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Appendix E: Site Health and Safety Plan Statement of Acknowledgement

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Appendix E: Site Health and Safety Plan Statement of Acknowledgement FINAL SITE CHARACTERIZATION WORK PLAN VOLUME I: SAMPLING AND ANALYSIS PLAN FOR THE FOREST GLEN ANNEX OF WALTER REED ARMY MEDICAL CENTER, SILVER SPRING, MD AND THE LEASED GILLETTE BUILDING, ROCKVILLE, MD Contract No. W912-DQ-08-D-0003, Delivery Order DA02 Prepared for: USACE Baltimore District 10 S. Howard Street Baltimore, Maryland 21201 Prepared by: 103 E. Mt. Royal Ave Suite 2B Baltimore, Maryland 21202 October 2009 Draft Final Site Characterization Work Plan Vol I (SAP) Comments WRAMC Forest Glen Annex Comment Page Section/Figure/ Commenter- Response Comment Response Number Number Table/Appendix ORG By Authorization 680 used P-32 until late 2006 and had S-35 in Burton- inventory until Nov of 2005. We have equipment and room final 1 17 Gillette Building WRAMC HPO surveys from January and February 2007. Cabrera Concur. Affected sentence has been revised accordingly. Burton- isotpes used had half-lives less than one year should be changed 2 18 building 501 WRAMC HPO to less than 120 days (every where in document) Cabrera Concur. Universal edit has been made. These rooms will be added to the text, but they have already been called out as rooms that have had final surveys conducted in the main table. Since this survey is 3.5-1 Gillette Burton- meant for the building as a whole, these rooms can be 332Building WRAMC HPO Add rooms and sinks 1071,1110,1086,1097 (see comment 1)? Cabrera ignored when doing scans/surveys. Concur. Affected text has been revised to note thorium-230 (or other equivalent alpha emitter). Along those lines, Tc- 99 has been revised to note "(or other equivalent beta Burton- emitter)," and Cs-137 has been revised to note "(or other 4 51 8.4.2.2 WRAMC HPO Specifies a thorium-230 source, we have Pu-239 Cabrera equivalent gamma emitter)." Burton- 5 91 3.2 WRAMC HPO see comment 2 Cabrera See above response Burton- 6 94 Notes WRAMC HPO see comment 2 Cabrera See above response Per Mr. Burton's inventories, RAM usage continued in the Gillette Building through 2005, despit close-out of the north wing ground floor in 1999. The recommendation to do the entire building as one Class 3 survey unit was made to confirm/verify/tie-in all previous survey/closure data to one final building closure, as well as ensure no re- contamination post closure due to migration of material Barbour- post-1999. A clarification statement has been added in 1 25 1.3 CENAB Why are we doing the north wing then? Cabrera text. Barbour- 1) Where is Co-57? Co-57 values have been added to the table and a column 2 41 Table 3-2 CENAB 2) Probably best to have removable in here as another column Cabrera for removable has been added as well. To safeguard against potential future concern whether different guides had different values listed, both tables of Barbour- Why are these here? It is the same as the 1757 values, just values are listed to show that both regulatory guides were 3 41 Table 3-2 CENAB rounded. Cabrera consulted in preparation of this plan. Text has been revised accordingly - even though Co-60 is not low energy, it still represents the lowest screening Barbour- value when compared to the low energy beta emitting 4 41 Table 3-2 CENAB Co-60 is not low energy. Cabrera RCOPCs. 10/13/2009 1 of 2 Draft Final Site Characterization Work Plan Vol I (SAP) Comments WRAMC Forest Glen Annex Comment Page Section/Figure/ Commenter- Response Comment Response Number Number Table/Appendix ORG By This value was a remnant of an old DCGL from a previous Barbour- iteration of the plan. The text has been changed to reflect 5 43 3.7 CENAB 19.5? Cabrera the correct value. Concur. The text in this section will be changed to include all beta emitters. Liquid scintillation will provide results for all beta emitters. The standard LSC setup has energy window for H-3 (up to 18.5 keV max ), C-14 (up to 157 What about all of the other low energy beta emitters. Needs HP keV), and an open window (157 to ~2 MeV) for higher Barbour- review to ensure we are properly addressing all of the low energy energy betas. We would see indication of Cs-137, Ni-63, 6 43 3.7 CENAB beta emitters. Cabrera and Co-60 contamination in the open window, if present. Concur. The results of the gamma spectroscopy scan of system samples will be investigated for all potential Barbour- gamma-emitting radionuclides. The reference to Co-60 will 7 43 3.7 CENAB No, g-spec is radionuclide specific. Needs HP review. Cabrera be removed in favor of a reference to the project DCGLs. This value was a remnant of an old count time from a Barbour- previous iteration of the plan. The text has been changed 8 46 4.1.1 CENAB not in table?? Cabrera to reflect the correct value. DU is not limiting for surface measurement count times due to the easy to detect 2.2 MeV beta from Pa-234m. However, the survey team will take a conservative approach and count potentially impacted areas covered Barbour- How long do we need to count beta in order to cover DU? Is it with mastic (renovated areas) for 2 minutes to account for 9 46 4.1.1 CENAB possible? Cabrera the decreased surface effiency. I believe that the only comment that I have is for a find and replace to be done throughout the document where it refers to Forest Glen as a Walter Reed Annex. Since 1 Oct 2009, it is now Fort Detrick's Annex. I think that in the first paragraph or page, something should be written that explains that. It makes sense to leave the part about BRAC 2005 and it being our Annex at the time and how the BRAC 2005 directive to close WRAMC is what drove the NRC license termination and subsequent decommissioning of all locations. Then, it can explain that the Forest Glen Annex was transferred to be under the command and control of Fort Detrick on 1 Oct 2009. Thereafter, it should be referred to only as the Forest Glen Annex; no mention of WRAMC Delp-WRAMC or Ft Detrick so as to not cause confusion if someone picks up 10 General General BRAC the document later and only reads a portion. Cabrera Acknowledged. Affected text will be revised as appropriate. 10/13/2009 2 of 2 Sampling and Analysis Plan FINAL Walter Reed Army Medical Center, Forest Glen Annex TABLE OF CONTENTS SECTION PAGE 1.0 PROJECT DESCRIPTION ..........................................................................................1-1 1.1 SUMMARY OF EXISTING SITE DATA..............................................................................1-3 1.2 SITE HISTORY AND RADIOLOGICAL CONTAMINANTS....................................................1-5 1.3 SUMMARY OF IMPACTED BUILDINGS/AREAS ................................................................1-8 1.4 SUMMARY OF NON-IMPACTED BUILDINGS/AREAS .......................................................1-9 1.5 SUMMARY OF IMPACTED AREAS NOT TO BE ADDRESSED IN THIS INVESTIGATION ....1-10 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES .....................................2-1 3.0 SCOPE, OBJECTIVES, AND SURVEY DESIGN ....................................................3-1 3.1 SCOPE ...........................................................................................................................3-1 3.2 OBJECTIVES ..................................................................................................................3-3 3.3 DATA QUALITY OBJECTIVES.........................................................................................3-3 3.4 MARSSIM BASIS.........................................................................................................3-5 3.5 SURVEY DESIGN ...........................................................................................................3-9 3.6 RESIDUAL RADIOACTIVITY SCREENING LEVELS.........................................................3-11 3.7 ACTION LEVELS..........................................................................................................3-13 3.8 DECISION RULES.........................................................................................................3-14 4.0 SAMPLING APPARATUS AND FIELD INSTRUMENTATION...........................4-1 4.1 DIRECT RADIATION MEASUREMENTS ...........................................................................4-1 4.2 SMEAR SAMPLE COLLECTION AND ANALYSIS ..............................................................4-3 4.3 VOLUMETRIC SAMPLE COLLECTION AND ANALYSIS ....................................................4-3 5.0 SAMPLE CHAIN OF CUSTODY/DOCUMENTATION .........................................5-1 5.1 FIELD LOG ....................................................................................................................5-1 5.2 PHOTOGRAPHS ..............................................................................................................5-2 5.3 SAMPLE DOCUMENTATION ...........................................................................................5-2 5.4 FIELD RECORDS ............................................................................................................5-4 5.5 CORRECTIONS TO DOCUMENTATION.............................................................................5-4 6.0 SAMPLE PACKAGING AND SHIPPING.................................................................6-1 6.1 SAMPLE HANDLING ......................................................................................................6-1 W912DQ-08-D-0003/02 CABRERA SERVICES, INC. i Sampling and Analysis Plan FINAL Walter Reed Army Medical Center, Forest Glen Annex 6.2 SAMPLE TRANSPORT.....................................................................................................6-1 6.3 SAMPLE SHIPPING
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