items ranging from minor laboratory equipment to expendable
supplies (e.g., disposable gloves), labware, reagents, and standards.
Laboratories should develop a plan that ensures instrumentation, laboratory equipment, and
supplies can be maintained at levels needed to support current and changing production needs
and which proactively address details associated with transitioning from routine operations to
incident response operations. This section will address several such areas.
This guide does not address personnel issues specifically, since that is beyond its scope.
However, it should be pointed out that both the capacity and the capability incident response
assessment has to include considerations such as the number of available staff and the extent of
available cross-training to ensure redundancy in all areas.
5.2 Documenting Capabilities and Estimating Capacity for Incident Response at the
Laboratory
An incident of national significance could create a sudden and very intense demand for a
particular capability or set of capabilities. Having previously identified capabilities and
capacities17 allows the laboratory to initially make more realistic commitments regarding the
type and number of samples that can be analyzed for particular parameters.
As part of planning for an incident response, a laboratory should define its capabilities and
estimate its capacity to analyze certain combinations of radionuclides and matrices. This will
establish a quantitative basis for planning to manage physical resources during an incident
response. It is recognized that capacity evaluations may need to take different forms to best
reflect the needs and unique aspects of the particular laboratory and questions at hand. Evalua-
tions may seek to place an upper bound on a laboratory's capacity by identifying discrete points
in the analytical process that limit a laboratory's capacity to perform a certain test or analyze a
17 The laboratory's capabilities must be based on validated methods. A laboratory should not assume that a method
can be developed and validated quickly, in response to the needs of an event.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
specific-sample matrix. For example, sufficient instrumentation and preparation space, proce-
dures, and staff may be available for processing soil samples, but a relative lack of equipment for
grinding soils may drastically limit the total number of soil samples that can be processed.
Appendix A provides an example of one possible matrix-based approach to estimating capacity
and identifying key factors that pose limits to a laboratory's capacity.
The laboratory, as part of its incident response planning, should develop contingency plans for
adding equipment, or making targeted changes to the facility and its operations, that will ensure
that it can maintain the physical resources needed to manage a smooth transition to incident
response operations, and which would allow it to very rapidly and economically expand its
capacity for a set of capabilities.18
5.3 Increasing Laboratory Capacity Without Adding Instrumentation
If the laboratory has not invested in additional radioanalytical instrumentation prior to the
incident, it may have problems obtaining new instrumentation in an expedient manner following
the incident. Demand will likely outstrip limited supply, and instruments may not be widely
available until after they are needed most. Anticipating this likely situation, the laboratory can
explore alternative strategies for increasing capacity using current instrumentation.
One strategy involves evaluating instrument use and implementing measures to identify under-
utilization. Such measures may be as straightforward as staffing uncovered shifts to provide
additional capacity. Screening potential high-activity samples before counting may identify cases
where shorter counting times will satisfy MQOs (while minimizing the risk of contaminating
detectors). Throughput also may be increased by optimizing QC frequency by processing full
batches of samples. If the laboratory Quality Manual and SOPs are flexibly and thoughtfully
written, QC protocols can be structured to reflect current needs for an instrument. For example,
the laboratory may be able to meet MQOs with shortened sample count times. Because
laboratories generally count backgrounds for much longer than the associated samples, it may be
possible to shorten background subtraction count times and periodic background checks to match
the counting times for samples, thereby "creating" additional instrument capacity for the
counting of samples, while ensuring that data quality is not compromised.
Another approach, however, involves additional advanced planning but will have the most
significant impact on increased sample throughput, not only for incident response operations but
potentially for routine operations as well. Since the count time needed to obtain results of a
specified uncertainty is roughly proportional to the inverse square of the size of the sample
processed, if methods can be modified to increase the size of the sample aliquant, count times
can be decreased and a marked impact on laboratory throughput achieved without having to
procure new instrumentation. Of course, this requires that more robust sample preparation and
chemical separation methods be used. Depending on the incident scenario and the radionuclides
being measured, sequential methods may contribute to time saving and thus increased capacity.
The laboratory should always remember that if it chooses to make significant changes in
18 Quite apart from the topic of incident response, such an exercise could identify areas where improvements could
be of immediate benefit to the laboratory's routine operations.
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methods or protocols, it is important that the methods be formally validated prior to use to
demonstrate that they will be capable of meeting project MQOs.
5.4 Adding (Non-Radioanalytical) Equipment During Incident Response
There is less chance that non-radioanalytical laboratory equipment will be as difficult to obtain
after an incident, as will radioanalytical equipment. It may be possible to identify areas where
additional capabilities would be needed following an incident. A laboratory may determine that it
can quickly expand capabilities by adding non-radioanalytical equipment after an incident. This
may allow the laboratory to quickly increase its productivity. New capabilities may be added, or
pinch-points that detract from laboratory capacity may be addressed by expanding existing
capabilities. This would require that specifications be written, plans developed, arrangements for
installing equipment made, methods developed, procedures written, and staff trained on new
equipment.
It might be possible to plan and make tentative arrangements with vendors in advance, so that
they will be able to secure equipment. For example, the laboratory in its Incident Response Plan
may make arrangements to conditionally rush order and rapidly deploy equipment when the need
arises. Plans should consider that, especially when major equipment is to be installed, this may
need to occur while the laboratory is working. Any plan should consider this and consider how to
minimize negative impacts on production. For example, sketches of the proposed changes to the
laboratory layout and the placement of the additional equipment could be included. SOPs could
be written flexibly enough that they apply to both old and new equipment, should it be added.
Table 1 lists examples of typical major and minor non-radioanalytical equipment and supplies
whose resupply a laboratory may choose to consider prior to an incident. Anticipating the need
for these materials and planning for their acquisition and deployment prior to an incident
response can significantly improve the laboratory's capabilities and capacity. Of course, any
complete list would be specific to a given laboratory's operations and could be much longer.
Table 1 - Typical Examples of Major and Minor Non-Radioanalytical Equipment
Major Laboratory Equipment
Minor Laboratory Equipment
Hoods
Glove boxes
Drying ovens
Muffle furnaces
Grinding equipment (e.g., paint
shaker ball mills)
Balances
Centrifuges
Specialty glassware such as radon
emanation or tritium distillation
apparatus
Microwave digestion apparatus
Infrared lamps (for drying planchets)
Pipettes, fixed and variable volume
Replacement parts
Sieves
Vortex mixers
Water bath
Hot blocks
Hot plates
Filtration apparatus (filter stands, manifolds)
Vacuum supply (e.g., filtering, emanation apparatus)
Chromatography apparatus
Vacuum boxes or peristaltic pumps for ion exchange and
extraction chromatography
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5.5 Supplies
Estimating capacity for an analysis is a difficult endeavor since estimates of capacity depend on
a large number of factors. The picture is further complicated since analytical demands change
from day-to-day, and varying mixes of analyses compete for a common set of resources. In order
to estimate the amount of supplies that are needed to ensure continued support to an incident
response, it is important to estimate the capacity of the laboratory to run the analyses in question.
This was discussed earlier in this chapter (see Section 5.2). Once some estimates for a realistic
maximum throughput have been made, the average expendables used for each analysis can be
estimated.
The simplest way to start is by analyzing the SOPs for use of various supplies, reagents,
standards, and other equipment. A list of typical supplies could include but is not limited to:
Reagents
Standards
Carriers
Resins
Chromatography supplies
Disposable labware
Centrifuge tubes
Pipette tips
Transfer pipettes
Filters, such as cellulose, glass fiber, polypropylene, etc.
Digestion vessels
Sample labels
Sample containers
Waste containers and drums
Swipes
Others that may be specific to the laboratory's methods
While some supplies have a relatively long shelf-life and may be used without concern of
expiration, others such as reagents, standards, and resins may have expiration dates assigned by
the manufacturer, or should have expiration dates established at the laboratory that will limit the
use of these items to a specific time, and which will also tend to limit the total inventory
maintained at any given time.
It is important to account for all supplies needed for batch QC (frequency varies based on batch
size), rework, preparation, cleanup, waste (e.g., assume that only 80 to 90% of standards or
reagents are fully utilized), and any periodic operations needed to continue running samples,
such as calibrations, backgrounds, validation activities, or standards verification activities. The
average rate of use for expendable supplies, equipment, reagents, and standards for operation at
maximum production levels should be calculated.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
The second step involves projecting realistic restocking time for critical expendables in the post-
incident context. It is important to identify potential critical supply-chain shortfalls that could
unexpectedly delay restocking of supplies. Vendors should be contacted and inquiries made
whether they keep enough stock on hand to address a run on supplies in the case of an
emergency. It could be assumed, as an example, that 30 to 40 laboratories will be placing orders
to meet similar needs calculated above. If a routine vendor does not maintain sufficient supply,
other vendors could be called on as back-ups if they can provide the same or at least equivalent
items. However, substituting items might impact method performance, and there may be pro-
curement restrictions on using non-approved vendors. Single-source suppliers for items, such as
specialty glassware, instrument replacement parts, and extraction chromatography supplies, may
not be able to maintain large stocks of items, and they may routinely produce to meet standing
orders from a customer. There are alternatives or strategies that might be used to secure the
supply of expendables. For example, it may be possible to obtain an agreement from a vendor to
maintain more stock (perhaps even at a discounted price) if it has contractual assurances that the
laboratory plans on procuring the item in question from the vendor over a longer period of time.
5.6 Major Radioanalytical Instrumentation
Radioanalytical instrumentation represents a longer term investment that contributes to an upper
bound on a laboratory's analytical throughput. Assuming that a laboratory's physical layout
already includes areas dedicated to sample preparation and chemical separation of potentially
elevated activity level samples, acquiring additional instrumentation is the next most effective
measure for increasing absolute analytical capacity. The relatively small size of the radioanalyti-
cal instrumentation market, however, will likely complicate attempts to obtain radioanalytical
instrumentation after a national emergency. Although the demand for instrumentation will spike,
manufacturing capacity for new instruments is typically tied to routine levels of demand. Even if
instrument manufacturers work to accommodate increased demand by ramping up production,
practical limitations such as the availability of trained, qualified personnel and the dependence
on contractor supply relationships mean that significant increases in production will possibly
occur after they are most needed. Limitations in the supply chain and the availability of four
major types of radioanalytical instrumentation in use at environmental radiochemistry labora-
tories will be addressed in more detail in Table 2 and in the subsections below.
5.6.1 Alpha Spectrometers
Instrumentation: Alpha spectrometers represent a relatively small niche in the radioanalytical
instrumentation market. Currently, there are only two producers of alpha spectrometers world-
wide. Total annual production is estimated in the range of 600 to 700 alpha spectrometers with
routine delivery times of 1 to 4 months, depending on currently available parts in stock. Alpha
spectrometry systems are manufactured on demand after receipt of an order. Financial considera-
tions, however, limit the number of excess parts maintained in stock for building alpha spectro-
metry systems. Parts on hand at any point in time may be sufficient to build no more than a total
of 20 to 30 chambers per manufacturer. After critical manufacturing parts are exhausted,
production of new units must stop until specialty contractors resupply the manufacturers. At that
point, production will move forward, limited by the established capacity for manufacturing the
units (trained personnel, facilities) and the resupply of critical components.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Table 2 - Availability of Radioanalytical Instrumentation Following a Radiological or Nuclear or
Incident
Laboratory
Instrument
Type
Alpha
Spectrometry
Systems
Gamma
Spectrometry
System
Low
Background
Gas Flow
Proportional
Counters
Liquid
Scintillation
Spectrometry
System
Component
Ch b
T~) ptp r*t or
J-X ^f l^f \S l\J 1
P 1 P r*t ro til r* ^
J 'IV I/ Ll \J111 \s o
Software
Detector
Electronics
Shield
OlllVlU
Software
Complete
system
Complete
system
Number
of
Vendors
in U.S.
(Globally)
2(2)
2(2)
3(4)
2(3)
Typical
Lead
Time
30-120
days
1-2
weeks
60-90
days
3-12
mo.
1-2
TT/ppl^-C
W ttJxS
2-3 mo.
1-2 mo.
Post-
Incident
Availability
and Delivery
Time
Extremely
limited
availability.
Delivery 9-
12 mo. and
beyond.
Yes
Very limited
availability.
Delivery 6-9
mo. and
beyond.
Yes
T ITTlltPfl
.1 i 1 1 1 11 IX- U.
availability.
Delivery 3-
12 mo And
beyond.
Good
\J\J\J\A.
availability.
Delivery 30-
beyond.
Time After
Delivery
Until
Productive
Days to
weeks
months
Days to
weeks
Days
Weeks
Days to
weeks
Comments*
World-wide production is -600-
700 chambers/yr. Systems
exclusively built to order - parts
on-hand limit immediate
production to < 50-100
chambers. Perhaps 1A of
available production will go to
environmental labs. After -6
months for ramp-up, additional
combined production may reach
25-50 chambers/month.
Perhaps 30-40 detectors in stock
at any time. Shortage of
electronics will immediately
limit delivery to less than -10
complete systems. After 3-6
months ramp-up, production for
new systems will be -20-30
units/month/ manufacturer.
Shields generally are built to
order and are a second limiting
factor. After 3-6 months ramp-
up, output of shields may reach
~5-10/week.
Stock of completed instruments
is probably -1 per manufacturer.
Limited parts are maintained in
stock and will delay ramp-up.
After 3-6 months ramp-up,
production will peak at -1 unit/
week/manufacturer. At this
point, however, the limiting
factor shifts from supply to on-
site support for set-up and repair
of instruments.
Relatively significant
production capability due to
market demand in biotech
research (25-35 units/mo). On-
site installation may present
itself as limiting to overall
expansion in the availability of
new instrumentation.
Support to install all instruments likely will be problematic after an incident but is not considered here. Information
in the table on the production and availability of various instrumentation types presented in the following sections is
based on information obtained during 2008 in interviews with present and former representatives of major
radioanalytical instrument manufacturers, including Ametek Ortec, Canberra, Gamma Products, Perkin Elmer Life
Sciences, Protean Instrument Corporation, and Target Instruments.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Following an incident involving alpha-emitting radionuclides, the short- and mid-term avail-
ability of alpha spectrometry systems will be poor, and delivery times may extend to a year and
beyond. Additionally, it is estimated that only about one-third of total production of alpha
spectrometers will be available for environmental testing after a radiological or nuclear incident
due to urgent demands for bioassay testing. Thus, it seems reasonable that perhaps only 200 to
250 additional alpha spectrometry chambers would become available over the first year after an
event. Given the longer term sales outlook, it seems unlikely that instrument manufacturers will
be inclined to expand production capabilities significantly beyond current levels.
Maintenance, Repairs, Spare Parts, and Consumables: In developing their incident response
plan, laboratories may wish to consult with manufacturers for recommendations for spare parts
and to discuss options and expectations for major maintenance should this be needed.
Laboratories may evaluate their needs and resources, and plan to maintain a supply of spare parts
on hand to facilitate minor repairs that are simple to complete on-site. Such parts might include:
Charged particle detectors (PIPSฎ/ruggedized alpha detectors)
Modular electronic components (e.g., amplifier, analog-digital converter (ADC), pulse-
height analyzer (PHA), multichannel analyzer/multichannel buffer/acquisition interface
module (MCA/MCB/AIM), bias supply)
Stand-alone alpha spectrometers (e.g., integral amplifier and electronics as appropriate)
Replacement cables (appropriate type, impedance, resistance, etc.)
Replacement chamber shelves
Gaskets or O-rings for chambers and vacuum manifold
Vacuum pumps
Vacuum pump oil demisters
Although silicon-charged particle detectors (i.e., alpha spectrometry detectors) are not
inexpensive, keeping spare detectors on hand (e.g., 10% of total installed capacity) will allow the
laboratory to immediately replace contaminated or defective detectors. Following an incident
with alpha emitters, detectors will likely be hard to obtain while contractors resupply the
manufacturer with detector-grade silicon and needed parts for manufacturing. Being able to
continue operations with a minimum of down-time, however, is not only vital, it will also
quickly repay the cost of any replacement detectors. If a detector is contaminated with short-
lived radionuclides, it need not be disposed of, but rather can be taken out of service for a period
of time until the contamination decays to levels that permit reuse.
When dealing with an alpha spectrometry system based on modular electronics, keeping spare
electronic components and supplies on hand will facilitate rapid troubleshooting of electronic
components and also provide replacements for defective components, thus saving time. Some
alpha spectrometry systems are constructed in group units (two, eight, etc.) with much of the
electronics and vacuum system integrated into a single spectrometer. While these units offer
some degree of operational simplicity, they may not lend themselves to on-site troubleshooting
and service that is as rapid as is the case for highly modular units. Thus, when service is
required, the entire multiple detector unit will potentially have to be taken off-line and returned
to the factory resulting in a significant loss of production capability. Clarifying and potentially
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
negotiating terms for major repairs in advance will both inform the laboratory's maintenance
planning and help streamline repairs should these become necessary. The laboratory will
significantly minimize interruptions in operations by putting a service contract in place with the
instrument manufacturer to guarantee rapid turnaround times for phone, on-site, and factory
troubleshooting and service. Laboratories should evaluate their needs and resources, and plan to
maintain a supply of critical consumable supplies that need to be maintained for alpha
spectrometry. Some possibilities for such a list could include:
Microprecipitation filters
Sample mounting disks
Microprecipitation filter funnels
Disks for electroplating
Electroplating cell supplies
Storage containers for sample test sources (e.g., Petri dishes or envelopes)
Mixed alpha calibration standards
Vacuum pump oil filters
Ion exchange and solid-phase extraction chromatography resins
5.6.2 High-Purity Germanium Gamma Spectrometers
Instrumentation: Analogous to alpha spectrometers, currently there are only two producers of
high-purity germanium (HPGe) gamma spectrometry systems in the world. While it is estimated
that after an incident, gamma detection instrumentation will be more readily available than alpha
spectrometers, obtaining new HPGe systems following an incident will be nevertheless
problematic. Stocks of HPGe detectors available on a routine basis are estimated to be fewer than
about 40 detector units. Initial supplies of complete gamma spectrometry systems, however, will
be limited by the availability of supporting electronics and counting shields to about 5 to 10
complete systems. After a period of 2 to 4 months required for production ramp-up, it is
projected that approximately 20 to 40 systems can be produced per month, and that turnaround
times for delivery could likely extend months and beyond, depending on demand. Laboratories
should also be aware that there are limitations regarding cross-platform compatibility of
equipment, especially in the case of associated electronics. While this is generally less of a
concern than in the case of alpha spectrometry, it will still tend to limit laboratories to buying
instrumentation from the manufacturer of gamma spectrometry equipment and software already
installed at the laboratory.
Maintenance, Repairs, Spare Parts, and Consumables: The considerations here are similar to
those discussed for alpha spectrometers. The laboratory should consult with the manufacturer
regarding spare parts as well as expectations for major maintenance. Laboratories should
evaluate needs and resources, and maintain a supply of spare parts on hand to facilitate minor
repairs that are simple to complete on-site. These might include:
Modular electronic components
Spare nuclear instrument module (NEVI) bin/NEVI power supply (many ADCs require 6-
volt power)
Replacements for cables (appropriate impedance or resistance for the application)
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Grounding straps
Volt meter
Dewar stands and insulators (to isolate potential electrical noise pickup/ground loops)
Dewar collar replacements
Liquid nitrogen fill lines and fittings
Oscilloscope
Entrance window protector caps (for extended range detectors)
Sample positioning jigs (also called geometry stands)
Sample carriers for automatic sample changers
When dealing with modular electronics, keeping spare electronic components and supplies on
hand will greatly facilitate rapid troubleshooting of electronics problems and provide replace-
ments for defective components, thus eliminating time lost waiting for repairs or replacements. If
major service is required for defective spectrometry equipment, units must often be returned to
the factory. Clarifying and potentially negotiating terms for major repairs in advance will inform
the laboratory's maintenance planning and also streamline repairs should these become
necessary. The laboratory can significantly minimize interruptions in operations by putting a
service contract in place with the instrument manufacturer to guarantee rapid turnaround times
for phone, field, and factory troubleshooting and service.
Laboratories should evaluate needs and resources, and plan to maintain stocks of critical
consumable supplies for gamma spectrometry. Some possibilities could include:
Containers for all calibrated geometries (e.g., Marinelli beakers, bottles, vials, planchets,
etc.)
Plastic spill protection (to cover detector and inside of cave)
Calibration standards
Liquid standards, radionuclide mix for custom standards, and QC samples
Liquid nitrogen
5.6.3 Low-Background Gas Flow Proportional Counters
Instrumentation: Short- to mid-term supplies of low-background gas proportional counters will
be limited following a radiological or nuclear incident. Although there are currently three
manufacturers that regularly supply the U.S. market (four world-wide), the overall size of the
market is still relatively small. Manufacturers generally have no more than one instrument of any
one type immediately available. After current supplies are exhausted, three to four months will
be needed to ramp up production to a level of about one detector system per manufacturer per
week. Thus, if 30 laboratories need to acquire one multi-detector unit each, it is estimated that
the minimum time elapsed between the order and delivery of the final units would be in the
range of 10 to 14 weeks. One further complicating factor will be having sufficient service
personnel available to install new equipment. This could extend delivery times by an additional
month or longer.
Maintenance, Repairs, Spare Parts, and Consumables: Although there are similarities to
alpha and gamma spectrometers, gas flow proportional counters generally rely less on modular
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
electronics than do alpha or gamma spectrometers. The effect of this is twofold. First, shared
electronics for multiple detector units are more expensive and sometimes more difficult to
troubleshoot on-site. Second, it is often less economically feasible to maintain components in
reserve that can be used for troubleshooting and rapid field repairs. Thus, the likelihood that
components will need to be sent back to the factory is greater than with highly modular alpha or
gamma spectrometry equipment.
Laboratories should evaluate needs and resources, and maintain a supply of spare parts on hand
to facilitate minor repairs that are simple to complete in the field. These might include:
Replacement windows for detectors
Carrier plates and inserts of various depths (as calibrated)
P-10 gas lines, plastic tubing and fittings
Amplifier
Detector replacement (particularly valuable for single detector units)
High-voltage power supply
Clarifying and potentially negotiating terms for major repairs in advance will inform the
laboratory's maintenance planning and also streamline repairs should these become necessary.
The laboratory can minimize interruptions in operations significantly by putting a service
contract in place with the instrument manufacturer to guarantee rapid turnaround times for
phone, field, and factory troubleshooting and service.
Laboratories should evaluate needs and resources, and plan to maintain stocks of critical
consumable supplies for gas flow proportional counters. Some possibilities could include:
P-10 gas
Snap rings or other filter mounting supplies for all calibrated configurations
Prepared efficiency or self-absorption calibration standards
Liquid standards and reagents for preparing efficiency or self-absorption standards with
short shelf-life (due to decay/ingrowth)
Planchets for all calibrated configurations
5.6.4 Liquid Scintillation Counters
Instrumentation: Short-term availability of liquid scintillation counting instrumentation will
likely be better for liquid scintillation counters than the other major instrumentation types used
for radiochemical analysis. Although there are only three suppliers of laboratory liquid scintilla-
tion counters, these instruments are commonly used in biological and pharmaceutical research,
and thus the market for liquid scintillation counters is much larger than for other low-level
radioanalytical instruments. Based on information received from one supplier of liquid scintilla-
tion counters, approximately 30 liquid scintillation counters would be available each month,
without need to modify production rates. Allowing for production from the other producer,
presumably 35 to 50 units could be produced per month prior to expanding production
capabilities. Thus, delivery times for scintillation counters are projected to range from weeks to
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
months. One limiting factor could be the installation of new equipment since only a fixed
number of service personnel are available for setting up equipment at laboratories.
Maintenance, Repairs, Spare Parts, and Consumables: Liquid scintillation counters are single
detector instruments. They are highly integrated and thus do not lend themselves to extensive
troubleshooting or repair by the user. On the other hand, there is almost never a need to return
them to the factory for service. Once on-site, service personnel can generally repair an
instrument in several hours. If parts are needed, these can generally be obtained from the factory
within 24 to 48 hours (depending on shipping options available for the time of day and the
location). Thus there is relatively little utility in maintaining spare parts for these instruments.
By the same token, however, clarifying and negotiating terms for major repairs in advance will
not only assist the laboratory's maintenance planning but also likely be the only option for
ensuring that service will be available in a timely manner. Putting a service contract in place with
the instrument manufacturer will optimize rapid turnaround times for phone, field, and factory
troubleshooting and service.
Evaluating needs and resources and planning to maintain stocks of critical consumable supplies
for liquid scintillation counters, on the other hand, will help prevent interruptions in production
operations. Some possibilities could include:
Sample racks
Scintillation vials
Scintillation cocktails (for all methods to be used)
Reagents and quenching agents for preparing quench curves
Liquid radionuclide standards for preparing efficiency standards and quench curves
5.7 Managing Supplies for Incident Response
Laboratories generally maintain sufficient inventory of supplies to support routine needs.
Planning ahead will help ensure that the laboratory will have sufficient supplies to accommodate
demand. The plan should evaluate the routine demand for supplies as well as the demand for
supplies that would arise as a result of a radiological or nuclear incident. The challenge is that
one cannot know when an incident might occur or which analyses will be required. The cost of
maintaining inventory, and in some cases shelf-life restrictions, encourages laboratories to
minimize supplies on hand, with mechanisms in place to restock supplies on a just-in-time basis.
However, a plan should be in place to allow for transition between routine and incident response
operations. This plan should balance inventory levels for routine and maximum capacity with
shelf-life limitations and economic concerns (e.g., cost of maintaining inventory).
In order to ensure that sufficient supplies are available to support an incident response, an
estimate of the supply "burn rates" at maximum throughput has to be obtained first. Based on the
maximum throughput values determined, and estimates of time needed to resupply, the levels of
inventory that would be needed to ensure continued operations can be projected for the time
needed to resupply. Weighing ongoing routine operational needs with financial considerations
will allow a laboratory to determine whether routine inventory can be maintained at levels to
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
ensure continued operations until new stocks arrive. If not, and if there is no funding available to
stockpile critical supplies, the resupply limitations should be documented in the Incident
Response Plan along with projected supply "burn rates" at maximum throughput. In the case of
an incident, the plan can then specify that the Incident Commander is promptly notified about
supply concerns so that he/she can help facilitate the resupply effort.
5.8 Reagents, Resins, Carriers, and Standards for Incident Response
Reagents, resins, carriers, and standards all play critical roles in the analytical process. Also, a
significant amount of time may be required to procure some of the materials, and to prepare
solutions and verify the integrity of these solutions. These materials and the time needed for their
preparation and verification should be taken into account when estimating the quantities of
supplies that will be needed to maintain operations during an incident response.
It should be noted that in the case of an incident response, processing higher-activity samples
will require tracer solutions and QC solutions that match the levels of activity being processed in
the laboratory. Thus, the amount of activity needed in standards will exceed that used for routine
samples. Appendix A includes an example of preparing laboratory supplies for incident response.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
6. MISCELLANEOUS LABORATORY INCIDENT RESPONSE PREPARATION
ISSUES
A variety of additional concerns relative to the laboratory's security, documentation, data
handling and reporting, and staffing should be addressed when the laboratory is planning and
preparing for a radiological incident response.
Security: Additional security measures may be needed if samples have increased chain-of-
custody requirements (e.g., legal, forensic) or need to be safeguarded against theft as potential
materials for an RDD.
Data handling and reporting: A significant increase in the number of samples may challenge the
ability of the laboratory to handle the flow of information as the samples are logged in,
processed, and analyzed; results are calculated and evaluated; and the reports are prepared. It
may be advisable to consult an information technology specialist to evaluate the existing system
of data handling and recommend changes where appropriate and feasible. Such evaluation and
resulting improvements will benefit the laboratory in the long run even when operating under
routine conditions. Examples of issues that should be addressed are:
Can the current system of sample receipt handle large influx of samples?
Is there a system in place to clearly identify samples and the results of screening that
create more than one stream of samples through the laboratory?
Does the laboratory have a system in place, such as a Laboratory Information Manage-
ment System, that collects data, performs calculations, and prepares required reports?
Are any changes to the current verification and validation procedures required?
Will these changes require additional staff and/or additional training for the existing
staff?
What reporting format(s) is supported by the laboratory, and is it aligned with require-
ments set forth by the authorities/organizations/agencies that will be accepting these
reports during the incident response?
Human resources: The Laboratory Incident Response Plan should identify changes in the
responsibilities and additional job functions created as a result of the laboratory's participation in
the incident response (see Section 2.2.2). However, such a plan is most likely written in terms of
job functions and responsibilities, and not in terms of names of specific staff members. The
laboratory management, when creating actual staffing plans for the incident response, should
take into account individual situations of the current staff, and plan to provide support in those
areas that might significantly interfere with their work performance during the response (e.g.,
daycare, eldercare, medical restrictions, transportation, and dietary needs).
Waste management: Even when routine waste is managed according to established procedures,
additional considerations arise when the influx of samples increases significantly or when high-
activity samples are analyzed. While questions such as those listed below may function as a
starting point and can be considered and addressed in advance of the incident, other issues may
be identified only during the incident response and may require real-time coordination with
appropriate federal and state agencies, waste brokers, and disposal facilities to ensure satisfactory
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
outcomes to the issues encountered. In any case, a laboratory's review of the questions should
generate discussions and proposed solutions for as many elements as possible.
What will be the potential volume of stored waste? What additional waste storage containers
may be needed?
If different or new methods of analysis are used during an incident response, will the
composition and character of waste differ from routine? Are procedures in place to accom-
modate the differences (e.g., revised sampling protocols, appropriate storage containers,
increased frequency of monitoring)?
Will the new wastes generated in the incident response samples be chemically compatible
with each other and existing waste forms?
How will the level of residual contamination in the waste change, and how will it impact
handling and disposal?
How will the stored waste be monitored? For which radionuclides are there validated
methods for sampling and monitoring the waste forms?
How and where will the waste be stored? Is it remote from occupied areas? What kind of
shielding, monitoring, and security will be provided?
Have disposal options been identified for all types of waste that will be produced?
Are waste brokers, and treatment, storage, and disposal sites able to accept all wastes
produced (considering activity levels; radionuclides, including radiotracers and carriers
normally used in the routine methods; mixed hazardous or toxic wastes)?
Are export permits needed to allow disposition of waste?
Will disposal be timely enough to ensure that regulation-driven time frames for RCRA-
regulated wastes (including mixed waste) can be met?
How will the laboratory's radioactive materials inventory system (as required by the NRC
license) be updated to track activity contained in wastes?
Will disposal be timely enough to ensure that radioactive material license possession limits
are not exceeded (given that material will accumulate more quickly)?
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7. REFERENCES
American National Standard Institute (ANSI) N42.23. Measurement and Associated Instrumen-
tation Quality Assurance for Radioassay Laboratories. 1996. Available at: www.ansi.org
ASTM D7282, Standard Practice for Set-Up, Calibration, and Quality Control of Instruments
Used for Radioactivity Measurements. ASTM International, West Conshohocken, PA, 2006.
Available at: www.astm.org/Standards/D7282.htm.
U.S. Department of Homeland Security (DHS). 2008 National Response Framework, Nuclear/
Radiological Incident Annex. Federal Emergency Management Agency, Washington, DC.
June. Available at: www.fema.gov/emergency/nrf/.
U.S. Environmental Protection Agency (EPA). 2002. Guidance for Quality Assurance Project
Plans (QA G-5), Washington, DC, EPA 240/R-02/009, December. See www.epa.gov/
quality/qa_docs.html.
U.S. Environmental Protection Agency (EPA). 2006. Guidance on Systematic Planning using the
Data Quality Objectives Process (QA G-4), Washington, DC, EPA 240/B-06/001, February.
See www.epa.gov/qualitv/qa docs.html.
U.S. Environmental Protection Agency (EPA). 2008. Radiological Laboratory Sample Analysis
Guide for Incidents of National Significance-Radionuclides in Water. Revision 0. Office of
Air and Radiation, Washington, DC. EPA 402-R-07-007, January. Available at:
www.epa.gov/narel/incident guides.html.
U.S. Environmental Protection Agency (EPA). 2009a. Method Validation Guide for
Radioanalytical Laboratories Participating in Incident Response Activities. Revision 0.
Office of Air and Radiation, Washington, DC. EPA 402-R-09-006, June. Available at:
www.epa.gov/narel/incident guides.html.
U.S. Environmental Protection Agency (EPA). 2009b. Radiological Laboratory Sample Analysis
Guide for Incidents of National Significance-Radionuclides in Air. Revision 0. Office of Air
and Radiation, Washington, DC. EPA 402-R-09-007, June. Available at: www.epa.gov/narel/
incident guides.html.
U.S. Environmental Protection Agency (EPA). 2009c. Radiological Laboratory Sample
Screening Analysis Guide for Incidents of National Significance. Revision 0. Office of Air
and Radiation, Washington, DC. EPA 402-R-09-008, June. Available at: www.epa.gov/narel/
incident guides.html.
U.S. Environmental Protection Agency (EPA). 2009d. Standardized Analytical Methods for
Environmental Restoration Following Homeland Security Events., Revision 5.0. EPA/600/R-
04/126E, September. Available at: www.epa.gov/nhsrc/pubs/600r04126e.pdf.
U.S. Environmental Protection Agency (EPA). (In Preparation). Guide for Radiological Labora-
tories for the Control of Radioactive Contamination and Radiation Exposure. Washington,
DC.
International Organization for Standardization (ISO). 1995. Guide to the Expression of Uncer-
tainty in Measurement. ISO, Geneva, Switzerland.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Multi-Agency Radiological Laboratory Analytical Protocols (MARLAP) Manual. 2004. EPA
402-B-04-001A, July. Volume I, Chapters 6, 7, 20, Glossary; Volume II and Volume III,
Appendix G. Available at: www.epa.gov/radiation/marlap.
U.S. Nuclear Regulatory Commission (NRC). 1999. Consolidated Guidance About Materials
Licenses: Program-Specific Guidance About Licenses of Broad Scope. Washington, DC.
NUREG-1556, Volume 11, April. Available at: www.nrc.gov/reading-rm/doc-collections/
nuregs/staff/sr!556/vl I/.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
APPENDIX A: EXCERPTS FROM AN ACTUAL LABORATORY INCIDENT
RESPONSE PLAN
Incident response changes routine functions of all personnel. New or more detailed responsi-
bilities need to be assigned to specific personnel so that each area of response has a "caretaker."
In addition to new assignments and more detailed functions, procedural modifications can occur
that deal specifically with incident response, particularly with samples of elevated activity that
can easily contaminate the laboratory environment.
The different sections of this appendix identify excerpts from an actual Incident Response Plan
that show how these modifications to laboratory operations are made. They are presented as
examples and are not intended to be complete or appropriate for all laboratories. Mention of
brand names or trademarked equipment does not constitute endorsement or approval by EPA.
Al. Initial Laboratory Preparation
Laboratory work flow and access controls will be modified to restrict access to areas from the
clean side into the contaminated or radiologically controlled areas and vice versa. One of the
main starting points is sample receipt. The use of checklists for a function like this is very
important. The checklist easily identifies the planned strategic functions for setting up the
laboratory and other areas. The checklists do not have to be performed in sequence and may
contain optional materials or actions that can be determined "Not Applicable" by the responsible
party. Identified here are two examples: one for the sample receiving area and one for the sample
preparation room. In each case, the specifics for an individual laboratory have been used as an
example.
Example Al.l Sample Receiving Station
The sample receiving station is a Radiological Control Area (RCA); a personnel survey/decon-
tamination form is required for entry or exit. Ribbon barriers mark the boundaries of the station
at both ends. A piece of plastic sheeting is used to cover the area of ground where samples may
be placed during processing. Vehicle approach to the receiving station is controlled by ... [fill in
controls like signage, cones, etc]. Access to the area is limited by ... [fill in methods like
barricades, signage, etc.].
PREPARATION OF THE SAMPLE RECEIVING STATION
Use the following checklist to make changes when setting up for incident response:
Q] 1. Apply plastic sheeting to the ground in the sample receiving area where samples
may be placed during processing.
Q 2. Place stanchions around the outside receiving area, and connect them with
ribbons. Post "Radiation Area" signs on each leg of this barrier. If bad weather is
expected, erect a small tent. If operations are expected to occur in darkness, erect
a set of halogen work lights.
Q 3. Place a table or cart just outside the door to be used for sample processing and to
hold survey meters and consumable supplies such as gloves, wipes, bags, and
tape.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
Q] 4. Place a barrier ribbon across the walkway to the main building area and post a
"Radiation Area" sign at the barrier. This is the RCA boundary.
Q 5. Set up two large garbage cans with liners in the hall inside the RCA boundary.
One is labeled "Radioactive Disposable," and the other one is labeled
"Radioactive Washable."
Q 6. Set up a photocopier or scanner in the hall outside the RCA boundary.
Q 7. Secure a step-off pad to the floor in the hall just outside the RCA boundary.
Q 8. Place a cart, or other appropriate carrier, in the hall just outside the RCA
boundary for sample transport.
Q 9. Perform and document an area survey prior to the arrival of samples using an area
survey/decontamination form.
Example A1.2 Sample Preparation Room
The sample preparation room is where samples are opened and processed for analysis. It is a
Radiological Control Area; a personnel survey/decontamination form is required for transfer of
materials in and out of this room. The laboratory includes workbenches, tables, a chemical fume
hood, a sink, a gross gamma detector (NaI[Tl]), and computer workstation. The laboratory has
three distinct working zones: the fume hood area where samples will be opened and processed,
the sink area where equipment will be cleaned, and the desk/gamma screening area where
clerical work will be performed. Within these three zones, there are seven specific areas in which
samples may be placed as they progress through processing.
PREPARATION OF THE SAMPLE PREPARATION ROOM
Q] 1. Remove all items that are not expected to be used during the emergency. Items
that will not be used but are to remain should be covered with plastic sheeting.
Q 2. Line the floor of the room with plastic sheeting in areas where sample processing
will take place.
Q] 3. Cover shelving with plastic sheeting. Leave one or two shelves open for storage.
Clear them of objects and line them with plastic.
Q 4. Cover bench tops and tables with an absorbent liner
Q 5. Place a barrier ribbon across the door to the laboratory at a height that allows
people wearing personal protective equipment to step over it.
Q 6. Post "Radiation Area" and "Authorized Personnel Only" signs outside the door.
Q] 7. Place a step-off pad in the hallway just outside the barrier.
Q] 8. Line a small table with absorbent material and place it outside the RCA
boundary, next to the step-off pad. This table will hold a survey meter and
personnel survey/decontamination forms.
Q] 9. Place three large garbage cans with liners in the laboratory. Label one
"Radioactive Disposable" and another "Radioactive Washable." Place "Caution
Radioactive Materials" signs on both of these garbage cans. Label the third
"Clean Garbage."
r~| 10. Label the work areas as follows:
A Area 1 Sample receiving area. Workbench, nearest the door. Samples are placed here as
they are brought into the lab.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
B Area 2 Sample processing bench top. Workbench, nearest the fume hood. Air and water
samples are processed here. Double-line with absorbent paper.
C Area 3 Sample processing fume hood. All other sample types are processed here.
Double-line with absorbent paper.
D Area 4 Gamma screening. Gamma detector in southeast corner of room (to the right of
the door on entering). Samples requiring a 1-minute screen are counted here,
then taken to Area 2 or 3.
E Table 1 This table holds supplies for sample processing.
F Table 2 Prepared samples are placed here to await transport.
G Intermediate Used to hold additional processed samples if needed.
Storage
Q 11. Arrange supplies in the work zones in such a way as to minimize the possibility
of contamination prior to use.
Q 12. Perform and document an area survey prior to the arrival of samples, using an
area survey/decontamination form.
A2. Contamination Control Oversight
During routine operations, this will usually be the sole responsibility of the Radiation Safety
Officer (RSO). During an incident response, the RSO will require sustained assistance to manage
the stepped up frequency of monitoring and controls and associated paperwork. The personnel
assigned to this support function will need to have their specific responsibilities identified, and
be trained for those responsibilities and separate procedures to guide them in performing those
tasks. The description of a survey team and an excerpt of a procedure are included here as
examples. Note that the procedural excerpt has numbered steps indicating that these are to be
followed sequentially.
A.2.1 Survey Team
Survey teams will be formed and assigned as needed. Staff members on duty but not assigned to
a specific work area (except the runner) will normally be the first choice. Sample receiving teams
may be designated a survey team following closeout of receiving operations provided the next
receiving team is on duty. Survey teams will not be designated in the event of short staffing.
Responsibilities of the survey team are to:
1. Be on call through the RSO and/or Emergency Response Center (ERC).
2. Conduct area contamination surveys as directed by the RSO.
3. Take wipes in areas of suspected contamination.
4. Analyze wipes using survey meters, gross alpha/beta counters, or liquid scintillation
counters, or deliver them to the sample preparation room for gamma spectral analysis, as
directed by the RSO.
5. Perform decontamination and cleanup as directed by the RSO.
6. Assist with personnel surveys and decontamination as needed.
7. Place and collect area dosimeters as directed by the RSO.
8. Complete appropriate documentation for above activities.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
A.2.2 Area Wipe Sampling - A Procedure
The laboratory will be processing samples that have significantly higher levels of radioactivity in
them than the laboratory is accustomed to handling. Therefore, it is imperative that every effort
be made to restrict the possible spread of contamination. A wipe test in conjunction with area
surveys is a tool in this effort. The standard 100-cm2 wipe area will be used when documenting
that a laboratory area has been successfully checked for contamination or decontaminated.
Wipe samples may be analyzed using either a count rate meter or the laboratory's instrumenta-
tion. The initial wipe analysis will typically be looking for gamma-emitting contamination. This
should be followed by analysis for gross alpha and beta contamination. Use the following
instructions (note that these should be performed in sequence, as indicated):
1. Place a clean glove on the hand that will be used to take the wipe.
2. For wipes to be analyzed with either a survey meter, or by gross alpha/beta counting, use
a prepared smear material. For wipes to be analyzed by liquid scintillation, use a filter
paper that is translucent to the wavelength of light emitted by the fluor in the cocktail.
3. Wipe the suspected contamination location by estimating the 100-cm2 area. If the area is
larger than about 2 ft2, at least two wipe samples should be taken.
If the wipe is taken on a bagged sample, wipe the entire bag.
If the wipe is to be taken from a piece of equipment, wipe the area where contamina-
tion is suspected.
If the wipe is from a laboratory area such as the floor or benchtop, wipe the area of
suspected contamination. Ensure that the bounds of the contaminated area are
determined.
4. Using a count rate survey meter equipped with a Geiger-Muller detector (GM) (or other
appropriate probe), count wipes in a low-background area. If the meter shows counts in
excess of twice background, the wipe is considered contaminated.
5. After each wipe has been analyzed, the wipe and glove should be disposed of simul-
taneously. These items shall be placed into either the radioactive or the non-radioactive
waste container as appropriate.
6. Occasionally survey the hand used to take the wipe to assure that no contamination is
present.
7. If using the laboratory instrumentation to analyze the wipe sample, follow the normal
standard operating procedure(s) for the instrument specified.
8. Document the results using an area survey/decontamination form.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
A3. Supplies and Equipment Checklists
A reserve supply of materials that are necessary for incident response should be purchased, used,
and restocked on a routine basis so that a rolling stock of materials is established.
The following checklist is a starting point for such supplies; each laboratory should add or delete
items from this list to fit its needs.
1. Nitric acid, concentrated, 4 1-gallon bottles
2. Hydrochloric acid, concentrated, 4 1-gallon bottles
3. Resin columns for separations (TEVA, UTEVA, SrSpec, Bio-Rad cation and
anion resins) 100 g each or 100 individual columns
4. Specific procedure reagents:
a. D BaCl2-2H2O, 1 500-g bottle
b. D TiCl3, 1 1500-mL bottle
c. D NdF3, 1 50-g bottle
d. D Sr(NO3)2, 1 100-g bottle
e. Tracer solutions:
i) D 232U (high and low activity)
ii) D 85Sr (low activity; supplier identified for rapid delivery of high
activity)
iii) D 242Pu (high and low activity)
5. Liquid scintillation cocktail, 2 1-gallon containers
6. Reserve telephone for contaminated area
7. Survey meter with appropriate probe for wipes (GM/a/P)
8. Prepared smears, or equivalent wipe material
9. Industrial vertical cutter/mixer
10. Top-loading balance (0-1,500 g x 0.01 g)
11. Contamination film for balance surface that can be peeled off (like Parafilm): 2
rolls
12. Trowels, spatulas, plastic spoons, and tampers (assorted-5 each)
13. Scissors, two or more pair
14. Razor blades, razor box knife, or scalpel
15. Forceps, assorted types and sizes, including large blunt-nosed
16. 4-mil plastic sheeting, 2 rolls
17. Versi-Dryฎ or equivalent absorbent paper, 4 rolls
18. Handi-Matฎ, or equivalent plastic bench cover
19. Masking, label, packaging, or cellophane tape
20. Hot plate, small, one per work station
21. Heat gun, heat tape, or hair dryer
22. Marking pens
23. Laboratory Nitrile gloves, 12 pair
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
24. Laboratory poly-gloves, disposable, 15 boxes
25.4-liter and 1-liter Marinelli beakers, 50 each
26. Polypropylene containers with lids, in 100-mL (Falconฎ #4014), 400-mL (Hi-
Plasฎ LT-309-16), and 800-mL sizes
27.2-inch and 4-inch stainless steel planchets, 1,000 each
28. 3.5-inch plastic Petri dishes, 500 each
29. 47-mm 0.45-|im filters, 1,000
30. Clear plastic bags, 1.5 mil, in small and medium sizes
31. Large plastic garbage bags, 4 boxes
32. Paper towels, 15 rolls
33. Sorting trays, 5 each
34. Wash bottles containing chelating detergent solution, one per work station
35. Dishwashing detergent, anionic, 2 gallons
36. Assorted dishwashing brushes
37. Spill kit
38. Hand soap
39. Calculators, one per work station
Completed: Date:
A4. Incident Response Procedures
In addition to enhanced normal procedures and ensuring that supplies are stocked, there may be
special incident response analytical procedures that are not normally performed. An example of
such a procedure is shown here for measurement of gross radioactivity on surface deposition
samples mounted on adhesive paper.
Example: Preparation of Deposition Samples on Adhesive Media During an Incident
Response
SUMMARY
This procedure is used to prepare deposition samples that have been collected on adhesive
media such as tape for analysis by gross alpha/beta counting, alpha spectrometry, or gamma
spectroscopy during an incident response. Such samples may be collected from plume fallout in
an effort to identify the nuclides involved in an event, to determine their ratios, and possibly to
provide a semi-quantitative assessment of levels.
This procedure is performed in the sample preparation room, which has been properly
prepared as a Radiological Control Area (RCA).
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
QUALITY CONTROL
1. A match between sample information listed on the sample tag and the laboratory report
sheet will be performed.
REAGENTS
1. De-ionized water
EQUIPMENT
1. 5cm stainless steel planchets
2. 3.5-inch plastic Petri dishes (Falcon #1029 or equivalent)
3. Stiff card stock, -1.5" x 2", -30-40
4. Hemostats or large, blunt-nosed forceps
5. Scalpel, razor blade, cork borer, or similar cutting tools
6. Paper, Bench-Koteฎ, or similar disposable work surface
7. Cellophane tape
8. Nu-Conฎ smears, or equivalent wipe material
9. Count rate survey meter with GM, or appropriate probe
10. Scissors
11. Fine-tipped indelible markers
12. Ruler with both inch and millimeter scales
13. 47-mm porcelain crucible lid (Coors sizeฎ 17-K)
14. Hotplate
It is expected that adhesive media deposition samples will arrive at the laboratory inside
plastic bags, with the sample material sandwiched between the adhesive side of the media and
the bag in which it has been placed. The bag must be opened and the adhesive media disengaged
from its container, then secured onto an appropriate mount with the adhesive facing upward.
PROCEDURE
1. At a workbench, carefully open the sample bag(s).
2. If the sample is to be analyzed by gamma spectroscopy only, proceed to Step 5.
3. Using hemostats or blunt-nosed forceps, remove the adhesive media from the container
by carefully peeling back the envelope or protective covering.
4. Place the media, adhesive side up, onto a clean paper.
5. Cut a circular piece of the media - 47 mm in diameter using a scalpel, razor blade, or
appropriate tool.
6. Mount the 47-mm piece of media in a counting geometry:
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
a. If the sample will be analyzed only by alpha spectrometry, mount the media
adhesive side up onto a piece of stiff card-stock. Use a small piece of cellophane
tape to secure it at both ends. Record the laboratory number on the card.
b. If the sample will be analyzed by gross alpha/beta counting or gamma spectrometry,
mount the media adhesive side up in a planchet, labeled with the laboratory number.
Use a small piece of tape or O-ring to secure it.
Wipe the outside of the planchet with a clean paper towel that has been
moistened with de-ionized water.
7. Measure the length and width (or radius) of the mounted sample. Record these
measurements, calculate the area, and list it as the sample size on the laboratory report
sheet.
8. Wipe the outer sides and bottom of the planchet, or the bottom and ends of the card-
stock, with a prepared smear.
9. Count the wipe with a survey meter. If surface contamination is evident, change gloves
and re-mount the sample on a clean holder.
10. If surface contamination is not evident, place the mounted sample into a 4-inch plastic
Petri dish.
11. Count the sample with a survey meter, probe !/2-inch away from the media, and record
the count rate on the laboratory sheet.
12. Place the lid on the Petri dish, write a "C" on the lid with a fine-tipped indelible marker,
and send the sample along with its Laboratory Report Sheet to the counting room.
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
APPENDIX B: LABORATORY CAPACITY-LIMITING FACTOR ANALYSIS
Table Bl is a simplified example of one approach that could be used to evaluate a laboratory's
capacity. The evaluation is meant to identify a laboratory's capacity to analyze samples that
could arrive tomorrow (or next week) without much time to make significant changes to
operations. It also is designed to identify areas where relatively minor tweaks might be possible
that would increase a laboratory's capacity in a targeted area.
The methodology for the evaluation is relatively simple. An assumption can be made first of an
infinite demand for a test/matrix combination, thus providing effectively a continuous stream of
incoming samples. Next, by assuming that all available resources will be concentrated on that
test/matrix combination, the limiting steps in the process that bound the maximum absolute
capacity for that test can be identified. For each test/matrix combination, estimates are made of
the maximum throughput possible for that step in the process based on the incident-specific
MQOs. These MQOs may be those found in Radiological Laboratory Sample Analysis Guide for
Incidents of National Significance-Radionuclides in Water (EPA 2008) or Radiological
Laboratory Sample Analysis Guide for Incidents of National Significance-Radionuclides in Air
(EPA 2009b), or may be developed by the laboratory. This permits the capacity-limiting step in
the production process to be identified. The throughput estimate based on this capacity-limiting
step can then be used to judge the quantity of operational resources needed to maintain
throughput at this maximum. Clearly, laboratories do not generally operate at their absolute
maximum over a longer period of time. During an incident response, however, they may be
asked to do exactly that for a given set of capabilities. Of course, this evaluation will be only as
realistic as the individual estimates the laboratory is able to make about its capacity.
The first column in the example shows the areas for which throughput estimates are to be made.
To be realistic, the analysis should include every part of the process. Mapping the laboratory's
process might be a good way to populate this column. It may be advisable (and quicker) to start
with relatively fewer (larger) areas and then to subdivide those areas if it becomes obvious that
more detail is needed to permit a realistic analysis. The laboratory will also notice that certain
functions are common to multiple tests (e.g., receiving a soil sample is the same regardless of the
analysis to be performed) and that these functions will need to be evaluated only once and may
be then applied to multiple analyses.
The second column ("Current Maximum - Samples/Day") is used to evaluate the current
maximum capacity using available resources and staff. It is common to find that staff very often
(but not always) turns out to be the limiting factor to a laboratory's capacity. This reflects current
needs more than it does the laboratory's potential to perform in a given area. This step in the
evaluation will be most realistic if the laboratory realistically takes known competing demands
for resources into account. For example, if there is a base load of analyses that the laboratory
assumes will always be present and must be performed and will thus compete for resources with
the analysis in question, a portion of the preparation space and equipment, the instrument time,
or the trained personnel will not be available for other purposes. Only the unused resources
should be considered to be available for this analysis. These estimates of capacity should be for a
longer-term surge (e.g., months to a year in duration). It is important to avoid double counting
personnel or other resources. The simplest way to do this is to consider exactly which resources
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
could be allocated to a given area over the long term without having other work go undone. It
could be assumed, for example, that a facility is 100% cross-trained. Allocating 100% of the staff
to a single task would prevent any other task from being completed for the next year. Instead, it
is important to make sure that all tasks from receiving of samples to transmission of the report to
the Incident Commander are covered.
The third column ("Max. Samples/Day - Not Staff Limited") looks beyond current staffing
limitations to the absolute potential for throughput given the facility, equipment, instrumentation,
and procedures. The same considerations discussed above apply here, except that the restraint of
staff has been removed. Some of the subcategory results may seem extremely (absurdly) high.
For example, one might be able to aliquant many more samples that one could ever process. This
is not a concern, however. Since the point of this exercise is to look for the limiting factor(s), a
large number indicates that the step is not limiting. By the same token, there is no real reason to
spend a lot of time estimating factors that are obviously not going to be limiting.
Table Bl - Example Laboratory Factor Analysis
Area/Operation
Receipt/Log-in
Rad Screen Prep
Rad Screen Count
Sample prep
Digestions
Separations
Source Prep
Counting
Calculation/Review
Reporting/Review
Am-241inSoil
0
PI ^
jj ii
"2 "B
"S ง
H
o
170
75
170
25
48
50
80
96
160
120
i
,B"B
J 1
a ,2
^ M
1 ^
320
240
170
75
144
150
240
144
400
400
00
.g
j
Staff/Work
stations
Staff/Hoods
Count
time
Staff/
Grinding
Staff/
Microwave
vessels
Staff/
Vacuum
Box
Staff/ Vac.
manifold
Count
time
Staff/Work
stations
Staff/Copy
scanning
Sr-90 in Soil
0
g ^5
"2 "B
"3 ง
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Guide for Laboratories Core Operations for Radiological or Nuclear Incident Response
have been included in the analysis but were omitted. Competition for any of these factors might
potentially require re-evaluation or adjustment of the results. There might be a need to group
factors differently, or to break factors into subcategories to help understand what is truly
limiting. Common sense should be used to assess the results, and make adjustments as deemed
realistic.
Once the limiting point is identified, it can be used to support planning purposes. The limiting
factors should also be evaluated to determine whether taking action to address one or more
limiting factors could rapidly and economically increase capacity for the test in question in the
case of an incident - or even for current operations.
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