United States
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Guide for Development of Sample
Collection Plans for Radiochemical
Analytes in Outdoor Building and
Infrastructure Materials Following
Homeland Security Incidents
June 2020
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Cincinnati, OH 45268
United States Environmental Protection Agency
Office of Research and Development
Homeland Security Research Program
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Acknowledgements
This document was developed by the U.S. Environmental Protection Agency's (EPA) Homeland
Security Research Program (HSRP) within EPA's Office of Research and Development, as a
companion to EPA's Selected Analytical Methods for Environmental Remediation and Recovery
(SAM) 2017 (EPA/600/R-17/356). Kathy Hall (EPA's Center for Environmental Solutions and
Emergency Response) was the project lead.
Special acknowledgement and appreciation are extended to the following individuals for their
valuable support and input:
Tim Boe, EPA Center for Environmental Solutions and Emergency Response
Michael Clark, EPA National Analytical Radiation Environmental Laboratory
Shannon Dettmer, Ohio Department of Health, Bureau of Environmental Health and
Radiation Protection
John Griggs, EPA National Analytical Radiation Environmental Laboratory
Mark Hannant, Illinois Emergency Management Agency, Division of Nuclear Safety
Scott Hudson, EPA Chemical, Biological, Radiological and Nuclear Consequence
Management Advisory Division
Lyndsey Nguyen, EPA Environmental Response Team
Kathryn Snead, EPA Office of Radiation and Indoor Air
Anna Tschursin, EPA Office of Land and Emergency Management
Terry Stillman, EPA Region 4
Technical and editorial support were also provided by Joan Cuddeback, Emily King, Robert
Rosson, Marti Sinclair and Larry Umbaugh (of CSRA), under EPA Contract EP-C-15-012.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Disclaimer
This document has been reviewed in accordance with U.S. Environmental Protection Agency
policy and approved for publication. Any mention of trade names, manufacturers or products
does not imply an endorsement by the United States Government or the U.S. Environmental
Protection Agency. EPA and its employees do not endorse any commercial products, services,
or enterprises.
Questions concerning this document, or its application, should be addressed to:
Kathy Hall
Center for Environmental Solutions and Emergency Response (CESER)
Homeland Security & Materials Management Division
Disaster Characterization Branch
Office of Research and Development (NG16)
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, OH 45268
(513) 379-5260
hall.kathv@epa.gov
Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions leading to a compatible balance between
human activities and the ability of natural systems to support and nurture life. To meet this
mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage
our ecological resources wisely, understand how pollutants affect our health, and prevent or
reduce environmental risks in the future.
The Center for Environmental Solutions and Emergency Response (CESER) within the Office of
Research and Development (ORD) conducts applied, stakeholder-driven research and provides
responsive technical support to help solve the Nation's environmental challenges. The Center's
research focuses on innovative approaches to address environmental challenges associated
with the built environment. We develop technologies and decision-support tools to help
safeguard public water systems and groundwater, guide sustainable materials management,
remediate sites from traditional contamination sources and emerging environmental stressors,
and address potential threats from terrorism and natural disasters. CESER collaborates with
both public and private sector partners to foster technologies that improve the effectiveness and
reduce the cost of compliance, while anticipating emerging problems. We provide technical
support to EPA regions and programs, states, tribal nations, and federal partners, and serve as
the interagency liaison for EPA in homeland security research and technology. The Center is a
leader in providing scientific solutions to protect human health and the environment.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Acronyms and Abbreviations
CFR Code of Federal Regulations
COC chain of custody
DCGL Derived Concentration Guideline Level
DOE U.S. Department of Energy
DQO data quality objective
ERLN Environmental Response Laboratory Network
EPA U.S. Environmental Protection Agency
FRMAC Federal Radiological Monitoring and Assessment Center
HASP Health and Safety Plan
HSRP Homeland Security Research Program
I ATA International Air Transportation Association
MARLAP Multi-Agency Radiological Laboratory Analytical Protocols Manual
MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual
MQO measurement quality objective
NIST National Institute of Standards and Technology
PAG(s) Protective Action Guide(s)
QA quality assurance
QAPP Quality Assurance Project Plan
QC quality control
RCRA Resource Conservation and Recovery Act
RSP Radiation Safety Plan
SAM Selected Analytical Methods for Environmental Remediation and
Recovery (SAM) 2017
SCP Sample Collection Plan
SOP Standard Operating Procedure
SOW Statement of Work
WMP Waste Management Plan
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Table of Contents
ACKNOWLEDGEMENTS I
DISCLAIMER II
ACRONYMS AND ABBREVIATIONS Ill
1.0 INTRODUCTION 1
2.0 OVERVIEW OF THE SCP DEVELOPMENT PROCESS 2
2.1 Step I - Data Acquisition and Requirements Determination 4
2.2 Step II - SCP Design and Development 4
2.3 Step III-SCP Implementation 4
3.0 STEP I - SCP DATA ACQUISITION AND REQUIREMENTS DETERMINATION 5
3.1 Data Quality Objectives (DQOs) and Quality Assurance Project Plan (QAPP) 7
3.2 Health and Safety Plans 8
3.3 Waste Management Plan 8
3.4 Initial Site Information 9
3.5 Characterize Real Property Radiological Contaminants 10
3.6 Identify Contaminated Areas 10
3.7 Identify Contaminated Media 11
4.0 STEP II - SCP DESIGN AND DEVELOPMENT 11
4.1 Review of Successful Sampling Plans 14
4.2 Defining Radioanalytical Laboratory Requirements for SCP Sample Analysis ...14
4.3 Classify Areas by Contamination Potential 16
4.4 Select Background Reference Materials 16
4.5 Identify Survey Units 16
4.6 Develop a Conceptual Cleanup Model of the Site for SCP Planning 17
4.7 Selection of Sampling Designs 17
4.8 Writing the SCP - Content of Major Elements 25
4.8.1 Project Background 25
4.8.2 Project Organization and Responsibilities 26
4.8.3 Project Scope and Objectives 26
4.8.4 Non-Measurement Data Acquisition 26
4.8.5 Field Activities - Project Sample Collection Procedures 26
4.8.6 Radiological Field Measurements and Equipment 27
4.8.7 Sampling Operations Documentation 27
4.8.8 Sample Packaging and Shipping Requirements 28
4.8.9 Sampling Waste 28
4.8.10 Project Quality Assurance (QA) 29
4.8.11 Non-Conformance/Corrective Actions 29
4.8.12 SCP Appendices 30
4.9 SCP Review and Approval 30
4.10 SCP Distribution 31
5.0 STEP III - SCP IMPLEMENTATION 31
5.1 Personnel Training 33
5.2 Field Sample Collection 33
5.3 Project Liaison 33
5.4 SCP Compliance Monitoring 33
5.4.1 Project, Field, and Laboratory Audits 33
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5.4.2 Project Activity Reports 34
5.5 Site Disposition 34
6.0 REFERENCES AND ADDITIONAL RESOURCES 35
APPENDIX A A-1
Figures
Figure 2.1. Sample Collection Plan (SCP) - Overview 3
Figure 3.1. Step I - SCP Data Acquisition & Requirements Determination 6
Figure 4.1. Step II - SCP Design and Development 12
Figure 4.2. Simple Random Sampling 18
Figure 4.3a Stratified Sampling - Asphalt Surface 19
Figure 4.3b Stratified Sampling - Building Fa?ade 19
Figure 4.4. Systematic/Grid Sampling 20
Figure 4.5. Adaptive Cluster Sampling 21
Figure 4.6. Composite Sampling 22
Figure 5.1. Step III - SCP Implementation 32
Tables
Table 4-1 Comparison of Sampling Designs 22
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
1.0 Introduction
This document provides a framework for developing and implementing an approach to
collection of outdoor building and infrastructure material samples during site cleanup
after an intentional or unintentional homeland security-related radiological contamination
incident. Examples of outdoor building and infrastructure materials include concrete,
brick, asphalt, limestone, granite, stucco and wood. This framework is designed to assist
incident commanders, project managers, state and local authorities, contractors, and
enforcement divisions responsible for the sample collection approach.
The information in this document is intended for use by individuals responsible for
collection of samples in support of EPA remediation and recovery efforts following an
intentional or accidental homeland security-related contamination incident. The
information in this document can be used to develop a systematic and integrated
methodology for sample collection that will meet data use needs and site disposition
objectives. This document incorporates processes that include quantitative and
qualitative assessments at each stage of cleanup decision making: from initial scoping
and stakeholder outreach, to evaluation of cleanup options and implementation of the
chosen alternative.
It is projected that, following initial site investigation and response under the Federal
Radiological Monitoring and Assessment Center (FRMAC), coordination of the
remediation of contaminated sites will be turned over by the U.S. Department of Energy
(DOE) to the U.S. Environmental Protection Agency (EPA) for cleanup. According to
FRMAC (FRMAC 2009), each radiological contamination incident is unique and the DOE
FRMAC director and senior EPA representative, in cooperation with coordinating agency
and affected state(s), will determine when it is beneficial and appropriate to initiate a
transfer of control from DOE to EPA. According to FRMAC guidance, the following five
criteria are met for this transfer to occur:
the immediate emergency condition is stabilized
offsite releases of radioactive material have ceased, and there is little or no
potential for further unintentional off-site releases
the offsite radiological conditions are evaluated and the immediate
consequences are assessed
an initial long-range monitoring plan has been developed in conjunction with the
affected state, tribal and local governments, and appropriate federal agencies
EPA has received adequate assurances from the other federal agencies that
they are committing the required resources, personnel and funds for the duration
of the federal response
The elements in this EPA document provide a general guide for preparation of homeland
security incident-specific Sample Collection Plans (SCPs). The SCPs are needed for
collection of data once a contaminated site has been turned over to EPA and must be in
compliance with EPA requirements regarding quality assurance (QA), quality control
(QC) and data quality objectives (DQOs). Additional guides may be issued to clarify or
amend the traditional cleanup protocols. The elements can be used to develop SCPs for
building and/or infrastructure investigation, characterization, cleanup, and final status
surveys to release the building and/or infrastructure, or to support decision making for
the final disposition of the contaminated structures. It is assumed that the number of
SCPs required, and the details contained within each, is dependent on the number, size
and complexity of the specific contaminated structures.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
This document is not intended for use in developing the following documents, which are
required for each project/site in addition to an SCP:
Quality Assurance Project Plan (QAPP)
Radiation Safety Plan (RSP) and associated procedures
Health and Safety Plan (HASP)and associated procedures
Waste Management Plan (WMP)
The information in this document is intended to apply only to the development of SCPs
for cleanup of outdoor building and infrastructure materials contaminated with
radioactivity following a homeland security-related incident. EPA's Selected Analytical
Methods for Environmental Remediation and Recovery (SAM) 20171 (EPA 2017b)
should be reviewed for analytical methods to be used during laboratory analysis of
samples. EPA's Sample Collection Procedures for Radiochemical Analytes in Outdoor
Building and Infrastructure Materials (EPA 2016) should be reviewed for information
regarding specific sample collection procedures and equipment. If additional
contamination is present (e.g., unexploded ordnance, chemical warfare agents,
biological wastes, hazardous chemical waste, and/or mixed waste), additional direction
will be required, and it will be necessary to develop an SCP that includes information on
how to handle these materials.
NOTE: The Multi-Agency Radiation Survey and Site Investigation Manual
(MARSSIM 2000) is cited several times throughout this document, as a resource for
additional information and guidance. The manual was developed collaboratively by
the EPA, U.S. Department of Defense, U.S. Department of Energy, and Nuclear
Regulatory Commission. It provides information on planning, conducting, evaluating
and documenting final status radiological surveys. Although the information in
MARSSIM is valuable, its introduction acknowledges the site- and incident-specific
nature of contamination incidents, stating that the approaches described may not
meet the data quality objectives (DQOs) corresponding to a given site. Readers of
this guidance document are encouraged to consult MARSSIM (2000) and other
resources cited, while considering site- and incident-specific needs and
requirements.
2.0 Overview of the SCP Development Process
Figure 2.1 provides a flowchart of major SCP developmental elements and the general
processes of project needs' determination through development of sample collection
plans and eventual disposition of the contaminated structure(s). The general steps of
this process are presented in Figure 2.1. Specific SCP elements are described in this
document for each step, and the user is encouraged to review the flowchart for each
step. Other elements, as determined in relevant documents listed in Section 6.0, may
also be included in the SCP development process.
1 EPA's Selected Analytical Methods for Environmental Remediation and Recovery (SAM) 2017 (EPA 2017b) and its
methods can be found at https://www.epa.gov/esam/selected-analvtical-methods-environmental-remediation-
and-recoverv-sam
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 2.1. Sample Collection Plan (SCP) - Overview
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
2.1 Step I - Data Acquisition and Requirements Determination
Before preparing an SCP, the project should assemble a core SCP design team. Team
members may include, but are not limited to:
Risk assessors
Statisticians
Technical planners
Health physicists
Radiochemists
Civil engineers
Radiological engineers
Health and safety specialists
Construction specialists
Public and media relations specialists
Regulatory specialists
State and local subject matter experts
Legal specialists
Incident commanders
On-scene coordinators
The SCP design team must review the information provided in the Step I section (see
Section 3.0), and perform a thorough review of all appropriate documents, including any
existing Statements of Work (SOWs), Quality Assurance Project Plans (QAPPs),
DQOs, Health and Safety Plans (HASPs), Radiation Safety Plans (RSPs), Waste
Management Plans (WMPs), or specifications regarding the impending cleanup effort
and disposition decisions. In some cases, the information included in these documents
can be prepared along with, and/or incorporated into the SCP.
2.2 Step II - SCP Design and Development
The SCP design team gathers the information obtained in Step I and prepares the SCP
prior to any field activities. The SCP will likely be amended or revised several times
during cleanup, and these amendments or revisions approved by the incident
commander and/or project lead. For each SCP developed, the format and content
should be consistent with this document, regardless of the size of the project. Section
4.0 describes the general format and content considerations for an SCP. Appendix A
lists the typical elements that should appear in the SCP. Specific elements that should
be included will depend on the size and/or complexity of the cleanup project, and the
SCP format should be modified as appropriate. A good working knowledge of these
elements is necessary to understand the type of information required and to determine if
additional sources of information are needed.
2.3 Step III - SCP Implementation
An EPA approved and cleared SCP, from the Step II process, must be in place before
data collection activities commence. As noted above, this SCP may be revised or
amended throughout site cleanup, as appropriate, to reflect the results of in-situ and
laboratory data collection throughout site remediation. Depending on the data collected
and the need for efficiency, data from earlier phases of site remediation that meet project
DQOs also can be used to meet data requirements in subsequent phases. All SCP
activities must be performed in compliance with the approved/cleared SCP and should
be monitored and verified throughout implementation (See Section 5.0).
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
While data collection activities are being performed, SCP compliance is monitored by
field, desk and laboratory audits. SCP defined QA elements (i.e., field and laboratory QC
samples, data assessment procedures) are also monitored to ensure SCP compliance.
QA audits of the SCP must conform to requirements set in the QAPP.
When all of the SCP activities are completed, an evaluation is made by the incident
commander and/or project lead, to determine if the sampling goals and objectives have
been met. If the goals and objectives have not been met, the SCP is reevaluated by
returning to Step II.
3.0 Step I - SCP Data Acquisition and Requirements Determination
To prepare an SCP, it is necessary to understand all requirements that are or will be
included in the project DQOs2 and QAPPs, and the site-specific requirements included in
the project's HASP, RSP and WMP, as shown in Figure 3.1. SCP developers also must
consider all available existing information regarding the specific building(s) and/or
infrastructure, and the project, including data collected during the initial response phase
of the incident.
SCP developers should consult with the response team to obtain information collected
during the initial phase. As time permits, the team should review data from previous
investigations, and/or information regarding site constraints (e.g., site accessibility due to
physical or legal limitations, supporting infrastructure availability). Before preparing an
SCP, developers should perform a thorough review of information included in all
appropriate existing project documents, including any SOWs, QAPPs, DQOs, HASPs,
RSPs, WMPs or specifications regarding the project or containing project planning
results.
The level of specificity outlined within these project documents may vary from outlining
general project goals to specifying sampling and analytical requirements to meet project
DQOs. Project documents should identify additional applicable references that might be
required for obtaining background information, including (but not limited to):
Engineering regulations and guidance documents
Regulatory program and status reports from previous investigations
Construction data
Ownership/operational histories
Site maps, drawings and photographs
Information on regional meteorological data
Current and future building/infrastructure use
2 DQOs and Guidance on Systematic Planning Using DQOs are provided in EPA's Guidance on Systematic Planning
Using the Data Quality Objectives Process, EPA QA/G-4 (EPA 2006), found at:
https://www.epa.gov/qualitv/guidance-svstematic-planning-using-data-qualitv-obiectives-process-epa-qag-4
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 3.1. Step I - SCP Data Acquisition & Requirements Determination
Data Quality Objectives
(DQOs)
Quality Assurance Project
Plan (QAPP)
Radiological Safety Plans
Health and Safely Plans
Waste Management Plans
To Step II
SCP Design
and Development
Initial Information
Preliminary Site Assessment
Site Reconnaissance
Event Cleanup Actions
Engineering Evaluations
Cost Analysis
Historic Assessments and
Investigations
Initial Corrective Actions
Identify Radiological
Contaminants and Chemical Form
Identity Contaminated Areas
Identify Contaminated Materials
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
3.1 Data Quality Objectives (DQOs) and Quality Assurance Project Plan (QAPP)
According to EPA policy, systematic planning must be used to develop acceptance or
performance criteria for collection, evaluation or use of environmental data. Systematic
planning identifies the expected outcome of the project, technical goals, cost and
schedule, and the acceptance criteria for the final result, which must be documented in a
QAPP. As defined in the Code of Federal Regulations (CFR) at 40 CFR 300.430 (40
CFR), the QAPP describes policy, organization, and functional activities, as well as the
DQOs and measures necessary to achieve adequate data. The QAPP is a plan that
provides a process for obtaining data of sufficient quality and quantity to satisfy data
needs. In some cases, information contained in the QAPP is also included in the SCP; in
these cases, the information must be consistent between the two documents.
The development of a QAPP can either be concurrent and combined with the
development of the SCP or separate from the SCP, but it is essential in defining project
DQOs and activities needed to ensure that project quality criteria are met. A site-specific
QAPP is usually developed in parallel with the development of an SCP. Information
pertaining to the preparation of a project-specific QAPP can be found in:
Guidance for Quality Assurance Project Plans (EPA 2002a)
EPA Requirements for Quality Assurance Project Plans (EPA 2001)
Project managers and planners should also review information regarding the DQO
process provided in:
Guidance on Systematic Planning Using the Data Quality Objectives Process
(EPA 2006)
Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM 2000)
Intergovernmental Data Quality Task Force's Uniform Federal Policy for Quality
Assurance Project Plans (IDQTF 2005)
Specific QAPP DQO elements related to collection of data for EPA use include:
Measurement quality objectives (MQOs)3.
Cleanup goals, cleanup options, and establishment of remediation levels.
[NOTE: MARSSIM should be consulted to gain a thorough knowledge of
remediation levels, or Derived Concentration Guideline Levels (DCGLs) and how
they are interconnected to the SCP and the DQOs of the QAPP.]
Identification of survey units and boundaries, along with acceptable levels of
spatial accuracy (e.g., drift).
Data assessment, including data quality indicators for precision, bias,
completeness, representativeness, reproducibility, comparability, sensitivity and
statistical confidence.
Data verification and validation.
Data management.
3 Measurement quality objectives (MQOs) are characteristics of a measurement method required to meet the
objectives of the survey including required measurement method uncertainty, detection capability, quantification
capability, expected concentration range for a radionuclide of concern, specificity, and ruggedness (MARSAME
2009).
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
3.2 Health and Safety Plans
Safety is a primary consideration in any sampling event and is a critical consideration
during development of an SCP. Personnel safety requirements and considerations for a
particular building or infrastructure may extend beyond radiological concerns and may
include physical hazards or chemicals that are toxic, corrosive, emit harmful or explosive
vapors, or are incompatible when mixed. The SCP must be consistent with all radiation
and industrial safety requirements and procedures associated with a site. The SCP also
must include or reference site-specific personnel safety and protection plans for radiation
and industrial health/safety.
Radiation protection requirements included in the site RSP are developed and
implemented by the site radiation protection group, which is responsible for:
Developing and implementing an RSP and radiation work plans for individuals
working at the site
Taking measurements of the radiation levels of all sampling sites and during
sampling activities
Dictating the radiation protection requirements for entering and working in a
radioactively contaminated sampling area
Stopping any activity to protect personnel from overexposure to radiation or from
radioactive material contamination associated with the activity
Industrial safety requirements included in the site HASP are developed and instituted by
a designated safety individual (e.g., safety and health officer) who is responsible for:
Developing and implementing a HASP and safety work plans
Assessing all site activities for potential safety concerns
Ensuring that personnel are informed as to the potential hazards in a sampling area
and dictating the requirements for safely working at the site
Stopping any job or activity to protect personnel from a dangerous situation
3.3 Waste Management Plan
Ideally, a general WMP will be in place prior to the incident, outlining waste management
requirements, procedures, strategies and processes, from the point of generation to final
disposition. This general WMP can be used by the incident commander and/or project
manager to prepare an incident-specific WMP. This incident-specific plan should
address federal (e.g., Resource Conservation and Recovery Act [RCRA]), state and
local waste management requirements for the different waste streams; state and/or
facility waste disposal agreements; waste characterization and waste acceptance
sampling and analysis; identification of waste staging locations; identification of waste
management facilities; on-site waste management and minimization strategies and
tactics; off-site waste management; waste transportation; and health and safety; as well
as tracking and reporting of waste sampling results. Additional details regarding the
elements of a WMP are provided in Appendix D of EPA's Sample Collection Procedures
for Radiochemical Analytes in Outdoor Building and Infrastructure Materials (EPA 2016).
Samplers and planners also can refer to EPA's Waste Management Options for
Homeland Security Incidents website for information on regulations and guidance to
support decision-making regarding waste treatment and disposal.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
3.4 Initial Site Information
When a site is transferred to the EPA for cleanup, under FRMAC, detailed response-
stage investigation data should be available for review and use in planning the cleanup.
In general, the information will detail how the investigation was conducted, will identify
contamination boundaries, and will detail contamination gradients, as necessary. This
information is critical for designing an appropriate and successful SCP that is consistent
with the site investigation. The detailed information provided under FRMAC might
include:
Preliminary site assessment information and data, along with indicators regarding the
quality of the data
Identification of contaminated building(s) and/or infrastructure
Any initial corrective cleanup actions performed to secure and control the effected
building(s) and/or infrastructure (e.g., fire hosing)
Identification of radiological contaminants, and the contaminated outdoor building
and/or infrastructure materials
Contamination deposition profiles comparable to background levels
Meteorological data
Information and data generated during engineering evaluations and cost analyses can
be used to supplement data typically provided by FRMAC for use in designing a SCP.
If detailed response data/information is not available when a site is turned over to the
EPA, as might be the case following a homeland security-related incident, the
information provided in this document would enable the planning team to develop an
SCP for site investigation and characterization, cleanup, final status survey, and
disposition. An historical site assessment or operational history, if applicable, could also
be performed or obtained to identify areas of concern or to identify liability from historical
or current use of radiological substances (see MARSSIM, Chapter 3). Information that
tracks these uses should be collected, and includes:
Existing Radiation Data Prior to the Contamination Incident Review of
applicable documents and records to determine if any information is available, via
public records, regarding potential pre-existing radiological contamination.
Interviews/Questionnaires Interviews or questionnaires with current owner(s),
manager(s) or other responsible parties, local government officials, and residents to
obtain as much information as possible regarding the building/infrastructure and any
operations and activities that occurred that might have included the use of
radionuclides. Included in this inquiry would be past and present improvements or
alterations, operations, and plans for future use.
Site Reconnaissance A site visit or inspection to observe current uses (and
evidence of past uses, when possible), including those likely to involve the use,
treatment, storage, disposal or generation of radioactive materials. In some cases, a
site access agreement may be needed prior to initiating remediation activities.
Evaluation of Data A written report to document initial investigation findings,
observations and recommendations, including suspected or identified areas of
radiological concern or liability, and what sampling and analyses activities were
conducted to verify the suspected areas of contamination.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
3.5 Characterize Real Property Radiological Contaminants
Once potential areas of concern or contamination are identified and evaluated, an SCP
strategy is developed so that sufficient data can be obtained to allow a designated
individual or group to conclude that the contaminant(s) of concern:
Is present at levels above the cleanup goals and cleanup is necessary, or
Is present at levels below the cleanup goals and no further action is required
3.6 Identify Contaminated Areas
Prior to cleanup following initial response, affected and unaffected buildings, as well as
infrastructure, will need to be assessed to identify the type, degree and extent of
contamination. Sample collection and analysis, as well as in-situ measurements, will be
required to support this assessment. Buildings and infrastructure in areas that have no
reasonable potential for contamination may not need any level of sampling and can be
designated as non-impacted.
FRMAC (Sandia 2010) defines this assessment as the evaluation and interpretation of
radiological conditions following a radiological emergency, in terms of the Protective
Action Guides (PAGs), which are described in FRMAC Assessment Manual Overview
and Methods Volume 1 (Sandia 2015). EPA developed PAGs to help responders plan
for radiation emergencies (PAG Manual: Protective Action Guides and Planning
Guidance for Radiological Incidents (EPA 2017).
Determination of cleanup actions will rely on initial post-incident measurements and
model predictions. Initial measurements from first responders and FRMAC teams will be
used in SCP development effort to identify the specific areas of contamination. This
information includes:
Outdoor building/infrastructure survey measurements
Radiological aerial and ground survey data
Laboratory analyses of various representative samples (e.g., concrete, brick, asphalt
matrices, limestone, granite, stucco, wood)
Meteorological information
Models (plume dispersion area, deposition rates, and re-suspension probabilities)
It should be noted that the initial assessment models and cleanup goals might be
modified after the results of detailed radiological characterization are gathered.
Prior to cleanup actions, information garnered from FRMAC is coupled with data
obtained from historic information (local public, corporate, and governmental
information). This information is used to identify areas where contamination could have
spread or areas that might affect the actions for cleanup of the area. Examples of
historic information to examine include:
Infrastructure support systems data (water, cable, electric, and sewer systems,
underground transport or other types of pipe chases or transport facilities)
Geological and geographical data that could impact cleanup activities (e.g., location
of the water table)
Documentation of locations where radioactive materials were used, stored, or
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
disposed of prior to the contamination incident (e.g., radioisotopes used by medical
professionals, radiological sources used by industries, contaminated backfill
material)
Records, such as news articles or local emergency responder reports that indicate
unusual occurrences that could have resulted in the additional spread of
contamination
Areas immediately surrounding or adjacent to the affected building(s) and/or
infrastructure are included in the identification of contaminated areas because of the
potential for inadvertent spread of contamination (e.g., due to airborne re-suspension,
rainfall, initial response activities).
3.7 Identify Contaminated Media
The next step in evaluating the data gathered is to identify potentially contaminated
outdoor building and infrastructure media. Direct in-situ readings from radiological
surveys can identify materials that have the potential to contain residual contamination
or materials that do not contain residual contamination. The results of the direct readings
can be used for preliminary classification and planning subsequent SCP sampling
activities. The evaluation will result in a finding of either "Suspected Contamination" or
"No Suspected Contamination," which may be based on analytical data, professional
judgment, or a combination of the two. Results also affect several decisions supporting
SCP development, including decisions as to the sampling and analysis techniques that
will be used, survey unit determinations, sample sizes, containers, and field equipment.
4.0 Step II - SCP Design and Development
The information and documents gathered and generated during Step I are used to
design and develop the project SCP as shown in Figure 4.1. SCPs are designed to lay
out and describe project requirements for conducting and completing sampling activities,
corresponding data assessment activities, and reporting requirements. Elements that are
included in an SCP are listed in Appendix A and described in detail in this section.
Specific elements that should be included will depend on the size and/or complexity of
the cleanup project, and the SCP format should be modified as appropriate. The SCP is
prepared and approved prior to initiation of any sampling activities and is expected to be
amended or revised several times during cleanup, as appropriate, to reflect the results of
data collection throughout site remediation.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 4.1 Step II - SCP Design and Development
From Phase I
SCP Data Acquisition
&
Requirements
Prior to initiation of SCP design, the decision maker(s) and sample collection planning
team should review the information in any existing QAPP and corresponding DQOs,
from Step I, to identify the data needs and purpose for sample collection(s), including:
Location of building(s) and/or infrastructure to be sampled, specific sampling
locations, and sampling frequencies
Types of samples to be collected or measurements to be performed
Target radionuclide(s)
Potential interfering radionuclides or chemical contaminants from decontamination
activities
Radiological measurements and instrumentation to support sample collection
Remediation level for each radionuclide of interest
MQOs for each radionuclide (e.g., required method uncertainty, required minimum
detectable concentration [MDC])
Analytical or screening methods that will be used in the field and laboratory to assay
samples
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Analytical bias and precision (e.g., quantitative or qualitative)
Number of samples to be collected
Type and frequency of QC samples to be collected
Amount of material to be collected for each sample
Sample tracking requirements (e.g., chain of custody [COC])
Sample packaging and shipping requirements
Additional standard operating procedures (SOPs) to be followed or developed
Cost of the methods being used (cost per analysis as well as total cost)
The use of gross field measurements
The use of laboratory surrogate measurements
Building- or infrastructure-specific background (e.g., from background reference
areas) for the radionuclide(s) of interest
Turnaround time required for sample results to maintain project schedules
Documentation requirements
For projects that encompass several buildings, infrastructures and types of materials, or
that involve a long-term effort, it may be beneficial to generate a comprehensive SCP
that includes addendums to cover all aspects of sampling and analytical requirements.
These addendums to the SCP must clearly identify the DQOs that are specific to the
target building(s)/infrastructure, applicable material matrices, sampling and analysis
requirements, and any deviations from the comprehensive SCP. Information in the
comprehensive SCP may be referenced in the SCP addendums. When this approach is
used, all addendum references to the comprehensive SCP must be verified by the
project technical planning team during the document review process. Preparatory
inspections (site audits) must ensure that all appropriate plans (comprehensive and
addendum SCPs) are available on site, and that sampling personnel are familiar with the
procedures included in both.
A separate SCP can be developed for the final status survey. Final status surveys are
performed after cleanup is complete to demonstrate that residual levels of radioactive
materials satisfy criteria for building/infrastructure disposition. These surveys provide
data to demonstrate that radiological parameters do not exceed the established
remediation levels and that DQOs have been met. Final status survey SCPs are
designed based on these objectives and the known or anticipated radiological conditions
at the site. The SCP must include an appropriate number and location of measurement
and sampling points to demonstrate compliance with the site release criteria. Planning
for a final status survey SCP should include early discussions with the appropriate
agencies concerning logistics for confirmatory surveys and sampling. Confirmatory
activities are usually limited in scope to include checking conditions at selected
locations, comparing findings with those of the final status survey, and performing
independent statistical evaluations of the data developed from the final status survey. An
independent verification survey may be performed to provide data to substantiate results
of the final status survey. Independent evaluations of final building or infrastructure
conditions are more extensive than the confirmatory activity listed above and involve
validation of the cleanup final status survey procedures, results, and documentation. The
independent verification survey is not a replacement or supplement to the final status
survey, but it serves to validate the final status survey prior to releasing the effected
buildings/infrastructure for use.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
4.1 Review of Successful Sampling Plans
When preparing an SCP, the design should match the needs of a given project with the
resources available, including personnel, time, cost and equipment. Project needs
generally consist of the cleanup objectives and tolerable limits of uncertainty. The goal of
the SCP should be to acquire and use all of the information available so that the data
collected meet the needs of the data user (i.e., decision maker).
The following is a list of some site-specific sampling plans. These sampling plans range
from complex site characterization plans to smaller sub-site project plans. All web
addresses in the following list were last accessed June 5, 2020:
Reconnaissance Level Characterization Plan for D&D Facilities, Revision 1
Reconnaissance Level Characterization Plan (RLCP) For the Rocky Flats
Environmental Technology Site (RFETS). Appendix D. D&D (Decontamination and
Decommissioning) Characterization Protocol, MAN-077-DDCP, July 2002 (RFETS
2002)
Pre-Demolition Survey Report (PDSR), Building 551 Closure Project, Rocky Flats
Environmental Technology Site. Revision 1. December 31, 2002 (RFETS 2002a)
Rocky Flats Environmental Technology Site, Type 1 Reconnaissance Level
Characterization Report (RLCR) Area 5 Group 6a Closure Projects Trailers
T130C, T130D, T130E, T130F, T130G &T130H, Revision 0, April 15, 2003 (RFETS
2003)
Battelle. Radiological Characterization and Final Status Plan for Battelle Columbus
Laboratories Decommissioning Project, West Jefferson Site," Revision 0, March
2000 (Battelle 2000)
Battelle Memorial Institute Columbus Operations Decommissioning Plan. DD-93-19,
Revision 3, August 2000 (Battelle 2000a).
Site Characterization Plan for Decontamination and Decommissioning of Buildings
3506 and 3515 at Oak Ridge National Laboratory, ORNL/ER/Sub/87-99053/69, Oak
Ridge, Tennessee, September 1993 (ORNL 1993)
4.2 Defining Radioanalytical Laboratory Requirements for SCP Sample Analysis
Early consideration of analytical capability is essential to the success of the SCP. SCPs
for large projects may indicate that more than one analytical laboratory is necessary to
meet the SCP objectives. Prior to defining radioanalytical laboratory requirements, SCP
designers should review the Multi-Agency Radiological Laboratory Analytical Protocols
Manual (MARLAP 2004), Volume 1, Chapters 5 and 7, for a detailed discussion on
obtaining laboratory services. The methods listed in SAM should be reviewed to aid in
discussions with the laboratory. The radioanalytical laboratory(s) that will perform the
analyses should be selected early in the planning process, so that they may be
consulted regarding the analytical methods to be used and to ensure sampling activities
will address the analytical needs. Designers and planners should focus on choosing a
laboratory that is a member of EPA's Environmental Response Laboratory Network
(ERLN), a national network of laboratories that can be ramped up as needed to support
large scale environmental responses. Designers must select the methods that will be
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
used to analyze samples, and design the SCP to meet the analytical needs of those
methods.
SCP designers should also consider the use of mobile laboratories to provide on-site
analytical capability and minimize off-site sample transportation, if feasible. The SCP
must identify:
Laboratories
Communications protocols between project management, field personnel and
laboratory personnel
COC requirements
Number and type(s) of samples each laboratory is expected to receive
Packaging and shipping requirements, including those specified by laboratory(ies)
Project requirements for analytical result turnaround times
SAM-approved analytical methods that will be used
Corrective action procedures for handling suspect analytical data
Requirements for documentation, reporting and project deliverables
Procurement of laboratory services usually requires a statement of work (SOW)
describing the analytical services needed. Careful preparation of the SOW is essential to
ensuring laboratories perform the required services in a technically competent and timely
manner (consult MARLAP, Volume 1, Chapters 5 and 7, for expanded details). SOWs
must be reviewed by personnel familiar with radioanalytical laboratory operations. For
complicated sampling events requiring a large number of analyses, it is recommended
that a portion of laboratory evaluations take the form of an audit. For smaller sites or
facilities, the decision maker(s) may decide that a review of the laboratory's
qualifications is sufficient. There are eight criteria that should be evaluated during this
review:
1. The laboratory should possess appropriate well-documented procedures,
instrumentation, and trained personnel to perform the analyses required to address
the DQOs (e.g., radionuclide(s) of interest and target detection limits).
2. The laboratory should be experienced in performing the same or similar analyses.
3. The laboratory should have satisfactory performance evaluation results from formal
monitoring or accreditation programs and should be able to provide a summary of
QA audits and proof of participation in inter-laboratory cross-check programs.
Equipment calibrations should be performed using National Institute of Standards
and Technology (NIST) traceable reference radionuclide standards whenever
possible.
4. The laboratory should have adequate capacity to perform all analyses within the
desired timeframe to meet project required turnaround times.
5. The laboratory possesses a radioactive material handling license or permit for the
samples to be analyzed.
6. The laboratory should provide an internal QC review plan for all generated data, and
the QC reviewers must be independent of the data generators.
7. The laboratory should have an active and fully documented QA program in place,
and the QA program should comply with the project DQOs.
8. The laboratory should have adequate protocols for method performance
documentation and sample security.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
4.3 Classify Areas by Contamination Potential
After a radiological contamination incident, affected areas of buildings and/or
infrastructure will have differing potential for contamination and, accordingly, will not
need the same level of sampling to demonstrate compliance with established cleanup
goals. The sampling process will be more efficient if the SCP is designed so that areas
with higher potential for contamination (based in part on results of the Step I
assessment) or that have a greater prioritization for reuse (e.g., residential or business
use) receive a higher degree of sampling.
Site classification is a critical step in designing the SCP. The working hypothesis of
MARSSIM is that all impacted areas that are being evaluated for release have a
reasonable potential for radioactive contamination above the DCGL. This initial
assumption means that all structures in these areas are initially considered to have the
highest potential for contamination (Class 1 areas)4 unless some basis is provided for
reclassification as either an impacted area with low potential for a dose above the
release criteria (Class 2), an impacted area with little to no potential for a dose above the
release criteria (Class 3) or a non-impacted area. Buildings and infrastructure that have
been designated as non-impacted are typically used as sources of reference materials.
4.4 Select Background Reference Materials
If a reference material is necessary, the SCP should clearly identify background
reference materials. These are located in non-impacted areas and should have
characteristics that are similar to the outdoor infrastructure or building material(s) being
sampled and evaluated for contamination. A reference material cannot contain
contamination that was introduced by the incident that is the reason for the response,
and should not be located in areas that are a part of the survey unit being evaluated.
(See MARSSIM, Chapter 4.)
If the suspected contaminant is normally present in the infrastructure or outdoor building
material (or if the measurement system used is not specific for a suspected
radionuclide), background measurements are compared to the survey unit
measurements to determine the level of residual radioactivity.
4.5 Identify Survey Units
Each survey unit is a physical area consisting of either an entire building or
infrastructure, or a portion of a building or infrastructure comprising a specified size and
shape for which a separate decision will be made as to whether or not that area exceeds
the release criterion. This decision is made as a result of the final status survey, and the
survey unit is the primary entity for demonstrating compliance with the release criterion.
The SCP must clearly define each survey unit from which samples will be collected.
(See MARSSIM, Chapter 4.)
To facilitate sample collection design and ensure that the number of sampling points are
relatively uniformly distributed among structures of similar contamination potential, the
site is divided into survey units that share a common history or other characteristics, or
are naturally distinguishable from other portions of the site. A survey unit should not
include materials that have different contamination classifications; however, in some
cases, it might be advantageous to combine dissimilar materials into a single unit to
4 As defined by MARSSIM
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
obtain a survey unit that is more representative of a building or infrastructure and
minimize sampling densities. (See NRC 1998, Chapter 12)
An example of combining dissimilar materials into a single survey unit could be an
overpass. The bridge material (e.g. reinforced concrete and/or metal) might be different
than the road surface. In that case, combining the materials into a single survey unit
would be more representative of the entire overpass.
4.6 Develop a Conceptual Cleanup Model of the Site for SCP Planning
A model serves as the basis for defining sample collection needs during development of
the SCP to support cleanup goals. Project planners should gather and analyze available
information to develop a conceptual model that shows locations of known contamination,
areas of suspected contamination, types and concentrations of radionuclides on
impacted buildings and infrastructure, potentially contaminated materials, and locations
of potential reference (background) areas. The diagram should include the general
layout of the affected area including all buildings and their uses, infrastructure, water
treatment facilities, drainage and sewer systems, roads, power lines and utilities, and
any other supporting infrastructure systems.
4.7 Selection of Sampling Designs
The main goal in the development of the SCP is to collect samples that are
representative of site conditions. Using the conceptual cleanup model, crucial
infrastructure and buildings requiring assessment are identified for possible sampling.
Sampling strategies can be grouped into either statistical or non-statistical methods. To
ensure that samples are as representative as possible, statistics are often used to
design an appropriate sampling strategy and to provide a sound basis for supporting
decisions. In selecting the sampling design, use of a statistician is recommended to
ensure the design provides the data needed to support project decisions.
Decisions regarding the number and location of samples to be collected will be
based on several site- and incident-specific considerations, including the expected
pre-existing background levels and location of the target contaminant, the
anticipated variability of measurements, and the project DQOs. Some guidance for
selecting a sampling design and the number of field and quality control (QC)
samples that should be collected is provided in several resources, including:
Chapters 3, 4 and 5 of the Multi-Agency Radiation Survey and Site
Investigation Manual
EPA's Guidance on Choosing a Sampling Design for Environmental Data
Collection for Use in Developing a Quality Assurance Project Plan. QA/G-5S
(EPA 2002b)
EPA's Guidance on Choosing a Sampling Design for Environmental Data Collection for
Use in Developing a Quality Assurance Project Plan, QA/G-5S (EPA 2002a) is a tool-
box of statistical designs for sample collection that can be consulted during development
of the SCP. An SCP may contain some or all of the designs. However, it is important that
the design(s) selected meet the objectives of the QAPP, and can support the DQOs and
remediation levels of the project. Sample collection designs can be based on, but not
limited to:
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Judgmental Sampling - In judgmental or "bias" sampling, selection of sampling units
(i.e., the amount and location and/or timing of sample collection) is based on the feature
or condition under investigation and on professional judgment. This type of sampling
differs from statistical scientific theory probability-based sampling. Therefore,
conclusions are limited and depend entirely on the validity and accuracy of professional
judgment. Expert judgment may also be used in conjunction with other sampling designs
to produce effective sampling for defensible decisions.
Simple Random Sampling - In simple random sampling, particular sampling units (e.g.,
locations and/or times) are selected using random numbers, and all possible selections
of a given number of units are equally likely. For example, a simple random sample of a
contaminated brick facade can be taken by numbering all the bricks and randomly
selecting numbers or by sampling an area using pairs of random coordinates. This
method is easy to understand, and the equations for determining sample population size
are relatively straightforward. Simple random sampling is most useful when the
population of interest is homogeneous (e.g., similar contaminated materials, and no
expected major patterns of contamination or hot spots). Advantages of this design
include:
- Provides statistically unbiased estimates of the mean, proportions and variability
- Relatively easy to understand and implement
- Sample size calculations and data analysis are straightforward
An example is shown in Figure 4.2, with dots representing determined locations for
collection of individual samples.
Figure 4.2 Simple Random Sampling
(from EPA QA/G-5S, EPA/240/R-02/005)
Stratified Sampling - In stratified sampling, the target population is separated into non-
overlapping strata, or into subpopulations that are known or thought to be more
homogeneous (relative to the building/infrastructure material or to the contaminant), so
that there tends to be less variation among sampling units. Strata may be chosen on the
basis of spatial or temporal proximity, or on the basis of preexisting information or
professional judgment. This design is useful when the target population is
heterogeneous and the area can be subdivided based on expected contamination levels.
Advantages of this sampling design are that it has potential for achieving greater
precision in estimates of the mean and variance, and that it allows computation of
reliable estimates for population subgroups of special interest. Greater precision can be
obtained if the measurement of interest is strongly correlated with the variable used to
make the strata. Examples are provided in Figure 4.3a (asphalt surface) and Figure 4.3b
(building fa?ade).
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 4.3a Stratified Sampling - Asphalt Surface
0adapted from EPA QA/G-5S, EPA/240/R-02/005)
Radius = 500 meters
Direction of
Prevailing Wind
<
Figure 4.4b Stratified Sampling - Building Fagade
(.adapted from EPA QA/G-5S, EPA/240/R-02/005)
Radius = 50 meters
Direction of
Prevailing Wind
<
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Systematic and Grid Sampling - In systematic and grid sampling, samples are taken at
regularly spaced intervals over space or time. An initial location and/or time is chosen at
random. The remaining sampling locations are defined so that all locations are at regular
intervals over an area (grid) or time (systematic). Examples of systematic grids include
square, rectangular, triangular or radial. In random systematic sampling, an initial
sampling location (or time) is chosen at random and the remaining sampling sites are
specified so that they are located according to a regular pattern (e.g., at the points
identified by the intersection of each line in one of the grids). Systematic and grid
sampling is used to search for hot spots and to infer means, percentiles or other
parameters. It is also useful for estimating spatial patterns or trends over time. This
design provides a practical and easy method for designating sample locations and
ensures uniform coverage of a site, unit or process. An example is shown in Figure 4.4.
Figure 4.5 Systematic/Grid Sampling
(from EPA QA/G-5S, EPA/240/R-02/005)
Ranked Set Sampling - In ranked set sampling, m sets (each of size r) of areas to be
sampled are identified using simple random selection. The locations are ranked
independently within each set using professional judgment or inexpensive, fast or
surrogate measurements. One sampling unit from each set is selected (based on the
observed ranks) for subsequent measurement using a more accurate and reliable
(hence, more expensive) method for the contaminant of interest. Relative to simple
random sampling, this design results in more representative samples and so leads to
more precise estimates of the population parameters.
Ranked set sampling is useful when the cost of locating and ranking locations on
buildings and/or infrastructure is low compared to laboratory measurements. It is also
appropriate when an inexpensive auxiliary variable (based on expert knowledge or
measurement) is available to rank population units with respect to the variable of
interest. To use this design effectively, it is important that the ranking method and choice
of analytical method(s) are strongly correlated.
Adaptive Cluster Sampling - In adaptive cluster sampling, initial measurements are
made of randomly selected primary sampling units using simple random sampling.
Whenever a sampling unit is found to show a characteristic of interest, additional
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
sampling units adjacent to the original unit are selected and measurements are made.
Several additional rounds of sampling and analysis may be needed. Adaptive cluster
sampling also tracks selection probabilities for later phases of sampling so that an
unbiased estimate of the population mean can be calculated. An example application of
adaptive cluster sampling is delineating the borders of a plume of contamination. It is
useful for estimating or searching for rare characteristics in a population, and is
appropriate for inexpensive, rapid measurements. It enables delineating the boundaries
of hot spots, while also using all data collected with appropriate weighting to give
unbiased estimates of the population mean. An example is shown in Figure 4.5.
Figure 4.6 Adaptive Cluster Sampling
{from EPA QA/G-5S, EPA/240/R-02/005)
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Popu I ati on G rid with Sh a cl eel Areas of
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-inal Adaptive Cluster Sampling Results
< = Sampling unit
Composite Sampling - In composite sampling, volumes of similar material from several
selected sampling locations on a building or infrastructure are physically combined and
mixed to form a single homogeneous sample. Compositing can be very cost effective
because it reduces the number of radiochemical analyses needed. It is most cost
effective when analytical costs are large relative to sampling costs; it demands, however,
that there are no safety hazards or potential biases (e.g., increased radiological dose
rates or radioanalyte cross contamination) associated with the compositing process.
Compositing is often used in conjunction with other sampling designs when the goal is to
estimate the population mean and when information on spatial or temporal variability is
not needed. It can also be used to estimate the prevalence of a rare trait. An example is
shown in Figure 4.6.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 4.7 Composite Sampling
(from EPA QA/G-5S, EPA/240/R-02/005)
Individual Samples
Composit
Samples
AliquDts to bs analy zed
Table 4-1 provides a comparison of advantages and disadvantages for each of the
sampling designs listed above.
Table 4-1 Comparison of Sampling Designs
Sampling Design*
Statistical or
Non-Statistical
Application
Advantage
Disadvantage
Judgmental
Sampling
Non-Statistical
Best professional
judgment is used to
select sampling
locations that appear to
be representative of
average conditions.
Good for
homogeneous, well-
defined sites
Not usually recommended
for sole use. Conclusions
are limited and depend
entirely on the validity and
accuracy of professional
judgment.
Simple Random
Sampling
Statistical
Representative
sampling locations are
chosen using the
theory of random
chance probabilities.
Good when
background
information is not
available and no
visible signs of
contamination are
present.
May not be cost-effective
for samples located too
close together. Does not
take into account spatial
variability of contaminated
material.
Stratified Sampling
Statistical
Site is divided into
several sampling areas
(strata) based on
background or site
survey information;
each stratum is
evaluated using a
separate random
sampling strategy.
Good for large sites,
or sites containing a
variety of materials to
be sampled, surface
area features, or
past/present uses.
Often more cost-effective
than random sampling.
More difficult to implement
in the field and to analyze
results. Does not take into
account spatial variability of
contaminated material.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Sampling Design*
Statistical or
Non-Statistical
Application
Advantage
Disadvantage
Systematic and Grid
Sampling
Statistical
Most common
statistical strategy;
involves collecting
samples at
predetermined, regular
intervals within a grid
pattern.
Best strategy for
minimizing bias and
providing complete
site coverage. Can be
used effectively at
sites where no
background
information exists.
Ensures that samples
will not be taken too
close together.
Does not take into account
spatial variability of
contaminated material.
Ranked Set
Sampling
Statistical
Sets of sampling
locations are identified
using simple random
sampling and ranked
independently within
each set using
professional judgment
or inexpensive, fast, or
surrogate
measurements.
More efficient than
simple random
sampling. Useful
when the cost of
locating and ranking
locations is low
compared to
laboratory
measurements.
Does not take into account
spatial variability of
contaminated material.
Adaptive Cluster
Sampling
Statistical
Sampling designs in
which the procedure for
selecting sites or units
for the sample
population may depend
on values of the
variable of interest
observed.
Takes advantage of
sample population
characteristics so as
to obtain more
precise estimates of
population values for
a given sample size.
Coefficients of variation
may be rather large
compared to other designs.
Areas of contamination
could be missed.
Composite
Sampling
Statistical
Multiple discrete
samples are collected
from a similar material
and combined into a
single sample with the
intention that this single
sample represents the
components of that of
material.
Analytical cost
savings.
Limitations include aspects
of false negatives or
positives, and loss of
information regarding any
relationships between
radionuclides in individual
samples.
* Although biased sampling is typically used for characterization, sampling designs and strategies will depend on the
specific contamination incident and site
Listed below are several available software tools that can be used to aid designers in the
development of SCPs.
NOTE: Mention of company names, trade names, or commercial products in this
document does not constitute endorsement or recommendation for use.
Dose Risk Calculation (DCAL) software performs biokinetic and dosimetric
calculations for the case of acute intake of a radionuclide by inhalation, ingestion, or
injection into blood at a user-specified age at intake. The user may compute either
equivalent or absorbed dose rates as a function of time following intake of the
radionuclide. The equivalent dose option enables the generation of a table of age-
specific dose coefficients, i.e., committed equivalent doses to organs and committed
effective doses per unit intake. DCAL software is accessible at
https://www.epa.gov/radiation/dcal-software-and-resources
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Cumulative Probability Plot can be used to plot empirical data on cumulative
probability distribution graphs. The software computes parametric statistics and a
"test statistic" based on "sampling by variables." It is useful for visual presentation of
characterization and final status surveys. Cumulative Probability Plot is available for
download at http://www.radprocalculator.com/Probability.aspx
GENII-NESHAPS provides a set of software for calculating radiation dose and risk
from radionuclides released to the environment. The GENII-NESHAPS Edition is
specifically designed to help site managers plan and improve compliance with 40
CFR 61, subparts H and I. GENII-NESHAPS Version 2 is available for download at
https://cfpub.epa.gov/si/si public record Report.cfm?Lab=ORIA&dirEntrylD=73944
MARSSIMPower2000 implements the final status survey designs described in
MARSSIM. MARSSIMPower2000 is available for download at
http://cvg.homestead.com/marssimpower2000.html
RESRAD-BUILD is a computer code designed for analyzing radiation exposures
resulting from occupying a building contaminated with radioactive materials or
housing contaminated equipment or furniture, as well as from remediating the
contamination. Developed by Argonne National Laboratory, RESRAD codes are
available for download at http://resrad.evs.anl.gov/codes/resrad-build/
RESRAD RDD is a computer code developed to derive operational guidelines for use
in emergency planning and response associated with a radiological dispersal device
(RDD) incident. The operational guidelines are expressed in terms of ground surface
radioactivity concentration levels (for comparison with measurement data) or stay
times (with known radioactivity concentrations) in the contaminated area and
correspond to the Protection Action Guides (PAGs) in terms of radiation doses
established by EPA (EPA 400-R-92-001). RESRAD RDD can be downloaded at
https://resrad.evs.anl.gov/codes/resrad-rdd/
Spatial Analysis and Decision Assistance (SADA) was developed by the
University of Tennessee and incorporates tools from environmental assessment
fields. These tools include integrated modules for visualization, geospatial analysis,
statistical analysis, human health risk assessment, ecological risk assessment, cost/
benefit analysis, sampling design, and decision analysis. SADA 5.0.78 is available for
download at https://www.sadaproiect.net/download.html
Visual Sample Plan (VSP) provides statistical solutions to sampling design (how
many samples to take and where to take them) and provides mathematical and
statistical algorithms. Visual Sample Plan is available for download at
https://vsp.pnnl.gov/
Turbo FRMAC software performs a series of automated calculations that allow users
to determine best courses of action during a radiological emergency. Actionable
decisions such as residential evacuations or crop destruction can be made based on
values generated from instrument outputs of field samples or from atmosphere
dispersion models. The values are generated from formulas created by EPA, FDA
and other federal agencies, and can be used to determine risk level exceedances.
Developed by Sandia National Laboratories, Turbo FRMAC is available for download
at https://nirp.sandia.g0v/S0ftware/TurboFRMAC/TurboFRMAC.aspx - Downloads
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ProLICL software provides a variety of statistical tools that can be used to address
sampling and statistical issues regarding a specific Superfund site. The software's
primary functions include calculating upper statistical limits, but also provide a variety
of graphical and statistical analysis tools for groundwater monitoring. Users input
datasets and statistical tests are then applied, generating outputs that include
recommendations, cautions and cited references. ProUCL version 5.1.00 can be
downloaded at https://www.epa.gov/land-research/proucl-software
Surface Preliminary Remediation Goals (SPRG) and Building Preliminary
Remediation Goals (BPRG) Calculators use slope factors that are dependent on
inhalation, ingestion, or dermal exposure pathways to calculate outdoor (the SPRG)
and indoor (the BPRG) radiation cleanup levels. The calculators can be used to
determine initial cleanup goals and radiation exposures in outdoor, residential and
commercial environments. The BPRG calculator can be accessed at https://epa-
bprg.ornl.gov/cgi-bin/bprg search. The SPRG calculator may be accessed in the
future at https://www.epa.gov/region8/calculating-preliminarv-remediation-goals-prgs.
Additional information on SPRGs can be found at
https://cfpub.epa.gov/si/si public record Report.cfm?Lab=OSRTI&dirEntrylD=15164
3
4.8 Writing the SCP - Content of Major Elements
When all of the appropriate site information is gathered, the SCP designers take the
information and assemble the SCP. Appendix A provides a checklist of elements that
can be used as a template for writing a site-specific SCP. The specific elements that
would be appropriate to include depend on site conditions (e.g., the extent and type of
the contamination, site size, number of impacted buildings or infrastructures, types of
impacted materials, project needs and DQOs).
4.8.1 Project Background
With the information gathered during Step I, including response information
turned over by FRMAC, the SCP should provide both a site history (including
descriptions of the use of the site, permits, and the previous use of radioisotopes
or the use of chemical decontamination agents during the response) and
information regarding the radiological contamination incident. The historical and
response data from any investigation and sampling efforts should be identified
and summarized. An assessment of the quality of the data should be included, as
well as a discussion of any problems encountered during initial site assessment
and incident response. The SCP should include a description and a map of the
location (physical address, GPS coordinates, cross streets, compass bearing),
size, and important physical features of the affected area, such as schools, public
parks, business centers, transportation infrastructure, water treatment facilities,
lakes, streams, drainage and sewer systems, buildings, and roads. Maps should
include both scales and legends.
This section of the SCP should also include an Executive Summary describing
the results of the initial investigation of the contaminant and the project's planned
approach toward resolution.
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4.8.2 Project Organization and Responsibilities
This element of the SCP identifies key field personnel or organizations
responsible for each sampling activity during cleanup and remediation. A chart
showing project organization and lines of authority should be included. The chart
should identify QC management organizations and identify their appropriate
independent reporting chain outside project management. This section of the
SCP should describe the responsibilities of all project field personnel, including
subcontractor roles and their key points of contact, sampling personnel, and
liaison personnel between field, laboratory and QC managers.
This section of the SCP should also identify any special training requirements
and/or personnel certifications necessary to perform the work, as well as all
organizations responsible for:
Project planning
Project coordination
Sample collection
Disposal of sampling waste
Sample custody
4.8.3 Project Scope and Objectives
The SCP must describe specific project objectives of the sampling effort. It
should identify the planned project activities, QA procedures to be implemented
to support project activities, relevant regulatory standards, and the project
schedule. The intended use of data should be stated and should satisfy the
intended uses of the data for meeting any identified regulatory requirements and
project-specific clean up criteria. An outline of the project schedule should be
provided and should include project plan review periods, sampling activities,
sample analysis, data management and validation, and project report writing.
4.8.4 Non-Measurement Data Acquisition
The SCP should describe data needed from non-measurement sources, such as
databases, literature, handbooks and local authorities. Information of this type
may be needed to support assessment of:
Data supporting modeling activities
Public transportation infrastructure
Building and infrastructure uses (e.g., residential, commercial, recreational)
Infrastructure support systems
Meteorological data
4.8.5 Field Activities - Project Sample Collection Procedures
The SCP should provide detailed site-specific instructions and requirements that
are to be used in conjunction with the sample collection procedures described in
EPA's Sample Collection Procedures for Radiochemical Analytes in Outdoor
Building and Infrastructure Materials (EPA 2016). The design team should refer
to these sample collection procedures for detailed information on how the
samples required under the SCP are to be collected. The SCP must provide
details to describe the field activities to be performed, including but not limited to,
information regarding:
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Sampling and field data-gathering procedures to be used
Specific sample collection equipment to be used
Data acquisition equipment and procedures to be used
Sample sizes required for each material matrix, to meet DQOs and MQOs
Sampling locations (corresponding GPS coordinates, if applicable)
The number of samples to be collected from each sampling location
Type of sample preservation, if applicable
Sample container types and sizes
QC requirements (e.g., field QC samples)
In situ field measurements (if any) and equipment
4.8.6 Radiological Field Measurements and Equipment
Many cleanup projects will include on-site screening for detection and/or
measurement of contamination. This screening can assist with project planning
and reduce the burden of sample collection and analyses. Site RSP
requirements for the sampling efforts to be performed should be identified, along
with the support function interface between the radiation protection group and the
sample collection personnel. A listing of building- and/or infrastructure-specific
matrices, the expected radionuclides present in the matrices, and the appropriate
instrumentation and measurement techniques to be used for each matrix should
be detailed.
4.8.7 Sampling Operations Documentation
The SCP should identify requirements regarding the records that will be used to
document sampling operations and should also identify the records and schedule
for those that require periodic submittal. The SCP also should include proposed
documentation forms. Documentation of error correction procedures must be
defined in the SCP and must be equivalent to the requirements of the QAPP.
Sampling operations documents may include but are not limited to:
Daily QC reports, including background checks
Field logbooks
Field work forms
Photographic records
Field analytical records
This section should also address the sample documentation records, such as:
Sample numbering system
Sample labels and tags
Field sampling logs/log books
COC forms and custody seals
Laboratory notification documentation forms
Electronic file naming system, if applicable
Sample custody requirements should be defined for:
Outdoor building/infrastructure and field QC samples
Sample transfer to the laboratory(s)
Laboratory custody control
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The SCP should also define project record custody requirements for original
field documents and laboratory reports. It should define record management
practices for, but not limited to:
SOPs
SOP review documentation, versions tracking, and record retention
requirements
Corrective action reports
Shipment manifesting and bills of lading
Waste profile and waste shipment vehicle survey forms
4.8.8 Sample Packaging and Shipping Requirements
The SCP should include a discussion of sample packaging and shipping
requirements in accordance with appropriate federal and state regulations (e.g.,
Department of Transportation regulations found at 49 CFR 171-178 (49 CFR);
International Air Transportation Association [IATA] regulations). It should identify:
Appropriate laboratory(s)
Laboratory(s) addresses and points of contact
Sample submittal schedule
Mode of sample transportation (e.g., overnight courier)
COC forms and seals
Manifesting requirements for the shipment
It is recommended that the receiving laboratories also document the condition of
building/infrastructure samples upon receipt at the laboratory. This enables
verification of correct sample volumes, COC completeness and accuracy, and
overall packaging techniques.
Sample packaging and shipping procedures described in Module I, Section 7.0,
of EPA's Sample Collection Procedures for Radiochemical Analytes in Outdoor
Building and Infrastructure Materials (EPA 2016) and in EPA's SAM companion
Sample Collection Information Document for Chemicals. Radiochemicals and
Biotoxins (EPA 2017a) should also be reviewed before completing this section of
the SCP.
4.8.9 Sampling Waste
The SCP should describe procedures that will be used for collecting, labeling,
storing, and disposing of the sampling waste. The SCP should detail procedures
for assessing corresponding sample results or sampling the waste to determine
whether it is hazardous. The SCP should address how the sample results will be
evaluated to determine disposal options for the sampling waste. Disposal actions
must be conducted with the concurrence of appropriate project technical
personnel and management. Module I, Section 6.0 and Appendix D, of EPA's
Sample Collection Procedures for Radiochemical Analytes in Outdoor Building
and Infrastructure Materials (EPA 2016) should be reviewed before completing
this section of the SCP.
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4.8.10 Project Quality Assurance (QA)
The SCP must include QA/QC elements that are consistent with the QAPP and
are applied throughout the project to ensure proper execution of the SCP and
appropriate data generation. The project assessment activities should be
discussed as they pertain to the QA objectives identified in the QAPP. In general,
the SCP should provide specifications for QA activities by defining in detail:
Project schedules
Proper technical review/approval of project documents
Radiochemical DQOs and MQOs identified in the QAPP, and their
respective data quality indicators
QA/QC protocols necessary to achieve the DQOs and MQOs
Analytical methods and measurements
Evaluation of laboratories
QC samples and sample handling procedures/verification
QC sample analysis
Use of single- and double-blind performance evaluation samples
Equipment calibration and maintenance documentation
SCP QA implementation protocols
Establishing experience and training requirements for key field personnel
Level of decision making empowered to key field personnel
Communication protocols between the field and project stakeholders
Data assessment procedures for the evaluation and the identification of any
data limitations, including data review, validation, and reporting
Generation of required quality reports
Sampling requirements to support the final status survey
EPA or EPA contract audit personnel should conduct a variety of audits (field,
laboratory, office) to identify procedures that could cause problems with sampling
and analytical results. The audits should be scheduled as early as possible, and
should cover project activities from initial investigation to post closure monitoring
to include but not be limited to:
Sample collection from all building and infrastructure media (i.e., concrete,
brick, granite, asphalt, etc. and sample generated waste)
Use of sampling devices
Decontamination of equipment or activities that could cause cross-
contamination
Post sample collection activities (packaging/shipping)
Laboratory activities
Data reporting, including electronic media
COC procedures and documentation
Field logs
4.8.11 Non-Conformance/Corrective Actions
The SCP must address notification procedures and corrective actions that should
be followed by field and laboratory personnel if there are deviations from the SCP
or problems with samples upon receipt at the laboratory. Typical problems or
deviations include, but are not limited to:
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Improper COC documentation
Broken sample containers or questionable sample integrity (e.g., broken
custody seals)
Sample location changes
Insufficient sample amount
Corrective action procedures must address:
Corrective actions required if field and/or analytical procedures are found to
deviate from the requirements in the SCP
Re-sampling with additional analysis of new samples
Reanalysis of existing field or QC samples
Proper data qualification
Notification processes
Contingencies
The SCP must state that significant changes to or deviations from the approved
SCP will not be made without the written approval of the incident commander
and/or project lead.
4.8.12 SCP Appendices
The SCP appendices should include, but not limited to, the following items:
References
List of abbreviations and acronyms
Standard project forms to be used
- COC forms
- Sample labels
- Shipping manifest
- Audit forms
- Non-conformance reporting forms
- QA report forms
Summary tables
- Data quality objectives summary
- Building and infrastructure cleanup objectives
- Sample container requirements
- Names and addresses of owners of property on the site
- Sample container types and quantities
- Summary of building/infrastructure sample matrices and locations
- Summary of number of samples and analyses
- Listing of approved analytical laboratories and contact information
List of figures
- Project organization
- Sampling schedule
- Proposed on-site and off-site sampling locations
4.9 SCP Review and Approval
The SCP should be reviewed to determine whether it will provide data that satisfy data
use needs and project/site DQOs, and whether it is compatible with all site constraints.
As a guide, reviewers should use a checklist that contains general information that
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typically should be included in an SCP. Review checklists can be prepared by reviewing
Appendix A and identifying project specific variations.
NOTE: Due to the complexity that each site-specific SCP might require, a detailed
checklist is beyond the scope of this document.
Once an SCP has been approved, appropriate personnel sign the signature page.
Personnel signing the SCP are determined on a project-specific basis. It is
recommended that the incident commander/project manager sign the title page of the
SCP, and that the technical manager sign the title page of the associated QAPP.
Deviations from the approved SCP must receive written approval from the incident
commander and/or project lead. In addition, there may be significant changes in the
project that necessitate appending or modifying the SCP. Similar procedures for review
and approval of those modified sections are necessary prior to execution of the
modifications.
4.10 SCP Distribution
Once approved, the final SCP and/or its approved modifications must be distributed to
all appropriate parties, including project and technical managers, primary and QA
laboratory(s), appropriate regulatory authorities, stake holders, and subcontractors (i.e.,
sampling firms, data validation firms).
5.0 Step III - SCP Implementation
An approved SCP must be in place before implementing the SCP activities. Figure 5.1
outlines the elements of a SCP, highlighting the importance of personnel being trained in
these elements prior to their implementation.
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
Figure 5.1 Step III - SCP Implementation
f
I
!<§
11
From Step II
SCP Design and Development
1
SCP
Implementation
'
'
Building/Infrastructure
Disposition
Incident Commanders &
Project Managers
Contractors
Analytical Laboratories
SCP Compliance Monitoring
Project, Field, and Laboratory Audits
Field & Laboratory QC Samples
Data Review & Validation
Records Review
Quality Assurance & Data Reports
Non-Conformance Reports
Corrective Actions Reports
Sample Collection & Radiological
Surveys
Sample Analysis
Project Sampling and Analysis
Sampling Progress Reports
Sample Shipment Reports
Waste Reports
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5.1 Personnel Training
Prior to implementation of the SCP, project personnel must be adequately trained for
their specific duties and possess a full understanding of all aspects of the SCP. Training
must include safety and health requirements and practices as defined in the HASP and
RSP.
5.2 Field Sample Collection
Prior to performing sample collection, sampling personnel should ensure that proper field
equipment is available, in good condition, and meets QA requirements. Personnel also
should ensure that sample collection and handling procedures are performed in
accordance with the SCP and following specifications provided in EPA's Sample
Collection Procedures for Radiochemical Analytes in Outdoor Building and Infrastructure
Materials (EPA 2016).
5.3 Project Liaison
A liaison between project management, field, and laboratory personnel should be
identified to ensure smooth transition of all samples from the field to the laboratory or
laboratories. Liaison duties also may include implementation of proper sample
documentation, packaging, and shipping procedures.
5.4 SCP Compliance Monitoring
Before data collection activities begin, an approved SCP must be in place and
subsequent collection activities must be performed in compliance with the approved
SCP. There are several QA elements that may be applied to the project to ensure proper
SCP compliance. These include, but are not limited to:
Field and laboratory audits
Field and laboratory quality control samples
Equipment calibration and maintenance documentation
QA sample handling verification
QA sample analysis using single- and double-blind performance evaluation samples
Data review and/or data validation
Electronic media audits
Generation of QA reports and data quality assessment reports
5.4.1 Project, Field, and Laboratory Audits
During implementation of the SCP, field activity audits should be performed for all
phases of field work, from initial investigation and data collection, to post closure
monitoring. Field audits should be scheduled as early in the activity as possible
to identify procedures that could cause problems with the sampling and analytical
results. This oversight is necessary to ensure that approved procedures, as
specified in the SCP, are used. Field audits include monitoring critical activities
such as decontamination of equipment or activities that could cause cross-
contamination, sample collection from all outdoor building and infrastructure
media (i.e., concrete, brick, granite, asphalt), and post sample collection activities
(packaging/ shipping). Laboratory audits must also be performed to ensure that
procedures for proper communication, proper documentation, and awareness of
project DQOs are in place and that these procedures are in compliance with the
analytical SOW.
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5.4.2 Project Activity Reports
While data collection activities are being performed, the sampling team should
communicate daily with appropriate project personnel regarding project status by
submitting at least, but not limited to, the following:
Field sampling progress reports in relationship to project schedules including
field work forms, photographic records, field analytical records
Sample shipment reports
Waste accumulation reports
Other project required field reports
Project quality assurance monitoring of data collection activities must include all
of the applicable QA/QC requirements identified in the SCP and the QA group
should communicate daily with appropriate project personnel regarding project
status by submitting at least, but not limited to, the following:
QA and data quality assessment reports
QC samples and sample handling procedures/verification reports
QC sample analysis reports
Field instrumentation QC reports
Non-conformance reports
Corrective action reports
5.5 Site Disposition
For most sites, following review of data results generated during one or more surveys, a
disposition decision is based on a demonstration of compliance with site cleanup goals.
When survey results are used to support a decision, the decision maker(s) needs to
ensure that the data will support that decision with satisfactory confidence. Actions must
be taken to manage the uncertainty in the survey results, so that sound, defensible
decisions may be made. These actions include design and implementation of proper
survey and sampling plans to control known causes of uncertainty, proper application of
QC procedures to detect and control significant sources of error, and careful analysis of
uncertainty before the data are used to support decision making.
NOTE: If the decision maker(s) determine that the cleanup goals have not been met
to satisfy the site QAPP due to a sample collection issue then the SCP will be
re-optimized through reevaluation and then redesigned. Additional sampling and
analysis may be required to satisfy compliance demonstration and site disposition.
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6.0 References and Additional Resources
Cited References (All web addresses were last accessed June 5, 2020)
6.1 40 CFR. Title 40 Code of Federal Regulations (CFR) part 300.430. Remedial
investigation/feasibility study and selection of remedy, https://gov.ecfr.io/cgi-
bin/text-
idx?SID=5b4a422c224195703ba577db77d72d03&mc=true&tpl=/ecfrbrowse/Title4
0/40tab 02.tpl
6.2 49 CFR. Title 49 CFR parts 171-178. Hazardous Materials Regulations.
https://qov.ecfr.io/cqi-bin/text-
idx?SID=5b4a422c224195703ba577db77d72d03&mc=true&tpl=/ecfrbrowse/Title4
9/49tab 02.tpl
6.3 Battelle 2000. Radiological Characterization and Final Status Plan for Battelle
Columbus Laboratories Decommissioning Project, West Jefferson Site," Revision
0, March 2000
6.4 Battelle 2000a. Battelle Memorial Institute Columbus Operations Decommissioning
Plan, DD-93-19, Revision 3, August 2000
6.5 EPA 2001. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5,
EPA/240/B-01/003, March 2001. Washington DC: U.S. Environmental Protection
Agency, https://www.epa.gov/gualitv/epa-gar-5-epa-reguirements-gualitv-
assurance-project-plans
6.6 EPA 2002. Guidance for Quality Assurance Project Plans, EPA QA/G-5,
EPA/240/R-02/009, December 2002. Washington DC: U.S. Environmental
Protection Agency, https://www.epa.gov/sites/production/files/2015-
06/d ocu m e nts/g 5-f i na I. pdf
6.1 EPA 2002a. Guidance on Choosing a Sampling Design for Environmental Data
Collection for Use in Developing a Quality Assurance Project Plan, EPA QA/G-5S,
EPA/240/R-02/005, December 2002. Washington DC: U.S. Environmental
Protection Agency, https://www.epa.gov/guality/guidance-choosing-sampling-
design-environmental-data-collection-use-developing-gualitv
6.8 EPA 2006. Guidance on Systematic Planning Using the Data Quality Objectives
Process, EPA QA/G-4, EPA/240/B-06/001, February 2006. Washington DC: U.S.
Environmental Protection Agency.
https://www.epa.gov/sites/production/files/documents/guidance systematic planni
ng dgo process.pdf
6.9 EPA 2016. Sample Collection Procedures for Radiochemical Analytes in Outdoor
Building and Infrastructure Materials, EPA/600/R-16/128, September 2016.
Washington DC: U.S. Environmental Protection Agency.
https://cfpub.epa.gov/si/si public record report.cfm?Lab=NHSRC&dirEntryld=335
065
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6.10 EPA 2017. PAG Manual: Protective Action Guides and Planning Guidance for
Radiological Incidents, EPA-400/R-17/001, January 2017. Washington DC: U.S.
Environmental Protection Agency, https://www.epa.gov/radiation/pag-manuals-
and-resources
6.11 EPA 2017a. Sample Collection Information Document for Chemicals,
Radiochemicals and Biotoxins - Companion to Selection of Analytical Methods for
Environmental Remediation and Recovery (SAM) 2017, EPA/600/R-17/389,
September 2017. Washington DC: U.S. Environmental Protection Agency.
https://cfpub.epa.gov/si/si public record report.cfm?Lab=NHSRC&dirEntrvld=339
258
6.12 EPA 2017b. Selected Analytical Methods for Environmental Remediation and
Recovery (SAM) 2017, September 2017. Washington DC: U.S. Environmental
Protection Agency, https://www.epa.gov/esam/selected-analvtical-methods-
environmental-remediation-and-recovery-sam
6.13 FRMAC 2009. Guidance Document for the Transfer of Operational Control of the
Federal Radiological Monitoring and Assessment Center (FRMAC) from the U.S.
Department of Energy to the U.S. Environmental Protection Agency, Version 2,
September 28, 2009. Washington DC: U.S. Department of Energy, U.S.
Environmental Protection Agency.
https://www.nnss.gov/docs/docs FRMAC/FRMAC Transfer.pdf
6.14 IDQTF 2005. Intergovernmental Data Quality Task Force (IDQTF), Uniform
Federal Policy for Quality Assurance Project Plans: Evaluating, Assessing, and
Documenting Environmental Data Collection and Use Programs, Part 1: UFP-
QAPP Manual (EPA-505-B-04-900A / DTIC ADA 427785), Final Version 1, March
2005. Washington DC: U.S. Environmental Protection Agency, U.S. Department of
Defense, U.S. Department of Energy.
https://www.epa.gov/sites/production/files/documents/ufp gapp v1 0305.pdf
6.15 MARLAP 2004. Multi-Agency Radiological Laboratory Analytical Protocols Manual
(MARLAP), NUREG-1576 EPA 402-B-04-001A, July 2004. Washington DC: U.S.
Environmental Protection Agency, U.S. Department of Defense, U.S. Department
of Energy, U.S. Nuclear Regulatory Commission.
https://www.epa.gov/radiation/marlap-manual-and-supporting-documents
6.16 MARSAME 2009. Multi-Agency Radiation Survey and Assessment of Materials
and Equipment Manual, (MARSAME), NUREG-1575, Supp. 1; EPA 402-R-09-001;
DOE/HS-0004, January 2009. Washington DC: U.S. Environmental Protection
Agency, U.S. Department of Defense, U.S. Department of Energy, U.S. Nuclear
Regulatory Commission, https://www.nrc.gov/reading-rm/doc-
collections/nuregs/staff/sr1575/supplement1/index.html
6.17 MARSSIM 2000. Multi-Agency Radiation Survey and Site Investigation Manual
(MARSSIM), NUREG-1575, Rev. 1; EPA 402-R-97-016, Rev. 1; DOE/EH-0624,
Rev. 1; August 2000. Washington DC: U.S. Environmental Protection Agency, U.S.
Department of Defense, U.S. Department of Energy, U.S. Nuclear Regulatory
Commission, https://www.epa.gov/radiation/multi-agencv-radiation-survev-and-
site-investigation-manual-marssim
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6.18 NRC 1998. A Nonparametric Statistical Methodology for the Design and Analysis
of Final Status Decommissioning Surveys, NUREG-1505, Rev. 1; June 1998. U.S.
Nuclear Regulatory Commission.
https://www.nrc.gov/docs/ML0618/ML061870462.pdf
6.19 ORNL 1993. Site Characterization Plan for Decontamination and Decommissioning
of Buildings 3506 and 3515 at Oak Ridge National Laboratory, ORNL/ER/Sub/87-
99053/69, Oak Ridge National Laboratory, Oak Ridge, Tennessee, September
1993
6.20 RFETS 2002. Reconnaissance Level Characterization Plan for D&D Facilities,
Revision 1, Reconnaissance Level Characterization Plan (RLCP) For the Rocky
Flats Environmental Technology Site (RFETS), Appendix D. D&D
[Decontamination and Decommissioning] Characterization Protocol, MAN-077-
DDCP, July 2002
6.21 RFETS 2002a. Pre-Demolition Survey Report (PDSR), Building 551 Closure
Project, Rocky Flats Environmental Technology Site, Revision 0, December 31,
2002
6.22 RFETS 2003. Rocky Flats Environmental Technology Site, Type 1
Reconnaissance Level Characterization Report (RLCR) Area 5 Group 6a Closure
Projects Trailers. T130C, T130D, T130E,T130F, T130G &T130H, Revision 0, April
15, 2003
6.23 SANDIA2010. FRMAC Assessment Manual Methods, Volume 1, SAND2010-
1405P, April 2010. Livermore, California: Sandia National Laboratories.
6.24 SANDIA 2015. FRMAC Assessment Manual Overview and Methods Volume 1
[Protective Action Guides (PAGs)] SAND2015-2884R, April 2015. Livermore,
California: Sandia National Laboratories.
Other References (All web addresses were last accessed June 8, 2020)
In addition to the information provided in this document, the following documents are
recommended as resources for generating an SCP that clearly identifies project goals,
associated data needs, and application of QA elements based upon the QAPP project
goals designed to reach site release:
6.25 Planning Guidance for Protection and Recovery Following Radiological Dispersal
Device (RDD) and Improvised Nuclear Device (IND) Incidents, 2008, FR Doc E8-
17645, Federal Register: (Volume 73, Number 149) [Page 45029-45048], Notice of
Final Guidance, August 1, 2008. https://www.gpo.gov/fdsys/pkg/FR-2008-08-
01/pdf/E8-17645.pdf
6.26 U.S. Army Corps of Engineers, Requirements for the Preparation of Sampling and
Analysis Plans, EM 200-1-3, February 2001. Washington DC: U.S. Army Corps of
Engineers, https://clu-in.org/download/toolkit/thirdednew/em 200-1-3.pdf
6.27 U.S. Department of Energy (DOE), Statistical and Cost-Benefit Enhancements to
the DQO Process for Characterization Decisions, DOE/EM-0316, September 12,
1996. Washington DC: U.S. Department of Energy.
https://inis.iaea.org/collection/NCLCollectionStore/ Public/28/021/28021665.pdf
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6.28 U.S. Department of Energy (DOE), Decommissioning Handbook, DOE/EM-0383,
January 2000. Washington DC: U.S. Department of Energy.
https://nucleus.iaea.org/sites/connect/IDNpublic/R2D2/Workshop%2007/doe-
decommissioning-handbook.pdf
6.29 U.S. Environmental Protection Agency, Guidance for Developing Quality Systems
for Environmental Programs, EPA QA/G-1, EPA/240/R-02/008, November 2002.
https://www.epa.gov/sites/production/files/2015-08/documents/g1-final.pdf
6.30 U.S. Environmental Protection Agency, Guidance on Assessing Quality Systems,
EPA QA/G-3, EPA/240/R-03/002, March 2003.
https://www.epa.gov/sites/production/files/2015-06/documents/g3-final.pdf
6.31 U.S. Environmental Protection Agency, Guidance on Technical Audits and Related
Assessments for Environmental Data Operations, EPA QA/G-7, EPA/600/R-
99/080, January 2000. https://www.epa.gov/sites/production/files/2015-
07/documents/g7-final.pdf
6.32 U.S. Environmental Protection Agency, Guidance on Environmental Data
Verification and Data Validation, EPA QA/G-8, EPA/240/R-02/004, November
2002. https://www.epa.gov/sites/production/files/2015-06/documents/g8-final.pdf
6.33 U.S. Environmental Protection Agency, Guidance on Technical Audits and Related
Assessments for Environmental Data Operations, EPA QA/G-7, Final, EPA/600/R-
99/080, January 2000. Washington DC: U.S. Environmental Protection Agency.
https://www.epa.gov/guality/guidance-technical-audits-and-related-assessments-
environmental-data-operations-epa-gag-7
6.34 U.S. Environmental Protection Agency, Guidance for Developing Quality Systems
for Environmental Programs, EPA QA/G-1, EPA/240/R-02/008, November 2002.
Washington DC: U.S. Environmental Protection Agency.
https://www.epa.gov/sites/production/files/2015-08/documents/g1-final.pdf
6.35 U.S. Environmental Protection Agency, Guidance on Environmental Data
Verification and Data Validation, EPA QA/G-8, EPA/240/R-02/004, November
2002. Washington DC: U.S. Environmental Protection Agency.
https://www.epa.gov/gualitv/guidance-environmental-data-verification-and-data-
validation
6.36 U.S. Environmental Protection Agency, 2003, Guidance on Assessing Quality
Systems, EPA QA/G-3, EPA/240/R-03/002, March 2003. Washington DC: U.S.
Environmental Protection Agency, https://www.epa.gov/sites/production/files/2015-
06/documents/g3-final.pdf
6.37 U.S. Environmental Protection Agency, 2005, Guidance on Quality Assurance for
Environmental Technology Design, Construction, and Operation, EPA QA/G-11,
EPA/240/B-05/001, January 2005. Washington DC: U.S. Environmental Protection
Agency, https://www.epa.gov/gualitv/guidance-gualitv-assurance-environmental-
technology-design-construction-and-operation-epa
38
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials
6.38
6.39
6.40
6.41
6.42
39 June 2020
U.S. Environmental Protection Agency, 2006, Data Quality Assessment: A
Reviewers Guide, EPA QA/G-9R, EPA/240/B-06/002, February 2006. Washington
DC: U.S. Environmental Protection Agency, https://www.epa.gov/guality/guidance-
data-guality-assessment
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Washington DC: U.S. Environmental Protection Agency.
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Radiochemical Analytes in Environmental Matrices, EPA/600/R-12/566, July 2012.
Washington DC: U.S. Environmental Protection Agency.
https://cfpub.epa.gov/si/si public record report.cfm?Lab=NHSRC&dirEntrvld=246
636
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analysis-plan-guidance-and-template-v4-general-proiects-042014
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5849.pdf
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials -
Appendix A
Appendix A
Sample Collection Plan
Design Elements and Development Checklist
1.0 Project Background
1.1 Site History and Contaminants
1.2 Contaminants and Contaminated Materials
1.3 Summary of Site Data Prior to Contamination Incident
1.4 Site-Specific Definition of Problems (including a description of the contamination
incident)
1.5 FRMAC Incident Response Data
2.0 Project Organization and Responsibilities
3.0 Project Scope and Objectives
3.1 Task Description
3.2 Applicable Regulations/Standards/Risk Based Cleanup Goals
3.3 Project Schedule
4.0 Nonmeasurement Data Acquisition
5.0 Sample Collection Field Activities
5.1 General Considerations
5.1 Surface Area Sample Collection
5.1.1 Rationale/Design
5.1.1.1 General Considerations
5.1.1.2 Sample Collection Overview
5.1.1.3 Number and Location of Samples
5.1.1.4 Sample Containers
5.1.1.5 QA/QC Samples and Frequency
5.1.1.6 Field and Laboratory Analysis
5.1.2 Sample Collection Procedures
5.1.2.1 Sampling using Dry Swipes
5.1.2.2 Sampling using Wet Swipes (Tritium sampling)
5.1.2.3 Sampling using Tape Swipe
5.1.2.4 Swipe Handling, Sample Containers and Cross Contamination
Prevention
5.1.3 Field Quality Control Procedures
5.1.4 Decontamination Procedures
5.2 Building/Infrastructure Materials Sample Collection
5.2.1 Rationale/Design
5.2.1.1 General Considerations
5.2.1.2 Sample Collection Overview
A-1
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Sample Collection Plans for Radiochemical Analytes in Outdoor Building and Infrastructure Materials -
Appendix A
5.2.1.3 Outdoor Building and Infrastructure Materials to be Sampled
5.2.1.4 Number and Location of Samples
5.2.1.4 Discrete/Composite Sampling Requirement
5.2.1.5 Sample Containers
5.2.1.6 QA/QC Samples and Frequency
5.2.1.7 Field and Laboratory Analyses
5.2.2 Sample Collection Procedures
5.2.2.1 Chip Sampling
5.2.2.2 Drilling (Hand)
5.2.2.3 Core Drilling
5.2.2.4 Needle Scaling
5.2.2.5 Sawing (Power, Chain, Circular, Cut Off, Diamond Wire)
5.2.2.6 Scabbling
5.2.2.7 Shaving and Grinding
5.2.2.8 Hydraulic/Pneumatic Hammering
5.1.3 Field Quality Control Procedures
5.1.4 Decontamination Procedures
6.0 Radiological Field Measurements and Instrumentation to Support Sample
Collection
7.0 Field Operations Documentation
7.1 Daily Quality Control Reports (QCR)
7.2 Field Logbook and/or Sample Field Sheets
7.3 Photographic Records
7.4 Sample Documentation
7.4.1 Sample Numbering System
7.4.2 Sample Labels and/or Tags
7.4.3 COC Records
7.5 Field Analytical Records
7.6 Documentation Procedures/Data Management and Retention
8.0 Sample Packaging and Shipping Requirements
9.0 Waste Sampling and Management
10.0 Project Quality Assurance
11.0 Non-Conformance/Corrective Actions
Appendices (e.g., SOPs, HASP, RSP, WMP)
References
A-2
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