2012-08 – QAPP Surface Gamma Scans and Down-Hole Gamma Logs

2012-08-qapp-surface-gamma-scans-and-down-hole-gamma-logs

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Re: meter cable for Westlake G;;J Dan Gravatt to: CharlesA Hooper 10/25/2012 09:44AM
Chuck, I figured a paper towel sprayed with alconox solution for decon. Let me know how the marks stand up to that Here’s the final QAPP.
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West Lake Gamma Scan QAPP.doc
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 11201 Renner Boulevard, Lenexa, KS66219 Phone (913) 551-7324
Principles and integrity are expensive, but they are among the very few things worth having.
CharlesA Hoop’-=e-‘-r__Dan, I got the meter cable marked yesterday. 0 … 10/25/2012 09:29:23 AM
From: CharlesA Hooper/R7/USEPA!US To: Dan GravatUR7/[email protected] Date: 10/25/2012 09:29AM Subject: meter cable for Westlake
Dan,· I got the meter cable marked yesterday. One foot increment hash-marks with labels every five feet. Now I need to make sure this marker is going to do the trick for decon; how were we planning on doing that and was there a final QAPP? I figured wet wipes but I don’t remember what was in the plan. If the wet wipes take off the marker then I’ll have to try it again with a different type but I wanted to let it dry before trying it yesterday. -Chuck
Please note our new address in Lenexa, Kansas.
Chuck Hooper, CHP Radiation Safety Officer US EPA, Region 7 11201 Renner Boulevard Lenexa, Kansas66219
(913) 551-7271 office [email protected]

At-Title and Approval
Quality Assurance Project Plan
Surface Gamma Scans and Down-hole Gamma Logs

West Lake Landfill OUt
Bridgeton, Missouri

August, 2012

Diane Harris Date: Regional Quality Assurance Manager
DeAndre Singletary, Chief Date: MOKS Branch SUPR Division, EPA Region 7
Dan Gravatt, RPM Date: MOKS Branch SUPR Division, EPA Region 7
A2 -Table of Contents
A 1. Title and Approval
A2. Table of Contents

A. Project Management …………………………………………………………………………………………………… 3
A3. Distribution List …………………………………………………………………………………………….. 3
A4. Project/Task Organization ……………………………………………………………………………….. 3
AS. Problem Definition/Background ………………………………………………………………………. 3
A6. Project/Task Description ………………………………………………………………………………… .4
A7. Quality Objectives and Criteria for Measurement Data ……………………………………….. 5
AS. Special Training Requirements/Certification ……………………………………………………… 6
A9. Documentation and Records ……………………………………………………………………………. 6

B. Measurement/Data Acquisition …………………………………………………………………………………….. 6
B1. Sampling Process Design ………………………………………………………………………………… 6
B2. Sampling Methods Requirements …………………………………………………………………….. ?
B3. Description of Decontamination Procedures for Sampling Equipment.. ………………… ?

84. Sample Handling and Custody Requirements …………………………………………………….. 8

85. Analytical Methods Requirements ……………………………………………………………………. 8

86. Quality Control Requirements ………………………………………………………………………….. 8

87. Instrument/Equipment Testing, Inspection, and Maintenance Requirements ………….. 8

88. Instrument Calibration and Frequency ………………………………………………………………. 8
B9. Inspection/ Acceptance Requirements for Supplies and Consumables …………………… 8
8 I 0. Data Acquisition Requirements ……………………………………………………………………… 8
B11. Data Management ………………………………………………………………………………………… 9

C. Assessment/Oversight …………………………………………………………………………………………………. 9
C1. Assessments and Response Actions ………………………………………………………………….. 9
C2. Reports to Management ………………………………………………………………………………….. 9

D. Data Validation and Usability ………………………………………………………………………………………. 9
Dl. Data Review, Validation, and Verification Requirements ……………………………………. 9
D2. Validation and Verification Methods ………………………………………………………………… 9
D3. Reconciliation with User Requirements ………………………………………………9

Abbreviations and Acronyms
Figure I: OU1 Extents and Monitoring Well Locations (Figure 2 from 2012 PRP SAP)
Table I: List of Monitoring Wells to be Logged (Table 3 from 2012 PRP SAP)
Appendix A Field SOPs
A. Project Management
A3. Distribution List
This quality assurance project plan (QAPP) is prepared for the West Lake Landfill site in Bridgeton, Missouri, and is submitted as documentation of the protocols and procedures to be followed during collection of surface and down-hole gamma scans at the site. Distribution of this plan will be as follows:
Dan Gravatt, RPM, MOKS/SUPR, U.S. EPA Region 7 On-Scene Coordinators (OSCs) assisting with field data collection, U.S. EPA Region 7 Diane Harris, RQAM/ENSV, U.S. EPA Region 7
A4. Project/Task Organization
This project is being managed and administered by EPA Region 7 according to the responsibilities described below:
Dan Gravatt, RPM
Project Manager
MOKS Branch/SUPR Division (913) 551-7324
Responsibilities: Project Management; Field Team Leader; Field Data Collection Project
Design and Implementation
OSCs (to be determined) and/or RPMs
MOKS Branch, ERNB and/or ERSB sections
Responsibilities: Field data collection

Tetra Tech (START Contractor)
Responsibilities: Field technical support for gamma scanning and figure preparation

A5. Problem Definition/Background
The purpose of this QAPP is to support the collection of surface and down-hole gamma scans. The objective ofthis work is to collect additional data on the distribution of radionuclides within Operable Unit 1 (OUl).
Surface gamma scans and down-hole gamma scans ofboreholes were conducted as part of the Remedial Investigation (RI) for the site in the late 1990s, and the data was summarized in the RI Report (EMSI, April 2000). Work under this QAPP will re-scan the surfaces ofboth areas of OU 1 for gamma emissions, as well as scanning all accessible monitoring wells at the site for gamma emissions. Some of the monitoring wells were previously scanned (as boreholes, prior to their completion as wells) during the RI, and some have never been scanned.
Gamma scanning field work will be performed by the RPM and OSCs using field.portable scanning instruments. No samples of any media will be collected.
A6. Project/Task Description
The objective ofthis study is to collect additional data on the distribution ofradionuclides within OU 1. This QAPP addresses field procedures to collect the surface and down-hole gamma scan data. The measurement and data acquisition methods specified below have been selected to meet this objective. Figure 1 illustrates the site layout and monitoring well locations for down.hole scans.
The data from this study will be assembled and provided to Dan Gravatt, RPM, MOKS/SUPR Division, U.S. EPA Region 7.
A6.1 Work to be perfonned
The scope offield activities to be performed for these gamma scans includes the following:

Scanning the surface ofOUl with a Ludlum Model2241-3 and Nal Tl detector; and


Scanning all accessible and intact monitoring wells associated with OU I and OU2 with a Ludlum Model 2241-3 and Ludlum 44-62 Nal probe to the maximum depth ofthe well or 150 feet, whichever is less.

(
1) Measurements

(a)
Areas and monitoring wells to be sampled

All accessible portions of the surface ofOUl will be scanned with the Ludlum Model 2241-3 and its Nal Tl detector. It is anticipated that vegetation or rubble piles may prevent scanning ofportions of Area 2 of OU 1. All accessible and intact monitoring wells on-site capable ofpassing the Ludlum 44-62 Nal down-hole probe will be scanned.
(b) Analyses
Both the Ludlum Model2241-3 with Nal Tl detector and the Ludlum 2241-3 with 44-62 Nal probe will collect real-time data on gamma intensity. No laboratory samples will be collected or analyzed.
(2) Standards/Criteria
As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations ofany radioisotopes in environmental media, there are no applicable thresholds or criteria for determining whether a particular gamma count value is acceptable or unacceptable. This data will be used to qualitatively update EPA’s knowledge of the distribution ofradionuclides at the site.
(3) Personnel/Equipment Requirements
All personnel perfonning activities covered by this QAPP shall comply with the Occupational Safety and Health Act, as well as EPA regulations for worker health and safety. Personnel requirements are discussed in Section A8. Level D PPE consisting of steel-toed boots, appropriate gloves, long pants and long-sleeved shirt at a minimum will be required for field personnel. Additional PPE for operating EPA’s utility terrain vehicles will include full-face helmets and eye protection.
(4) Assessment Techniques
Field instrumentation will be calibrated and demonstrated to be working properly as described in 8.7 below.
(5) Project Schedule
The anticipated schedule for this sampling effort will consist ofone field scanning mobilization in August, 2012. The field work is anticipated to take one week.
(6) Documentation
Data collection activities will be documented with the following (more detailed descriptions of the documentation is provided in Sections A9, 810, and C2 of this QAPP):
Field records;
Data Summary tables; and
Data Summary figures.

A7. Quality Objectives and Criteria for Measurement Data
The purpose of this investigation is to obtain additional gamma scans ofthe surface and down-hole gamma logs of accessible monitoring wells. No samples of any media will be collected. As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, the following quality objectives are generally in a narrative form.
Representativeness will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings correlate to the distribution of gamma-emitting radionuclides at the site.
Comparability expresses the confidence with which one· set of analytical data may be compared with another. Comparability will be qualitatively addressed by comparing the results of the surface gamma scan with the results of the previous RI surface gamma scan; however, due to differences in the methodologies used, differences in the two scan results will not necessarily indicate any change in conditions at the site
Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under normal conditions. Field completeness is a measure of the amount of valid measurements obtained from the measurement taken in the project. The field completeness objective for this project will be 80%. I 00% completeness is not required for the data to be useable for its intended purpose.
Accuracy and precision will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings accurately measure gamma emission rates at the site.
AS. Special Training Requirements/Certification
All personnel who will be on-site performing field activities associated with this investigation must have successfully completed an initial 40-hour hazardous waste operations training course and, thereafter, an annual 8-hour refresher course. The training must comply with Occupational Safety and Health Administration (OSHA) regulations found in 29 Code of Federal Regulations ( CFR) 191 0.120( e). Personnel must also have had advanced radiation safety training, and will be required to wear a thermoluminescent dosimeter and electronic personal dosimeter while on-site. Personnel must be trained and certified to operate EPA’s utility terrain vehicles, which will be used for the surface gamma scan.
A9. Documentation and Records
The project manager will be responsible for ensuring the most current version of the QAPP is available and distributed to all involved parties, and that data collected during this field work is properly stored and reported to stakeholders.
B. Measurement/Data Acquisition
B I. Sampling Process Design
The surface gamma scan will be conducted with a Ludlum Model 2241-3, with a 3-by 3.inch Nal Tl scintillator probe. The scan will be conducted in a serpentine pattern across each area of OU 1, with spacing between scan lines of 30 feet (the RI QAPP specified a 30’ grid). A narrower spacing and/or scan lines at different angles may be used in areas exhibiting higher gamma counts to provide more detail, based on field observations. The detector will be held approximately twelve inches above the ground surface while the surveyor moves the detector at a constant speed approximating walking pace, and the system will collect a reading every two seconds. Global Positioning System (GPS) data will be simultaneously collected, and the resulting gamma results will be mapped. Prior to scanning the site, background gamma levels will be established at a nearby uncontaminated area (the RI QAPP specified “Local background will be established by taking a measurement off-site on the open field east of the site and east of the St. Charles Rock Road entrance to the site”).
The down-hole gamma scan will be conducted with a Ludlum Model2241-3, with a 44.62 detector. The detector will be lowered to the bottom of each accessible well or to a maximum depth of 150 feet, whichever is less. The detector will then be raised in one-foot increments, and measurements will be recorded at each interval using the scaler set for a 6-second count.
Groundwater samples will not be collected during this work, though previously available analytical results from other studies may be used in interpreting the data from these down-hole gamma scans. Groundwater elevations within the wells will not be measured during this work, though previously available water level measurements from other studies may be used in interpreting the data from these down-hole gamma scans.
Wells PZ-1 03SS, PZ-1 04SS, PZ-1 05SS, PZ-1 08SS, PZ-111 SO and PZ-116SS are designated as background wells to represent naturally-occurring gamma emissions in the subsurface geologic materials. These wells were selected for their depth ( 150 feet or more), their distance from the OU I cells, and their lack of any historical detections of radionuclides in groundwater above applicable standards.
B2. Sampling Methods Requirements
Standard operating procedures for the gamma scanning instrument and detectors will be followed. These SOPs are included in Appendix A.
The utility terrain vehicle will be driven at a speed appropriate to generate a thorough density of data points and to minimi?e the generation ofdust.
The EPA field team leader will detennine the need for any change in sampling method or locations, if field personnel note difficult site conditions. Any corrective actions required during the implementation of field sampling activities will be documented by the field team leader.
B3. Description of Decontamination Procedures for Sampling Equipment
The down-hole gamma probe shall be decontaminated prior to logging the first well and between each well by washing with a soap solution (such as Alconox) and rinsing with potable water. Previous analytical results for these wells indicate that several metals and volatile organic compounds are present in some wells above their maximum contaminant levels, including arsenic, lead, and benzene. Concentrations of these contaminants are not high enough to warrant additional PPE or more stringent decontamination methods. The rinse water will be poured onto the ground away from the well after use.
The surface gamma scan instrument does not contact the land surface and does not require decontamination.
The utility terrain vehicles, field personnel boots, and any other equipment potentially contaminated by soil will be decontaminated by dry brushing to remove the material. Equipment will then be scanned with a Ludlum Model 44-9 Geiger-Muller “pancake probe” to ensure that any radioactive contamination has been removed down to a level ofthree times the background count rate with the pancake probe.
Any solid investigation-derived waste such as gloves or paper towels will be bagged, surveyed with the ”pancake probe” to ensure that radiation levels do not exceed three times the background count rate, and disposed of at the solid waste transfer facility on-site.
B4. Sample Handling and Custody Requirements No samples of any media will be collected during this work. B5. Analytical Methods Requirements No analytical methods will be used for this work. B6. Quality Control Requirements
Quality control will be maintained during the field work by operating the instruments in accordance with the manufacturer’s instructions and EPA’s SOPs. B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements
The field equipment testing, inspection, and maintenance will be performed in accordance with the manufacturer’s recommendations. B8. Instrument Calibration and Frequency Field equipment calibrations will be performed in accordance with the manufacturer’s recommendations prior to mobilization. B9. Inspection/ Acceptance Requirements for Supplies and Consumables No supplies or ,consumables will be required for this work. B10. Data Acquisition Requirements
Data acquired from the surface gamma scan instrument and its GPS tracker will be downloaded to EPA computer systems and mapped as necessary to support program goals. Data from the down-hole gamma scanner will be recorded by hand in field logbooks and transcribed into an EPA computer system, or entered directly into an EPA laptop in the field in real time.
B 11. Data Management
Data will be stored and backed up on EPA computer systems, filed in the Records Center, and distributed to stakeholders as needed. Documents filed in the Records Center are stored according to standard records retention schedules.
C. Assessment/Oversight
C 1. Assessments and Response Actions
The EPA QA manager or their designee may conduct an audit of the field activities for this project if requested by the EPA project manager. The EPA QA manager will have the authority to issue a stop work order upon finding a significant condition that would adversely affect the quality and usability of the data. The EPA project manger will have the responsibility for initiating and implementing response actions associated with findings identified during the on-site audit. Once the response actions have been implemented, the EPA QA manger will perform a follow-up audit to verify and document that the response actions were implemented effectively.
C2. Reports to Management
A report of the field work and analytical results will be prepared by the project manager and copies shared with the state and other stakeholders. This report will also include information on any performance evaluations, audits, and significant QA problems, as applicable.
D. Data Validation and Usability
Dl. Data Review, Validation, and Verification Requirements
The EPA Project manager will be responsible for overall validation and final approval of the data in accordance with project purpose and use of the data.
D2. Validation and Verification Methods
As the data collected by the planned field work is semi-quantitative, no additional data validation or verification methods are planned.
D3. Reconciliation with User Requirements
Once the data results are compiled, the EPA project manager will review the data results to detennine if they fall within the acceptance limits as defined in this QAPP. Completeness will be evaluated to determine if the completeness goal for this project has been met. If the completeness objective has not been met, the EPA project manager will determine an appropriate course of action. Failure to meet the completeness objective will not necessarily require re.sampling.
..

Upon compilation of the data, the RPM will review the data in relation to the quality objectives and criteria for measurement, to identify any limitations on the use of the data. The RPM will evaluate data to ensure the information sufficiently characterizes the distribution of gamma-emitting radionuclides at the site, and assess the degree to which the Quality Objectives in A. 7 and the Quality Control measures in B.6 have been met. If the RPM detennines data quality indicators do not meet the project requirements, then the data may have to be discarded and re-sampling may be required.
CFR EPA GPS
osc
OSHA
ou
PPE PRP QA QAPP QC RI RPM RQAM SAP SOP
sow
Abbreviations and Acronyms
Code of Federal Regulations
U.S. Environmental Protection Agency Global Positioning System On-scene commander Occupational Safety and Health Administration operable unit personal protective equipment potentially responsible party quality assurance quality assurance project plan quality control remedial investigation Remedial project manager regional quality assurance manager sampling and analysis plan standard operating procedure statement of work