10.0 SAMPLE PACKAGING AND SHIPPING
Samples to be shipped off-site must be analyzed on-site to determine the levels of radionuclides present. This will allow for proper packaging and shipping via International Air Transport Association (IATA) Dangerous Goods Regulations (IATA, 1998). By IATA definition, a material must have an activity greater than 2,000 pCi/g in order to be considered radioactive. If the radioactivity of a material is < 2,000 pCi/g, it does not need to be shipped as radioactive.
The following procedure applies only to un-preserved radioactive samples. If preserved samples are being shipped, consult the IATA regulations for proper packaging, labeling, marking, and documentation.
1) Tabulate the activities of the radionuclides present in each of the samples on the Sample Shipping Worksheet (this can easily be set up on a computer spreadsheet so that all of the calculations are done automatically). The activity ratio for each sample bottle must be less than 1.0 in order to be shipped by IATA regulations. Each bottle is considered a package for shipping purposes, while the cooler is considered an Overpack. Shipping requirements apply to each package not to the total Overpack container.
2) Prepare the cooler(s) for shipment:
· Tape drain(s) shut.
· Place mailing label with laboratory address on top of cooler(s).
3) Prepare the sample bottles.
4) Check to see that lids are on tight and that bottle labels are firmly affixed. The labels that should be present on each sample container are the sample identification labels and a radioactive label. The radioactive label helps the lab know that the samples originated from a radioactive source.
5) Spray the bottles with tap water and wipe with a paper towel.
6) Measure the removable surface contamination of each sample bottle as follows. Wipe a 300 cm2 area of the bottle (or the whole bottle if the area is < 300 cm2) with an absorbent material (filter paper). Measure the activity of the wipe. The removable contamination for each bottle must be <1 pCi/cm2 to be shipped using exemption packaging.
7) Arrange the sample containers in front of their assigned coolers.
8) Each sample container should be wrapped in bubble wrap. Seal each sample container in a separate zip-lock plastic bag and arrange the sample containers in the coolers.
9) Fill the remaining space with bio-degradable peanuts.
10) Sign the chain?of?custody (COC) form (or obtain the signature) and indicate the time and date the samples are relinquished to the overnight carrier.
11) Seal the proper COC copy and a free of loose contamination/limited quantity statement in a zip-lock bag and place it inside the cooler.
12) Attach a "RADIOACTIVE" label to the inside of the cooler lid, or write the word "RADIOACTIVE" on the inside of the cooler lid. The word must be visible to anyone who opens the cooler during transport.
13) Close the lid and latch the cooler.
14) Sign and date two custody seals. Carefully peel the custody seals from their backings and place them intact over the front and back edges of the cooler. Cover the seals with clear protection tape.
15) Tape the cooler shut on both ends, making several complete revolutions with strapping tape (do not cover the custody seals).
16) Take wipe samples of the top, bottom, and both sides of the cooler. Obtain a dose rate of the cooler. Record all survey results and verify the cooler can be released for shipping.
17) Send the shipment to the analytical laboratory via overnight carrier, completing the carrier required shipping papers.
18) Telephone the laboratory and provide the following information:
· Your name
· Project name
· Number of samples sent to the laboratory for analysis
· Air bill numbers
As an alternative, send a facsimile of the COC, including air bill numbers, and copies of any pertinent radiological survey data to the laboratory.
11.0 ANALYTICAL PROCEDURES
All samples will be analyzed to monitor site conditions under federal and state regulations, to document the radiological and chemical characteristics of the material in order to determine waste disposal pathways and to meet waste acceptance criteria. Samples will be analyzed both on-site and off-site to determine the radiological profile of the material in question.
11.1 On-Site Laboratory
All on-site radiological analyses will be performed by the radiological subcontractor using performance-based methods.
The following performance criteria are specified for radiological analyses:
· Quality control samples must routinely be analyzed, including blanks and replicated reference materials (control samples and spiked samples as applicable).
· At least one quality control sample of each type must be analyzed per batch of samples. A batch should not exceed 20 samples. The results must meet control limits derived from historical performance data, designed to indicate that analyses are within control limits. Reference material analysis is not required with every batch, but should be done on a periodic basis. In cases where material availability or technical feasibility prohibit reference material or spiked sample analyses, the lab need not meet the above requirements, but should document the reason for not analyzing a reference material or spiked sample. The QC Chemist must review and approve each occurrence.
· The lab will have a preventative maintenance program in place.
· The analytical instrumentation must be calibrated at an acceptable frequency using standards covering the range of expected sample concentrations, traceability of the standard materials must be documented and maintained. Calibration linearity must meet historically derived criteria.
· The lab will routinely measure the background signal of their instrumentation. The counting instruments source checks have performance ranges of ± 20% of the background calculation. Pre- and -post calibrations source checks must be in this range for the day's data to be acceptable. Source checks are tracked daily on a monthly control chart.
· The on-site gamma spectroscopy unit counts at a 95% confidence level of the source material activity.
· All analytical reports will require full documentation of each analysis performed, including all QC and calibration information and the raw data necessary to allow for recalculation of the result.
11.2 Off-Site Laboratory
All samples analyzed by the off-site laboratory will be in accordance with SW-846 methods, ASTM methods, U.S. Department of Energy (DOE) methods, and Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM) radiological analytical methods. These methods are performance based, and quality control samples will be analyzed as per the laboratory's Quality Assurance Management Plan (QAMP). This management plan describes all methods and procedures for ensuring quality analytical results.
Chemical analyses (lead) will be performed using SW846 methods, which are performance based. The following criteria are specified for these methods (as applicable):
· Sample holding times;
· GC/MS tuning criteria (method specific);
· Initial and continuing calibration (method specific criteria);
· Detection limits (historical performance based criteria);
· Laboratory blanks (SW846 criteria);
· Laboratory control sample (historical performance based criteria);
· Surrogate spike recoveries (historical performance based criteria);
· Matrix spike/duplicate analysis (historical performance based criteria); and
· Internal standard area (method specific criteria).
All radiological analyses will be performed using performance based methods. A laboratory will usually perform better using methods it routinely employs as opposed to using other methods with which it has less experience. The lab is also likely to have historical data on performance for methods it routinely uses. The following performance criteria are specified for radiological analyses:
· All analytical methods must be derived from reliable sources, such as those listed in Section 7.7 of MARSSIM.
· Quality control samples must be routinely analyzed, including blanks, replicates, reference materials, control samples and spiked samples.
12.0 CALIBRATION PROCEDURES AND FREQUENCY
12.1 On-Site Instrumentation
Analyses will be performed in the on-site lab using performance based criteria. Performance based criteria for field instrumentation calibration are as follows:
· Each radiation detecting instrument directly or indirectly used in sample analysis must be verified to be calibrated at the start of each day and tested to demonstrate that the instrument is operating properly.
· Standards preparation must document reagent purity, traceability, and preparation method.
· Balances must be checked daily to demonstrate proper operation; the daily checks must be documented.
Refrigerator and freezer temperature must be checked daily to demonstrate proper operation; the daily checks must be documented.
A calibration/maintenance file will be kept on all equipment used in sampling or field analysis. It should include the following information for equipment requiring periodic calibration and instrumentation requiring daily calibration:
· Name of the equipment;
· Equipment identification/serial number;
· Manufacturer;
· Calibration frequency (daily, weekly, monthly);
· Calibration certifications provided by the manufacturer or other outside agency (periodic calibrations only);
· Date of last calibration;
· Manufacturers' operating instructions;
· Manufacturers' calibration and maintenance instructions; and
· Vendor location for purchase of spare and replacement parts (when applicable).
12.2 Off-Site Laboratory Instrumentation
The off-site laboratory will calibrate all instrumentation utilizing manufacturer, USEPA, or ASTM methods. These procedures are published in operation-specific and corporate SOPs.
Radiological and chemical analyses will be performed in the off-site lab using performance based criteria.
· Each radiation detecting instrument directly or indirectly used in sample analysis must be verified to be calibrated at the start of each day and tested to demonstrate that the instrument is operating properly.
· Standards preparation must document reagent purity, traceability, and preparation method.
· Balances must be checked daily to demonstrate proper operation; the daily checks must be documented.
· Refrigerator and freezer temperature must be checked daily to demonstrate proper operation; the daily checks must be documented.
13.0 PREVENTIVE MAINTENANCE
Proper preventive maintenance of field equipment is a necessary element in achieving equipment reliability and minimizing equipment downtime.
Field equipment will be properly calibrated, charged, and in good general working condition at the beginning of each day. Any non-operational field equipment will be removed from service and returned to the equipment center and a replacement will be obtained. Most field equipment will not be repaired in the field. Selected spare parts will be kept in the field to be inserted as replacements are needed. Maintenance records will be kept for each field instrument. These records will be reviewed prior to instrument use in the field to ensure that all maintenance and calibration are up-to-date.
All field instruments will be properly protected against inclement weather conditions during the field investigation. Each instrument is specially designed to maintain its operating integrity during variable temperature ranges that are representative of ranges that will be encountered during cold-weather working condition. At the end of each working day, all field equipment will be decontaminated, taken out of the field, and secured in a cool, dry room for overnight storage, as applicable.
All subcontractor equipment will arrive at the site in proper working condition. Before the start of work each day, the field supervisor will inspect all equipment for fluid leaks. If a leak is detected, the equipment will be removed from service for repair or replacement.
In addition, the following general preventative maintenance guidelines will be followed:
1. Be certain that each instrument is working properly before going to the field. Performance calibration to be sure it falls within the right range.
2. Make sure the proper electrical power is available in the field.
3. Know what you are doing before you operate any instrumentation. Get instruction or help if you are unsure.
4. If the instrument is battery operated, have a spare battery. If it requires charging, be sure to charge it each night.
The on-site laboratory will be required to have a detailed preventative maintenance program, which includes documentation of procedures performed. Details regarding the off-site laboratory's preventative maintenance program can be found in the laboratory's QA/QC Plan.
14.0 CONTRACTOR CHEMICAL QUALITY CONTROL
There are five features of work that require chemical quality control during the BOMARC remediation project:
1. Mobilization
2. Sample collection and on-site analysis
3. Final status survey
4. Off-site sample shipment, and
5. Off-site sample analysis
The individual tasks associated with each definable feature of work were grouped to facilitate implementation of the 3-phase inspection process. QC measures to be implemented during each definable feature of work are discussed below.
14.1 Mobilization
Mobilization consists of furnishing all materials, labor, and equipment to perform the work indicated in the Site Operations Work Plan. Part of the mobilization task includes set up of the on-site laboratory.
The Certified Health Physicist (or Designee), with assistance from the Certified Health Physicist will check that the following are in place at the on-site laboratory:
· The required instrumentation is on-site and in good working order;
· All supplies have been procured from a reputable supplier, in sufficient quantity;
· Calibration standards are National Institute of Standards and Technology (NIST) traceable;
· All instruments have been properly calibrated;
· Analysts have the appropriate education and experience for their assigned tasks;
· The lab has implemented a well-defined quality assurance program; and
· Analytical methods are available for each type of analysis to be performed; analysts are familiar with the methods.
14.2 Sample Collection and On-Site Sample Analysis
Various types of samples will be collected throughout the remediation, including air filters, decontamination wastes, wipes, soils being shipped for disposal, and waste profile samples.
During sampling, the QC Manager (or Designee) with the assistance from the Certified Health Physicist will check that:
· Samples are collected as specified in the SAP;
· Sample documentation is being properly completed;
· Sampling equipment is properly decontaminated; and
· Quality control samples are collected at the proper frequency.
The QC Manager (or Designee) with assistance from the Certified Health Physicist will check the laboratory during on-site sample analysis for the following:
· Calibration standards are NIST traceable;
· All instruments have been properly calibrated at the method-required frequency;
· Analytical methods have been derived from reliable sources;
· Quality control samples are being analyzed at the proper frequency;
· Appropriate corrective actions are being taken when the QC sample results are outside control limits;
· Preventive maintenance is regularly performed and documented; and
· The lab routinely measures the background signal of their instrumentation.
14.3 Final Status Survey
During the Final Status Survey the QC Manager (or Designee) with assistance from the Certified Health Physicist will check that:
· The grid has been properly laid out and documented;
· Sampling locations have been properly located;
· The appropriate number of samples were collected;
· Samples are collected as specified in the SAP;
· Sample documentation is being properly completed;
· Sampling equipment is properly decontaminated; and Quality control samples are collected at the proper frequency.
The QC Manager (or Designee) with assistance from the Certified Health Physicist will check the laboratory during on-site sample analysis for the following:
· Calibration standards are NIST traceable;
· All instruments have been properly calibrated at the method-required frequency;
· Analytical methods have been derived from reliable sources;
· Quality control samples are being analyzed at the proper frequency;
· Appropriate corrective actions are being taken when the QC sample results are outside control limits; and
· Preventive maintenance is regularly performed and documented.
14.4 Ship Samples for Off-Site Analysis
Various types of samples will be shipped to an off-site laboratory for analysis. The QC Manager (or Designee) with assistance from the Certified Health Physicist will check the shipping process for:
· Properly completed chain-of-custody forms;
· Proper sample documentation;
· Shipment in accordance with IATA regulations; and
· Proper sample packaging.
14.5 Off-Site Sample Analysis
Various samples will be analyzed by an off-site laboratory. The QC Manager (or Designee) with assistance from the Certified Health Physicist will verify that the off-site lab has performed the following:
· Calibration standards are NIST traceable;
· All instruments have been properly calibrated at the method-required frequency;
· Analytical methods have been derived from reliable sources;
· Quality control samples are being analyzed at the proper frequency;
· Appropriate corrective actions are being taken when the QC sample results are outside control limits;
· Preventive maintenance is regularly performed and documented;
· All supplies have been procured from a reputable supplier, in sufficient quantity;
· Analysts have the appropriate education and experience for their assigned tasks;
· The lab has implemented a well-defined quality assurance program;
· Analytical methods are available for each type of analysis to be performed, analysts are familiar with the methods;
· SW846 analyses meet QC criteria;
· Analytical reports contain all of the information needed to perform data validation; and
· Balances, refrigerators, freezers, and the water supply are checked and documented daily.
14.6 Performance And System Audits
14.6.1 Field Procedures
During field activities, the QC Manager or his designee will observe and audit field sample collection activities, sample handling procedures, and chain of custody/documentation procedures employed by Site personnel against the Sampling Plan requirements. The field audit will be performed following the initiation of major field activities, to verify the following conditions:
· Field activities are in conformance with documents governing project operations;
· Actual practice agrees with written instructions;
· Appropriate field logbooks have been established; and
· Deficiencies have been addressed and appropriate corrective actions have been initiated.
The QC Manager or designee will have full authority to stop Site operations if procedures are not in conformance with the QC objectives set forth in the project documents. A report documenting the audit findings and recommendations will be sent to the Project Manager for inclusion in the project files.
The contractor(s) affected by the audit will also be notified of the audit findings and recommended corrective action.
14.6.2 Laboratory
The on-site laboratory will be audited by the QC Manager or his designee prior to site excavation activities. Audits by the QC Manager or his designee will be performed a minimum of once per 3 months during field activities. Serious deficiencies discovered during the audits will be documented and corrective actions will be taken within two business days of discovery of the deficiencies. Samples will not be analyzed until the laboratory has corrected all major deficiencies. A copy of the audit will be sent to the Project manager for inclusion in the project files.
Each radiation detecting instrument directly or indirectly used in sample analysis must be verified to be calibrated at the start of each day and tested to demonstrate that the instrument is operating properly.
15.0 CORRECTIVE ACTIONS
15.1 Field Activities
The initial responsibility for reporting and documenting an out-of-control event lies with the on-site personnel. On-site personnel must immediately notify the Site Project Manager, who is responsible for immediately reporting out-of-control events to the QC Manager and for documenting the event. The Site Project Manager is responsible for investigating identified problems and implementing corrective action, or for assigning other personnel to perform these tasks. The Site Project Manager must also verify that the corrective action has eliminated the problem in question. All field personnel have the authority to stop work when an out-of-control event has occurred that could impact the quality of the site work. Corrective actions will be decided upon by the Site Project Manager in consultation with the Project Manager and QC Manager.
Corrective actions in the field are likely to be immediate in nature and can be implemented by field personnel or the Site Project Manager; the corrective action will usually involve reanalysis, repeating the instrument calibration, or resampling at a particular location. Once an out-of-control event has occurred and the Site Project Manager and QC Manger have been notified, the following steps will be taken to regain control:
1. The Site Project Manager will investigate and determine the probable cause of event;
2. The Site Project Manager will consult with the QC Manager regarding appropriate corrective actions;
3. The Site Project Manager will decide on an appropriate corrective action;
4. The Site Project Manager will implement or direct the Contractor(s) to implement immediate corrective action; and
5. The QC Manager will verify the effectiveness of the corrective action and decide on further actions if necessary.
The QC Manager will document each out-of-control event by recording the situation and its resolution (including all notifications and corrective actions taken) in the Daily QC report. Possible causes, proposed corrective action(s), and the date the corrective action(s) occurred will be recorded. The QC Manager will check to be sure that corrective action has been taken, the corrective action appears effective, and the situation has been fully resolved.
15.2 Laboratory
At the laboratory level, re-analysis and other corrective measures are required if specific control limits established in the standard methods are exceeded. The technician directly responsible for the test must know the current operating and acceptance limits, and take the required corrective actions (including sample re-analysis). Bench results must also be reviewed by the laboratory staff to insure that all method-specified QA requirements have been met. The report is then prepared and submitted for final QA check. Each person in the review process has the authority to require re-extraction and re-analysis of a sample if QC problems are identified.
The Certified Health Physicist is responsible for proper data validation. If data validation or QC audits result in detection of unacceptable conditions, the Certified Health Physicist will be responsible for timely notification of the laboratory. The laboratory Quality Assurance Officer will be responsible for developing and initiating corrective action, and verifying that the corrective action has resolved the problem. Corrective action may include:
· Re-analyzing samples if holding time criteria permit;
· Re-sampling and analyzing;
· Evaluating and amending sampling and analytical procedures; and
· Accepting data acknowledging level of uncertainty.
Data inadequacies attributable to Site-specific interference or conditions may require that sampling procedures or analytical.
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